Wednesday, March 11, 2009

Multimedia General Permit – Combining Stormwater & Air Requirements

There is a clear advantage for State and Federal permitting agencies to develop and offer general permits to the regulated community. A single permit can be prepared and issued which can be used by many permittees. In most cases, the general permit option benefits the permit holder as well, including:

  • Significant reduced time to receive permit(s),

  • Clear understanding of permit requirements and limitations before applying for coverage,

Permittees that can not accept the requirements or limitations in the general permit have the option to apply for an individual permit.

Recently, the general permit approach has been taken to the logical next step – a Multimedia General Permit. Multimedia General Permits incorporate the requirements that apply to different permitting programs. To date, the permitting programs which have been combined are Air Emission Permits and Stormwater Discharge Permits. In this case, permittees that require both an air permit and a stormwater permit apply to be covered under a single Multimedia General Permit.

Because the regulatory requirements for air emission and stormwater discharge permits are sector- or industry-specific, the multimedia general permits offered are usually limited to a fairly narrow industrial sector. And therefore, because a multimedia general permit will apply to a smaller number of potential permittees, many States have not devoted significant resources to develop many such permits.

Two States have developed one or more Multimedia General Permits:

Alabama – (ADEQ): In February 2009, ADEQ promulgated a multimedia general permit for Dry Litter Poultry Animal Feeding Operations – a type of regulated Confined Animal Feeding Operation or CAFO. The general permit incorporates requirements for air emission permitting and compliance and stormwater permitting and compliance.

South Dakota – (SDDENR): DENR has three Multimedia General Permits for asphalt plants, rock crushing operations, and concrete plant. Like the Alabama permit, the South Dakota permit combines air emission and stormwater discharge requirements.

Because permittees need to accept both air emission and stormwater discharge requirements and limits, it becomes even more important for sites considering multimedia general permit coverage carefully review the compliance requirements.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
Caltha LLP Website

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