First, the focus of this permit should be on ease of implementation to assist with maximium compliance.  The requirements for stormwater permits are not well understood outside of No. Va. jurisdictions and are seldom enforced except against large homebuilders and commercial developers.  The DCR should make every effort to synthesize the various requirements for erosion controls, storm water mangement and BMP's so that it is possible for contractors to know what is needed to comply.  This requirement will apply to Harry homeowner installing a pool or tennis court in the Ches Bay region, not ot mention single lot/custom home builders without staff to dedicate to regulatory compliance.

Second, the DCR should keep the current system or be required to respond to a Notice of Intent within a short time, such as one week; otherwise, builders will be stuck holding lots waiting for a response to the NOI.  That is an unreasonable economic hardship.

Also, the requirement for public disclosure for the SWPPP at the operator's expense is unnecessary, improper and very difficult to implement.  The SWPPP is required by statute to be kept on the site so a duplicate would have to be made for public review.  The SWPPP includes approved E&S plans, stormwater detention design plans, a narrative description of procedures to comply, records of inspections and actions taken, maps of the BMP's and various site attributes, and possibly spill prevention plans or groundwater protection plans.  It is constantly being updated and evolving and contains information on the operator's business practices that should not be subject to public scrutiny.  It is an internal document for which no legal authority exists to require disclosure.