Comments to the Industrial General Permit Amendment

Brash Industries (BI) represents more than 250 auto recyclers (SIC Code 5015) and 100 scrap recyclers (SIC Code 5093) and is the Compliance Group Leader for Compliance Groups for the afore mentioned SIC Codes. BI serves the needs of small to mid-size Permittees. BI works closely with the 5015 Permittees and represents their trade associations; California Auto Dismantling and Recyclers Alliance (CADRA), Automotive Dismantlers Association of Southern California, (ADASC), Inland Automotive Dismantlers Association (IADA), San Diego County Auto Recyclers Association (SDCARA), and Valley Auto Dismantlers Association (VADA). With the State issuing approximately 13,000 Industrial Permits of which approximately 1,000 Permits are issued to auto recycling facilities, Brash submitted comments in February, 2018 on the proposed amendment to represent the concerns and perspectives of a significant number of the Permittees.