Regulatory Alert: AAAE Solicits Feedback on EPA's Proposed 2020 Multi-Sector General Permit
May 8, 2020
AAAE is distributing a survey to members to solicit feedback on the U.S. Environmental Protection Agency's (EPA) proposed multi-sector general permit (MSGP) for stormwater discharges from industrial activity, which EPA released for comment in March 2020. AAAE is seeking input from members on EPA's proposal, including a new three-stage protocol in the proposed MSGP that would require covered airports to implement progressively more prescriptive and protective stormwater control measures (SCMs) when monitoring results exceed or repeatedly exceed benchmark values. The current deadline for submitting comments to EPA is June 1, 2020.
You can find AAAE's survey on the proposed 2020 MGSP here. We highly encourage you to provide input before May 18, 2020. Your feedback will help us appropriately respond to this important proposal and ensure that airports are not subjected to unnecessary and costly mandates, particularly during this critical time when airports are trying to respond to and recover from impacts due to the coronavirus outbreak.
Background. In accordance with the Clean Water Act, EPA implements the National Pollutant Discharge Elimination System (NPDES) program, which requires permits for any person or organization to discharge industrial stormwater into waters of the United States. EPA's first MSGP was issued in 1995 and revised in 2000, 2008, and 2015, to provide operators with coverage for such stormwater discharge. The MSGP only provides coverage for four states, Washington, D.C., many Tribal areas, and U.S. territories, where EPA is the NPDES permitting authority. However, many states use the MSGP as a model for developing their own industrial stormwater discharge permits, reflecting its importance for the industry and airports.
Highlights of Proposed Changes. The proposed 2020 MSGP makes a number of changes from the existing 2015 MSGP. Highlights of the proposed changes for airports that would be covered by the MSGP include:
Resources on Proposed Rule. AAAE has compiled resources to help educate and familiarize members with the details of the proposed 2020 MSGP. You can access these documents and more at the following links:
If you have any questions, comments, or other feedback regarding the proposed 2020 MSGP, please contact Justin Barkowski at justin.barkowski@aaae.org.
AAAE is distributing a survey to members to solicit feedback on the U.S. Environmental Protection Agency's (EPA) proposed multi-sector general permit (MSGP) for stormwater discharges from industrial activity, which EPA released for comment in March 2020. AAAE is seeking input from members on EPA's proposal, including a new three-stage protocol in the proposed MSGP that would require covered airports to implement progressively more prescriptive and protective stormwater control measures (SCMs) when monitoring results exceed or repeatedly exceed benchmark values. The current deadline for submitting comments to EPA is June 1, 2020.
You can find AAAE's survey on the proposed 2020 MGSP here. We highly encourage you to provide input before May 18, 2020. Your feedback will help us appropriately respond to this important proposal and ensure that airports are not subjected to unnecessary and costly mandates, particularly during this critical time when airports are trying to respond to and recover from impacts due to the coronavirus outbreak.
Background. In accordance with the Clean Water Act, EPA implements the National Pollutant Discharge Elimination System (NPDES) program, which requires permits for any person or organization to discharge industrial stormwater into waters of the United States. EPA's first MSGP was issued in 1995 and revised in 2000, 2008, and 2015, to provide operators with coverage for such stormwater discharge. The MSGP only provides coverage for four states, Washington, D.C., many Tribal areas, and U.S. territories, where EPA is the NPDES permitting authority. However, many states use the MSGP as a model for developing their own industrial stormwater discharge permits, reflecting its importance for the industry and airports.
Highlights of Proposed Changes. The proposed 2020 MSGP makes a number of changes from the existing 2015 MSGP. Highlights of the proposed changes for airports that would be covered by the MSGP include:
- Requires airports to conduct quarterly benchmark monitoring for three parameters, including pH, total suspended solids (TSS), and chemical oxygen demand (COD), called universal benchmark monitoring;
- Continues to require certain airports to conduct benchmark monitoring for two additional parameters, including biochemical oxygen demand (BOD5) and ammonia, called sector-specific benchmark monitoring;
- Introduces a new tiered Additional Implementation Measures (AIM) process that requires airports to implement increasingly robust and prescriptive control measures depending on the nature and magnitude of the benchmark threshold exceedances for specific parameters;
- Allows airports to use a composite sampling method to comply with benchmark monitoring requirements; and
- Requires airports to consider implementing enhanced measures if located in an area that could be impacted by stormwater discharges from major storm events causing extreme flooding conditions.
Resources on Proposed Rule. AAAE has compiled resources to help educate and familiarize members with the details of the proposed 2020 MSGP. You can access these documents and more at the following links:
- EPA's Proposed 2020 MSGP for Public Comment
- EPA's Notice and Request for Public Comment
- EPA's Informational Webcast on Proposed 2020 MSGP
If you have any questions, comments, or other feedback regarding the proposed 2020 MSGP, please contact Justin Barkowski at justin.barkowski@aaae.org.
