Event:
Construction Stormwater Enforcement & Compliance: Working with Industry Partners to Achieve Results
Date:
October 24, 2017
Duration:
10:00 am - 12:00 pm (EPA HQ)
Objective:
The construction sector pulls nearly half of all permits issued by EPA's 402 program annually, more than industrial and municipal permits combined. Unfortunately, this administratively complex program is ill suited for an important economic group: single family home builders. In this forum, National Association of Home Builders (NAHB) members from around the country will identify top enforcement issues generating uncertainty, redundancy, and increased costs in the field. Participants will discuss winwin opportunities to provide builders and developers with a clear path to compliance, reduce the occurrence of minor violations, and allow the agency to focus its resources on activities that cause real environmental harm.
Attendees: OECA and OW senior staff, program staff (5-10)
NAHB members from each EPA region (10)
NAHB staff (5)
Draft Agenda:
Welcome (Susan Bodine, EPA; Greg Ugalde, NAHB 2ndVice Chairman of the Board)
5 minutes
Introductions
10 minutes
Key Enforcement Issues (NAHB Members)
40 minutes
Overly burdensome requirements for small sites
Excessive fines for de minimis violations
State vs Federal role in the enforcement process
Confusion as to whether details of SWPPP plans are enforceable
[BREAK]
Summary of Challenges
5 minutes
Potential Solutions
40 minutes
Provide simplified permit option for small sites
Revise EPA guidance (Expedited settlement offer/right-to-cure)
Launch compliance assistance initiative via "Smart Sectors" program
Issue memoranda clarifying "enforceability" of SWPPPs
Summary and Next Steps
10 minutes
Sierra Club v. EPA 18cv3472 NDCA
Tier 7
ED 002061 00177901-00001