AGC Provides Substantive Criticisms on Proposed Update to the Multi-Sector General Permit

The Environmental Protection Agency (EPA) Proposed Extensive Updates to the Multi-Sector General Permit

The Environmental Protection Agency (EPA) proposedextensive updates to the Multi-Sector General Permit, which covers stormwater discharges from industrial activity. Construction companies that perform activities associated with cement or concrete manufacturing, asphalt paving, minerals mining, or landfill operations will all likely be impacted by the changes. AGC has several concerns with the proposed permit and submitted extensive comments with a broad coalition of industry partners on June 1, 2020. click "learn more" for further information.

AGC’s top concerns with the permit are: (1) the aggressive and punitive structure for an Additional Implementation Measure (AIM) Program that goes beyond the settlement agreement with quarterly reporting obligations for permittees and (2) new requirements for universal benchmark monitoring. The comments go into considerable depth on the deficiencies of benchmark monitoring and recommend EPA explore a new approach that focuses wet weather events. The coalition also expressed concerned with the extensive industry-specific “fact sheets” in Appendix Q. It is confusing when and to what extent these fact sheets would apply. Several of AGC’s industry partners have reported that not all of the practices included in the fact sheets are achievable or applicable at every facility.

The draft permit incorporates changes due to a legal settlement (related to the 2015 permit) as well as changes in response to recommendations from the National Academies of Science. The Multi-Sector General Permit (MSGP) applies in instances in which EPA is the permitting authority and sets the standard for related industrial general permits issued by states.

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