I’m confused on what value public comments will bring to the table at this point. The public notice speaks in broad strokes: minimal impacts, streamlined pathways, continued protection. But it offers no real structure:  no thresholds, no conditions, no map of how this framework will actually function in the field.  It doesn’t discuss how this permit would improve upon the 4 current general permits and/or the ability to use “reporting only” which is already a steamlined process for proposed impacts of a small (quantity) nature.

Instead of a defined regulatory architecture, the Notice defers the entire substance of the program to a future Technical Advisory Committee process. The committee is tasked with building the rules that have not yet been shown to the public in any meaningful form.

As written, this NOIRA functions less as a proposal for informed comment and more as a placeholder for a framework yet to exist in any actionable detail. Stakeholders are asked to comment on direction without visibility into design.

A regulatory action intended to improve efficiency and reduce burden should begin with a clear framework, followed by public input on its actual mechanics. In this case, the sequence is reversed: intent is published first, while structure is postponed.

For meaningful participation, DEQ should first develop and disclose the foundational permit framework—definitions, thresholds, applicability, and compliance structure—before soliciting comment on whether it achieves the stated goals of efficiency and burden reduction.

Without that foundation, the public is not commenting on a proposal so much as a “concept of a plan”.