PUBLIC MEETING | CGP Re-issuance Stakeholder Meeting

This meeting is to discuss the Construction General Permit (CGP) draft and identify a path forward to finalization and issuance. 

Time: 9 a.m. - 11:30 a.m.
Location: ADEQ, Room 3175
                   1110 W. Washington St.
                   Phoenix, AZ 85007

Join us by phone: 240-454-0879
Access code: 804 791 947

Review Documents

Meeting Agenda | View >
Draft Permit | View >

Background

ADEQ has met with various customers and industry groups about items in ADEQ's current permit to consider for improvement.  The following is a summary of the three main topics that were considered, including corresponding alternatives and remaining discussion points:

  • Inspection Frequency — ADEQ proposed to modify the inspection schedule to establish the minimum routine inspection frequency at 14 days, rather than the seven days in the 2013 permit. ADEQ proposed the longer inspection frequency interval in consideration of Arizona's arid environment. Many stakeholders, however, advocated for retaining the minimum inspection frequency of seven days.
  • SWPPP Submission — ADEQ is proposing to narrow the criteria as to when a stormwater pollution prevention plan (SWPPP) must be submitted to ADEQ for review. The 2013 permit specifies a SWPPP must be submitted with the NOI if the site is within 1/4-mile of an impaired or Outstanding Arizona Water (OAW). The implementation of electronic permitting using myDEQ allows for decision points to streamline the process by limiting the factors for SWPPP submission. For example, waters that are impaired for pollutants that are typically not associated with construction activities (such as dissolved oxygen), can be bypassed for SWPPP submission, thereby expediting permit approval and saving customers the $1,000 SWPPP review fee. Sites that are located within 1/4-mile of an OAW or water impaired for sediment would still be required to submit the SWPPP for ADEQ's review to ensure environmental protection.
  • Who Must Apply for Coverage — As with many states, ADEQ has historically followed EPA's original permitting framework, which requires all persons who meet one or both of the "operator" definitions to obtain permit coverage. On many sites, this has resulted in two or more operators required to obtain coverage for the same construction activity. This also resulted in confusion for customers regarding permitting obligations. Working with various stakeholders, ADEQ introduced a framework that specified only one person is required to obtain coverage for any given construction activity. Further stakeholder discussions failed to find agreement as to who should be the single permittee. The consensus then became to retain the EPA permitting framework whereas any person who meets one or both "operator" definitions is required to obtain permit coverage.