Patiently Waiting for the New CGP to Be Issued...

We're getting close, apparently. My last conversation with the Stormwater Section indicated that we will see the issuance of the new CGP program in the very near future. The original comment was "Friday", and I was talking to them last week, but it's par for the course at this point.

The reason I am so anxious for a new permit program (one that, at first blush seems to tighten regulatory requirements, not loosen them), is because the new program is risk-based. The one-size-fits-all approach of the old CGP, which required the same materials even if the site just barely fit into the program, is gone. Now, you score the risks of your project (Is it in an impaired waterway? Does it have highly erodable soils? Is it on a steep slope?) and deduct risk-mitigation factors (keeping a wetland/stream buffer, limiting soil exposure to one week, limiting disturbance on steep or erodable soils). In the end, you tally your risks, subtract your mitigation factors, and then you have three levels of permitting:

Low Risk - An administrative permit which requires just the Notice of Intent (application form)

Moderate Risk - Requires the preparation of a site-specific Erosion Prevention and Sediment Control Plan (similar to the existing permit requirements today)

Individual Permit - Required if the risks are too high. Extra requirements like the background monitoring of sediment levels in the receiving stream are required.

To put this in perspective, a site that I have previously permitted required an individual permit (since it was in an impaired watershed). The next phase of work in the project is coming up, and using the new guidelines, it rates as a moderate risk site. Other sites that would have required moderate risk measures now are low risk.

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LHINC Projects In Action

Residential Construction Site

Stabilization of a swale with erosion control blankets and use of check dams for increased sedimentation.