AGA Comments Urge EPA to Retain Flexibility for LDC Projects in Stormwater Construction Permit

Policy May 27, 2016

On May 26, AGA filed comments on EPA’s proposed revisions to the permit-by-rule known as the Stormwater Construction General Permit (CGP). EPA is required by the Clean Water Act to review and reissue the CGP every five years. In April, the agency published the Draft 2017 CGL to replace the current 2012 version next year. EPA proposed several revisions that raise concerns for AGA and its members. We objected to requiring utilities to join a Group Stormwater Pollution Prevention Plan (SWPPP) on construction sites involving multiple operators. Instead, we urged EPA to continue allowing utilities to use either an individual SWPPP or join a group plan at their option. We also objected to shortening the timeframe for completing the installation of stabilization measures, and we urged EPA to retain flexibility for linear construction in several respects. AGA received detailed input from ERAC and coordinated with the Utility Water Act Group (UWAG), INGAA, Gas Processors Association, and other stakeholders.

A copy of the comments is attached.

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160526 AGA Comments EPA Stormwater 2017 CGP436.71 KB