Environmental Observer
The Associated General Contractors of America | Quality People. Quality Projects.
www.agc.orgJune 29, 2011 / Issue No. 5-11
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On the Inside
Take Action!
Take Action on the EPA’s Proposed Construction General Permit (CGP) for Stormwater Runoff
Comment Deadline Extended: Proposed Wetlands Permit Guidance
EPA Extends Comment Period for Stormwater Discharge Proposal; AGC Continues to Solicit Member Feedback
New EPA Memo Pushes for Monitoring Requirements in Stormwater Discharge Permits
AGC Sends Letter in Support of Coal Ash Management Bill
New Interim Rules Issued to Green the Government
Take Action!
Take Action on the EPA’s Proposed Construction General Permit (CGP) for Stormwater Runoff

The U.S. Environmental Protection Agency’s (EPA) stormwater permit revisions would change the way contractors everywhere manage stormwater runoff. The revised construction general permit will replace the current 2008 permit and EPA is accepting public comments on the draft until July 11, 2011. Use AGC’s Legislative Action Center to let EPA know how the proposal will impact your business.  The process is easy and only takes a minute!

The draft CGP includes SIGNIFICANT changes that would increase the costs, labor, and paperwork burdens and liability for construction site operators tasked with stormwater compliance. This affects ALL construction firms EVERYWHERE because states that run their own stormwater permit programs generally follow EPA’s lead in adopting enhanced protections. You need to be involved! AGC Chapters and members can easily send a letter directly to EPA through the AGC online Legislative Action Center. EPA must receive your letter by July 11, 2011.

EPA especially needs to hear from practitioners on how the proposal will impact them, their construction practices, and their businesses. Members’ input is crucial and will help shape the future of the construction stormwater runoff program.  For more information and analysis click here.

Talking Points

  • EPA should not include the numeric stormwater limit or associated provisions in its new permit until the Agency has promulgated revisions to that regulation and concluded related litigation before the 7th Circuit Court of Appeals.
  • EPA should avoid implementing overly-prescriptive erosion and sediment control requirements not specific to the December 2009 C&D ELG rule and issue guidance.
  • EPA should rely on its “Total Maximum Daily Load (TMDL) program” to control construction site runoff to impaired waters and avoid setting unsubstantiated and costly benchmark limits.
  • EPA should allow simply quarterly reporting of turbidity data to track compliance with EPA’s numeric stormwater discharge limit.
  • EPA should extend the 2008 CGP for its full term until 2013.

Action Needed

Please visit AGC’s Legislative Action Center to send a personal comment letter to EPA. The online form will allow you to personally edit your comment letter. For more detailed instruction on submitting comments click here.

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For more information, contact Leah Pilconis at (703) 837-5332 or pilconisl@agc.org. Return to Top

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