STREAMLINED STORMWATER PERMITTING STRATEGIES FOR PIPELINE CONSTRUCTION

摘要

Stormwater permitting in the United States has seen dramatic changes over the past decade with implementation of Phase II of the National Pollutant Discharge Elimination System (NPDES). Phase II requires municipal stormwater permits for operators of small municipal separate sewer systems (MS4s) (larger MS4s were already required to have discharge permits from Phase I of NPDES). Now that these smaller systems must be permitted under NPDES, they are required to develop their own construction-phase programs that meet or exceed minimum standards established by the state. For larger MS4s that already had municipal permit requirements in place from Phase I of NPDES, construction program requirements have become more stringent in recent years, due in part to increased enforcement from states, both on individual construction sites and via audits of municipal programs. Additionally, Phase II lowers the threshold for projects requiring state stormwater permit coverage from five acres to one acre of disturbance, and the lowered threshold has led to an increase in the number of projects requiring permit coverage.