ST0102-CS030102From:
To:
Date:
Subject:
"Steve Ligon" <SLIGON@tceq.state.tx.us>
<staylor@ci.coppell.tx. us>
1/2/03 IO:04AM
Re: Construction Permitting
Page
Since coverage will not be available through your MS4 permit, by March 10th you will need to compare
your SWP3 to the Phase II construction general permit, make any necessary changes to the SWP3 (after
the permit is issued and final), follow the notice requirements, and proceed.
For future projects, you will be able to cover city projects just as soon as the NOI for the MS4 permit is
submitted. The permit requirements (SWP3) are the same regardless of whether the authorization is
under the MS4 permit or the separate construction general permit, so it seams you could provide for both
possibilities in near-future bids/contracts.
Stephen M. Ligon
Storm Water & General Permits
>>> "Suzan Taylor'' <staylor@ci.coppell.tx.us> 12/18/02 01:50PM >>>
I really appreciate your help in this matter and I have a few more
questions. The City's small construction project( 4 acres) will not be
completed before March 10, 2003. There was a SWP3 developed and
implemented as part of the design of the project. Since the Phase II
MS4 permit will not be issued until February 2003, we probably will not
have our NOI and SWMP (with the 7th MCM) for the general permit
submitted by March 10, 2003. This will leave us without coverage for
our small construction project. Do we obtain coverage for the project
under the general construction permit, once it is issued in February?
Will all of our projects that bid before we submit our Phase II NOI need
to be covered under the general construction permit?
Thanks so much for your help, I just want to make sure that we are in
compliance.
>>> "Steve Ligon" <SLIGON@tceq.state.tx.us> 12/16/02 09:04AM >>>
Thank you for your inquiry. I believe that the proposed 7th MCM will
be very efficient for small MS4s compared to obtaining coverage under a
separate permit.
The deadline for coverage of Phase II construction projects (1-5 acres)
is March 10, 2003. If you have developed the required Storm Water
Management Plan (7 MCMs) and submitted it with the NOI for coverage
under the Ph II MS4 permit for Coppell, you will not need to submit an
NOI for small construction activities where the City is the operator.
Instead, just develop the site-specific storm water pollution prevention
plan for the construction activity, and post a site notice (provided in
the back of the proposed permit) at the site. If a small construction
activity begins prior to March 10, 2003, and is completed and the site
stabilized prior to that date, no authorization or notice is required.
If the project continues past this date, or commences after this date,
you will need to get authorization by March 10, 2003.
The projected date for issuance of the TPDES construction general
permit is now the third week in January. The Ph II MS4 permit will be
issued in February, with applications due no later than 90 days from the
date of issuance.
Stephen Ligon
Storm Water & General Permits Team
For large construction sites (< 5 acres) you must already have permit
coverage through the USEPA permit. The issuance of the TPDES permits
(Construction and MS4) just shift the administration of this
authorization from EPA to TCEQ.
>>> "Suzan Taylor" <staylor@ci.coppell.tx. us> 12/04/02 01:43PM >>>
I am still confused about the permit coverage for Coppell. The TCEQ
is
expected to issue the permit on or around December 18th. Will the
City
have to obtain coverage for small construction activities (1 to 5
acres)
after that date, or do we have until Mamh 10, 2003 to obtain coverage
for small construction activites? Will we have to file an NOI? It is
my
understanding that we have to obtain coverage for large (5+ acres)
construction sites after Mamh 10, 2003. We are including the 7th
minimum control measure in our storm water managment plan, so that we
do
not have to file an NOI for each municipal project. I am just not
sure
how to handle small construction projects that may bid in between the
time the permit is issued and the March 10, 2003 date. Thanks for
your
assistance in this matter.
>>> "Steve Ligon" <SLIGON@tceq.state.tx. us> 10/30/02 03:14PM >>>
Thank you for your inquiry. Until the TCEQ permit is issued (probably
December 18th or very soon after), large construction sites should
obtain permit coverage under the current NPDES construction general
permit. To do this, simply develop a storm water pollution prevention
plan according to the EPA general permit, complete the EPA's notice of
intent, and send it to the address on the form.
After the TCEQ permit is issued, construction projects authorized
under
the NPDES permit may continue to operate under that permit for 90 days.
Before this 90 day period expires, these permittees must either
finally
stabilize the sites according to the conditions of the NPDES permit,
or
submit a notice of intent to the TCEQ for continued coverage under the
new permit.
I hope that this has answered some of your questions. Please feel
free
to contact me if you need additional assistance.
Stephen Ligon
Storm Water & General Permits Team
>>> "Suzan Taylor" <staylor@ci.coppell.tx. us> 10/24/02 03:22PM >>>
Under the ISTEA, the City of Coppell was not required to obtain a
· [§uza--'-h"¥~¥1or- Re: Construction Permittin~ ,
storm
water permit for large construction activities. The City is opening
bids on November 1, 2002 for a small construction project and is
scheduled to start construction prior to issuance of the general
permit
on December 9, 2002. Do I have to obtain permit coverage for this
project? Would we be required to obtain a permit on a large
construction project if we started construction pdor to December 9?
Your consideration of this matter is appreciated.
Thanks