Top 10 Differences
Between the Municipal Regional Permit
&
Statewide General Construction Permit
Kristin Kerr, P.E., QSD
EOA, 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
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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 ?