We are building a high-rise residential building in a tight urban (Boston) site that is under 1-acre in size.
Since it is less than 1-acre, the GC does not have to obtain a EPA NPDES permit or create a Stormwater Pollution Prevention Plan (SWPPP).
Our documents do include Specifications that require Erosion and Sedimentation Control measures, requiring compliance with Boston regulations. And they require compliance with EPA NPDES -- except NPDES's 1-acre exclusion excludes the project from that requirement...!
So, it appears no one is required to actually create more of a CAPP "plan" than that which is in our Specs, mentioned above.
Any thoughts on if we comply with LEED's prerequisite or if we need to do more for a plan? Other than we know that we need to document the measures as they are installed.
Thanks.
Vanessa Nelson
LEEDuser Expert
7 thumbs up
September 30, 2019 - 5:21 pm
The EPA’s construction general permit outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. While the permit only applies to construction sites greater than 1 acre, the requirements are applied to all projects for the purposes of this prerequisite. So the project team needs to create and implement an erosion and sedimentation control (ESC) plan that conforms to the 2012 EPA CGP or local standards and codes, whichever is more stringent, regardless of project size.
The plan can be a drawing or written plan, and must describe the measures implemented to accomplish the following objectives:
--To prevent loss of soil during construction by stormwater runoff and/or wind erosion, including protecting topsoil by stockpiling for reuse.
--To prevent sedimentation of storm sewers or receiving streams.
--To prevent pollution of the air with dust and particulate matter.
Harry Flamm
Senior Sustainability ConsultantStantec Architecture
12 thumbs up
October 1, 2019 - 9:44 am
Thank you Vanessa.