July 3, 20190

If you are an entity subject to stormwater regulation, you should be aware of an update to one of the state’s environmental regulatory compliance initiatives, the Rhode Island Multi-Sector General Permit (MSGP). The 2019 Rhode Island Multi-Sector General Permit (MSGP) became effective on May 3, 2019. This means that even those entities covered by the existing permit, who wish to continue that authorization, must re-apply for coverage under the permit. The re-application period expires on August 2, 2019.

Rhode Island is a delegated state for purposes of environmental regulatory compliance for stormwater. This means that the state is authorized to review applications for and issue individual or general permits under state law. The Rhode Island Department of Environmental Management (RIDEM) in 1993 drafted a statewide baseline general permit for stormwater discharges associated with industrial activity. RIDEM then issued another general permit to cover discharges associated with construction activity.

In an effort to assist permittees with their environmental regulatory compliance during the re-application period, the Rhode Island Department of Environmental Management (RIDEM) has indicated that “existing MSGP permittees are not required to conduct sampling of their stormwater discharges for benchmarks, pollutant causing impairment or effluent limitation guidelines during the current calendar year (January 1, 2019 – December 31, 2019).”

As of January 1, 2020, the applicable sampling requirements will begin again.  Also, all MSGP permittees are required to comply with all other aspects of their MSGP permit for 2019. These environmental regulatory compliance requirements include “visual stormwater assessments and facility inspections,” per RIDEM communications.

Under the 2019 MSGP, and to ensure environmental regulatory compliance, existing permittees must submit an electronic version of their Notice of Intent (NOI). The NOI process is now managed through something called NETMSGP. According to RIDEM, “NETMSGP is a freely available Web-based tool accessible through EPA’s Central Data Exchange (CDX) network that allows RIPDES permittees to electronically sign and submit their NOI to DEM via a secure internet connection. The new tool can be added to an existing CDX account or a new account by logging in to: https://npdes-ereporting.epa.gov/msgp.”

Part of the NOI environmental regulatory compliance practice requires that applicants also upload a copy of their Storm Water Management Plan (SWMP) or submit a link to that document directly. An SWMP is a plan that creates methodologies, practices, and reporting deadlines for purposes of adequately managing stormwater to meet the goals and policies of state law and RIDEM regulation, per the 2019 MSGP.

The MSGP program is a part of the federal Clean Water Act, an initiative to protect the country’s waters from unauthorized discharges to waters of the states. In Rhode Island, the water pollution control policy includes developing and enforcing permit restrictions for both municipal and industrial wastewaters discharges, sources of stormwater discharges, and combined sewer overflows (CSOs). These sources are considered a target for environmental regulatory compliance.

In order to provide further information and instruction, RIDEM scheduled two workshops on the 2019 MSGP and the new electronic submittal requirements as follows:

Thursday, June 27, 2019, at 10:30 AM
Tuesday, July 9, 2019, at 1:30 PM

Rhode Island Department of Environmental Management
235 Promenade Street, Room 300
Providence, RI

To learn more about these new stormwater requirements and how they can impact your property and business, call Desautel Browning Law at 401.477.0023 today.

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