For a building starting construction in February 2011 do we follow the Construction General Permit 2003, like it says in the reference guide, or do we refer to the newer Construction General Permit 2008? Is there any difference in content? Do we have to follow the NPDES for a project outside of the United States? Or do we simply state in our narrative that the Construction General Permit and NPDES are not relevant as the project is outside of the United States and refer to local codes, even if less stringent, in our ESC Plan? What if there are no local codes?