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The Public Comment period for the 2024 General Permit for Stormwater Discharges from Construction Activities (CGP) is open from now until June 28th

Attached are the comments that I will be submitting, as well as a copy of the latest Fact Sheet released by the Department of Water Quality (DWQ). 


There have been a few changes since the Stakeholder review was released. If you were not able to join our review of the changes from the stakeholder review, you can view it at this link:



The new changes include the following:

Section 2.2.2 - Preservation of Vegetated Areas was reverted back to the previous language with the addition of 'unless there are groundwater contamination concerns...', meaning that the requirement to preserve vegetation is only where possible and directing stormwater to vegetated areas is only required where feasible.


Section 2.2.4.d - Minimize Trackout added an exception for Single Lot residential buildings that removes the requirement for a trackout pad on each lot as long as vehicle traffic onto the lot is controlled and the street is swept after any vehicles are done accessing the lot. This is a welcome and very common sense addition to the permit since it is very burdensome to create a trackout for each individual lot.


2.2.14: Stabilize exposed portions of the site - has been updated to increase the time requirement for initiating temporary stabilization of inactive portions of the site to 30 days from 14 days and extended the time for completion to 30 days after initialization instead of 14. Final stabilization requirements for sites that discharge to impaired waters was also extended to 30 days (from 7 days).


2.3.3(e): For construction and domestic wastes - The new requirement to cover all dumpsters containing anything other than clean, sorted waste has been removed. The language is now the same as it was in the previous permit.


3.2: Water Quality-Based Conditions for Sites Discharging to Certain Impaired and High-Quality Receiving Waters - added a requirement for specific control of PCB pollutants on sites where demolition of structures built prior to 1980 will occur.

Please review my comments below and let me know if you have any questions or concerns. If you would like to send in comments, I highly encourage you to do so. All comments should be emailed to wqcomments@utah.gov.


Thank you!


Hank Tolman

President

Accena SWPPP Services

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