RCC Holdings Corp fka RCCH

[worktoplay]

frog...

I kinda miss you too...LOL

I thought posting the Chromaglas website would have been enough of a hint for the "DD" wizards on this board to realize that there's a problem here, and I intended to let it lie. But then one of the great unenlightened sent me a nasty private message...ssssooooo...

I could be here all night arguing with these "investors", but let's just deal with one of their key contentions. That RCCH has unique technology, as demonstrated by that EPA approval listing they found.

They seem to think that because IWS is the only system listed that they have some sort of corner on the market. The only reason they think this is that they have no understanding of how the regulatory system works.

First of all, the only reason RCCH/IWS submitted directly to EPA is because they HAD to. And they HAD to because Idaho is one of the very few states left that have not applied to become a designated regulatory authority under the NPDES provisions of the Clean Water Act. Nearly EVERY state in the union did so decades ago.

To become a designated agency, they must develop water quality standards and procedures for regulation of wastewater dischargers in their state that meet or exceed USEPA regulations. If they do, EPA will approve them to issue and monitor discharge permits in their state. Apparently Idaho would rather the Feds handle that for them, thus, in order to install one of these systems in Idaho, it would first have to be approved by EPA, not Idaho.

This is from the State of Idaho DEQ website:

NPDES Program Implementation

In Idaho, the NPDES permit program is administered by the U.S. Environmental Protection Agency (EPA), which means that EPA is responsible for issuing and enforcing all NPDES permits in Idaho. The state's role in this process is to certify that NPDES-permitted projects comply with state water quality standards.

State Primacy Consideration

Idaho is one of only a handful of states where the NPDES program is administered by EPA. States are encouraged by EPA to attain primacy for the program. Primacy enables states to assume responsibility for administering certain federally mandated programs, such as the NPDES program.

Montana, on the other hand, has at some point applied for and received delegated authority from EPA to issue permits directly as do most other states:

State Agency

Montana’s water quality laws are administered by the Montana Department of Environmental Quality (DEQ), Water Protection Bureau.

Delegated Permit Authority

Montana has been delegated permit authority for the NPDES permit program including stormwater permits for all areas except Indian lands. Montana has also been delegated authority from the COE for the section 404 dredge and fill permit program.

This is no small point as the "investors" here believe their system to have some sort of unique approval from EPA. The reason I posted the Chromaglas website was to show the more astute that may be here that they're not alone in the universe...lol

If they'd like to see a true sampling of their competitors (BTW, I wouldn't consider any of those companies listed in that Granada Research report to be true competitors to RCCH), all they need do is take a look at the list of similar systems approved in the state of Arizona:

http://www.azdeq.gov/environ/water/permits/download/listpro.pdf

Go to any state DNR or DEQ website (as long as they have been delegated authority) and you'll find a similar list of systems approved for use in their individual state. While they're at it, they may wish to may a note of who is NOT listed.

If anyone takes the time to do any REAL research, they'll find that in every case, these types of systems are sold by the hundreds and thousands through Distributor networks or Manufacturer's Rep networks. Not by a guy in a condo in California.

Maybe that's why, having been in business since 1993, they've only sold 23 systems in two states. And since the Granada report itself tells us how many systems they've sold since inception, has anyone on this board sat down and done a quick calculation of how much revenue this company had generated in the last 16 years? Hint...it's not much.

Hey happy camper9...seems you're the one that needs to rethink his position.

Anyway, frog, I've done alot more here than I intended. I really do wish you the best in your future endeavors. And good luck with the locals.

Later,
W2P

PS...My personal background includes 10 years experience as a Capital Program Coordinator for a major US City Water/Wastewater Authority, Technical Specialist responsible for NPDES Permit negotiation with EPA Region V and DNR for that same City, staff person to former US Water Pollution Control Administration Administrator, and 15 years Manufacturer's Representative for some of the largest water/wastewater treatment equipment manufacturers in the world, including Lakeside Equipment Corporation.