On behalf of the City of Chesapeake, I would like to offer the following comments:

1)  Sections 9VAC25-880-50 and 9VAC25-880-60 require that signed (paper) registration and termination statements be submitted to the VSMP Authority. We urge you to modify this language so that if an electronic format becomes available in the future, the local programs are not bound by this regulation to require submittal of paper statements. Many local programs are implementing systems which will allow electronic submittal of plans as well as electronic permit processing. This regulatory language should not be a barrier to exploring or developing an electronic option.

2)  There appears to be a conflict within the permit regulation regarding the deadline date for filing a registration statement in order to continue existing 2009 permit coverage. 9VAC25-880-30 H.1. states that registration statements must be submitted by June 30, 2014 in order to continue permit coverage, yet 9VAC25-880-50 A.2.a.(1) states that registration statements must be submitted by June 1, 2014 in order to continue existing permit coverage. I understand from discussions with DEQ staff that the intent is to require the registration statements by June 1, 2014 (and no later than June 30, 2014 in order for administrative continuance), however the current language is contradictory, confusing, and misleading. We strongly suggest that one date be referenced in both sections as the registration deadline for continuation of 2009 permit coverage.

Suggested language:  An operator who was authorized to discharge under the 2009 permit and who intends to continue coverage under this general permit must submit a registration statement by June 1, 2014. Provided the registration statement is submitted prior to June 30, 2014 the operator is authorized to continue to discharge under the terms of the 2009 permit.

Thank you for the opportunity to provide input.