Tips for CGP & SWPPP Compliance

We are in the midst of the California rainy season, and construction project sites must be compliant with the Construction General Permit (CGP) and Storm Water Pollution Prevention Plan (SWPPP) regulations to avoid project delays and violations.

“The most effective SWPPP designs combine environmental knowledge to ensure regulatory compliance while minimizing SWPPP implementation and maintenance costs,” said Paul Walsh, a Dudek Qualified SWPPP Practitioner (QSP). Walsh offers the following tips for CGP and SWPPP compliance:

  1. Sites under one-acre (43,560 sq. ft.) do not need coverage under the CGP or a SWPPP. This is automatic so these sites do not need a coverage period. Work completed during the drier months on sites that are between one and five acres in size may be eligible for a waiver. A waiver can be obtained by submitting a Notice of Intent (NOI) and Sediment Risk form through the State Water Board’s SMARTS online system. The submitted information must demonstrate that the project will not pose adverse impacts to water quality. The submitted data must indicate that the rainfall erosivity factor is less than five.
  2. Some of the best BMPs are the cheapest, including site management. Effective site management includes completing grading work in stages so more vegetation is not cleared from the site than necessary. This avoids opening the site to risk in the case of a rain event. Other site management options are building earthen water checks, traps, and detention ponds.
  3. An up-to-date BMP “wall map” at the construction site is one of the most important SWPPP items a regional board inspector will check.
  4. A muddy track-out at a project site is a red flag to city and regional board inspectors.
  5. If National Oceanic and Atmospheric Administration (NOAA) predicts a 50% or greater chance of rain, a Qualified SWPPP Practitioner (QSP) must prepare a Rain Event Action Plan (REAP) within 48 hours prior to any likely precipitation event.
  6. If a half-inch or more of rain occurs storm water sampling must be performed for pH and turbidity using equipment that meets CGP requirements.
  7. Training construction staff on how to identify potential problems can catch issues early before they become significant problems.
  8. BMPs that are relocatable and reusable can save money. Another option is Geofabric gravel bags that are more durable and more environmentally-friendly. Pete Trotta, a QSP/QSD with Dudek’s Habitat Restoration Sciences (HRS) native landscape contractor, has implemented and maintained numerous BMPs. “As a licensed contractor, HRS knows how to install BMPs, how to identify potential problems, and how to correct issues on a project site. We combine the knowledge of the CGP requirements and over 19 years installation experience to better serve our clients.”
  9. Devising the right seed mixes and revegetation methods are essential to obtain the plant cover needed to meet the new Notice of Termination (NOT) requirements.

For more information contact,

Paul Walsh, QSD/QSP of Dudek at pwalsh@dudek.com , 760 942 5147

Or Pete Trotta, QSD/QSP of HRS at ptrotta@hrs.dudek.com, 760 419 6506