CGP FAQs - Coverage for Houses in a Subdivision
Construction season is in full swing, and we are entering (unofficially) our second season under the Construction General Permit (CGP), the stormwater permit for the construction phase. This is still a generally new permit, so we are still very much on the learning curve. I'll be posting several articles on the CGP in order to clarify details of the plan that are important, and have been rather murky to date.
First is the issue of CGP coverage for a residential subdivision. Due to the permitting guidelines (namely that the house be shown on site plans and finished grading for each lot is required), construction permits may not show the house lots at first. This is common where house dimentions are not known yet. However, each house must be covered by a CGP, since each lot is considered a part of the overall subdivision. At some point, every building must be shown on a plan and a grading plan must be shown for all of the earthwork that is required.
The CGP is focused on the owner of the land and giving them the responsibility of getting coverage. Also subject to the CGP are contractors that perform earthwork. This can lead to a very confusing situation if open lots are sold to homeowners (who must sign onto the CGP) for development, where there can be many contractors (who must sign onto the CGP as a co-permittee) working on houses thoughout the duration of subdivision buildout. Developers should keep a careful eye on what contractors are working on their site to ensure that they understand the CGP requirements, since they are all covered under the same permit, and all are responsible for implementation of their Stormwater Pollution Prevention Plan.
In the future, I will talk about the special requirements for CGP permitting in impaired watersheds. Being in South Burlington (home of most of the State's impaired watersheds), we at LHINC are starting to focus on these stricter requirements.
(Return to lhinc.net) |
First is the issue of CGP coverage for a residential subdivision. Due to the permitting guidelines (namely that the house be shown on site plans and finished grading for each lot is required), construction permits may not show the house lots at first. This is common where house dimentions are not known yet. However, each house must be covered by a CGP, since each lot is considered a part of the overall subdivision. At some point, every building must be shown on a plan and a grading plan must be shown for all of the earthwork that is required.
The CGP is focused on the owner of the land and giving them the responsibility of getting coverage. Also subject to the CGP are contractors that perform earthwork. This can lead to a very confusing situation if open lots are sold to homeowners (who must sign onto the CGP) for development, where there can be many contractors (who must sign onto the CGP as a co-permittee) working on houses thoughout the duration of subdivision buildout. Developers should keep a careful eye on what contractors are working on their site to ensure that they understand the CGP requirements, since they are all covered under the same permit, and all are responsible for implementation of their Stormwater Pollution Prevention Plan.
In the future, I will talk about the special requirements for CGP permitting in impaired watersheds. Being in South Burlington (home of most of the State's impaired watersheds), we at LHINC are starting to focus on these stricter requirements.
