We are encouraged to see the following language being included and wondering how you defend against those staunch advocates that want WADOE or NJDEP only?

Under the "Additional State, Regional, or National Certification Programs" 

When submitting nutrient and sediment removal efficiencies from additional States, Regions or National programs, how do applicants know what the criteria for approval is if its on a case by case basis?    This sounds like an open ended process that needs to be better explained to ensure repeatability.    

Say if the Dept accepts an MTD based on an approval from Maine, Maryland, New Hampshire, Rhode Island, Vermont, Connecticut or any other state - wouldn't that allow any other MTD that has been through that particular States certification program to be approved?   Wouldn't it be best if you qualified these States ahead of time and made it easier on the applicant?    Seems like Maryland is an easy place to start for the Dept, its a neighboring state, focused on nutrients and TSS, in the Chessapeake Bay area, and is a self certifying state with its own monitoring protocol program.     This is easily on par with your assignment of 40% TP to NJDEP certified 80% TSS removal MTDs.