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NC-v4 SSp1:Construction activity pollution prevention

Local Standards Comparisons as Required Documents

When working on a project using local standards rather than the 2012 EPA CGP, what is necessary to prove that the local standards are as, if not more, stringent than the CGP.  How in depth does 'describe' have to be?  Does this mean a comparison of each subsection of standards or more broad?

Thank you!

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Wed, 07/27/2022 - 14:13

Hi Nate, If the local standard is basically the EPA CGP with some minor edits or a later version, I'd just check the EPA CGP box rather than do the comparison, because you are following the CGP. Within the US the local standards are generally based on the CGP so I don't see a need to highlight where they're *more* stringent. I've never had a reviewer comment something like "you checked the 2012 CGP box but we know Tennessee uses the 2021 version."    If the local standard doesn't use the CGP as its basis, typically the case outside the US, I would provide 2-3 bullet points for each high-level section of the CGB table of contents, and it's ok if some of those points are "same requirements as CGP." The goal isn't to do a comprehensive analysis of the difference, more to show that you have done your due diligence rather than assuming the local standard is equal.   That said, it's been a while since I worked on a non-US project, so would love to hear from others on this forum who have been through a review of the comparison document recently! 

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