Top 10 Differences Between the Municipal Regional

Permit&

Statewide General Construction Permit

Kristin Kerr, P.E., QSDEOA, Inc.

Construction Inspection Workshop

April 11, 2013

Outline Top Ten Differences provides

• Statewide General Construction Permit Information and Requirements

• Municipal Regional Permit Information and Requirements

• Applicability to Municipal Activities

• Applicability to Municipal Construction Projects

#10 Permit Issuance

Statewide General Construction Permit (CGP): • State Water Resources Control Board (State Board)• Adopted in September 2009• Regulated area: State of California

Municipal Regional Permit (MRP): • Regional Water Quality Control Board (Regional Board)• Adopted in October 2009• Regulated area: San Mateo, Alameda, and Contra

Costa Counties; northern Santa Clara County; Fairfield, Suisun City, and Vallejo (Solano County)

#9 Applicable Sites

General Permit: • Construction sites ≥ 1 acre

(including linear projects)

MRP: • All construction sites

#8 Enforcement Actions / Fines

General Permit requirements enforced by: • Regional Board, which may fine Legally Responsible

Person (LRP) for failure to comply with CGP.

MRP:• Regional Board

– Enforces local agencies’ compliance with MRP.– May fine agencies for failure to comply with MRP.

• Local stormwater program (city/county) – Enforces requirements at construction sites.– May fine property owner/permit holder.

#7 Required Plans

General Permit: • Storm Water Pollution Prevention Plan (SWPPP):

– Prepared by Qualified SWPPP Developer (QSD)– Must meet minimum requirements in CGP.– Must be available on site.

MRP: • Before issuing grading permit, review project’s

erosion control plan for consistency with:– Local requirements, – Appropriateness and adequacy of BMPs.

#6 Best Management Practices (BMPs)

General Permit: • Requires specific minimum BMPs in 6

categories

MRP: Provision C.6 requirements• Local agencies shall require all construction

sites to have site-specific, seasonally- and phase- appropriate effective BMPs

• Require appropriate BMPs in the same 6 categories, but there are no minimum BMPs

#5 Training

General Permit: must have training & certification to be a • Qualified SWPPP Developer to develop a Stormwater Pollution

Prevention Plan (SWPPP)

• Qualified SWPPP Practitioner to implement the SWPPP

MRP: minimum every other year to municipal staff responsible for conducting inspections• Correct use of specific BMPs• Proper installation & maintenance of BMPs• Permit requirements• Local requirements• Enforcement Response Plan

#4 Notice of Intent (NOIs)

General Permit: Municipalities file for an NOI for public/capital improvement projects ≥ 1 acre

MRP: Municipalities verify applicable projects (public & private) have filed an NOI for the Statewide Permit

#3 Municipalities Ensure Compliance

General Permit: • For all public/capital improvement projects ≥ 1

acre

MRP: • For all construction sites; minimum inspection requirements for:

– Sites ≥ 1 acre– High priority sites

#2 Compliance Inspection

General Permit: • Regional Board inspects for compliance with

GP requirements

MRP: • Municipal inspectors inspect

sites (including NOI sites) for

compliance with local ordinances

#1 Record Keeping

General Permit: • NOI facilities submit self inspection data,

monitoring data and annual reports in SMARTs online database

MRP Municipalities: • Track construction inspections of high priority

sites and sites ≥ 1 acre in electronic tabular format

• Submit summaries in Annual Reports

Questions ?