California Construction General Permit: A Deeper Look

In a previous issue, we let you know that the new Construction General Permit will go into effect on September 1, 2023.  Over the next couple of months, we are going to take a more in-depth look at the changes. The revised inspection requirements follow.

Revised Inspection Requirements:

The previous General Permit required Storm Water Pollution Prevention Plans to be prepared by a Qualified SWPPP Developer (QSD) but did not require QSD inspection. The new permit details that the QSD must perform the following on-site visual inspections:

• Within 30 days of construction activities commencing on a site;
• Within 30 days of a discharger replacing the QSD;
• Twice annually, once August through October and once January through March;
• Within 14 calendar days after a numeric action level exceedance; and
• Within the time period requested in writing from Water Board staff.

The previous permit allowed the QSP to train inspectors to perform required inspections.  The new permit still allows for trained inspectors, but details that the project QSP is required to perform the following on-site visual inspection:

Once every calendar month;

• Within 72 hours prior to a forecasted Qualifying Precipitation Event.
• Within 14 days after a Numeric Action Level exceedance
• Prior to the submittal of General Permit Notice of Termination or Change of Information (for acreage changes).

Most of these are new inspection requirements or ones that could previously be performed by a trained inspector.  The increased inspection requirements can come at a considerable cost to a construction project.  

If you have any questions about the upcoming Construction General Permit, please feel free to reach out to Associates Environmental’s Jennifer Fieber, jfieber@associatesenvironmental.com (714) 916-4996. Next month we will look at the New Monitoring Requirements.