EPA Opens the Comment Period for the Proposed 2020 Multi-Sector General Permit
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EPA Opens the Comment Period for the Proposed 2020 Multi-Sector General Permit

By: Gretchen Méndez-Vilella, Esq.

March 3, 2020

On March 2, 2020, the U.S. Environmental Protection Agency (EPA) issued the proposed National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) for stormwater discharges associated with industrial activity. The proposed 2020 MSGP would replace EPA’s 2015 MSGP upon final issuance.

Some of the revisions EPA has made to the 2015 MSGP require facilities subject to the 2020 MSGP to:

  • Post a sign of permit coverage to inform the public of EPA contacts in case stormwater pollution is observed in the discharge.
  • Consider implementing enhanced measures for facilities located in areas that could be affected by stormwater discharges from major storm events that cause extreme flooding conditions.
  • Perform benchmark monitoring for pH, total suspended solids (TSS), and chemical oxygen demand (COD), regardless of sector/subsector.
  • Monitor under a new cadmium benchmark threshold for consistency with updated recommended EPA water quality criteria.
  • Perform sector-specific benchmark monitoring for Sector I (Oil and Gas Extraction), Sector P (Land Transportation and Warehousing), or Sector R (Ship and Boat Building and Repair Yards).
  • Implement a tiered approach for any corrective action triggered by benchmark exceedances that would require levels of increasingly robust control measures, with limited exceptions (natural background sources, run-on).

The EPA will take public comments on the proposal 2020 MSGP during a 60-day period commencing on March 2, 2020 and ending on May 1, 2020. Details concerning the Federal Register Notice, proposed permit documents, and other supporting information may be found on: https://www.regulations.gov/docket?D=EPA-HQ-OW-2019-0372.

Goldman Antonetti & Cordóva, LLC stands ready to assist you and your business to adjust to Puerto Rico’s regulatory and legal changes. If you need further assistance in this area, please contact any of the following members of our firm:

Gretchen Méndez-Vilella 787.759.4207
Alicia Lamboy-Mombille 787.759-4144


Although the information included in this document may concern legal issues, it is not a legal opinion or professional advice and clients shall not use it as such. We assume no responsibility or liability of any kind for any information contained herein, and we expressly disclaim all liability for any claim for damages arising from the use, reference to, or reliance on, such information. If legal or other expert assistance is required, the services of a competent professional should be sought.

Goldman Antonetti & Cordóva, LLC | 787-759-8000 | www.gaclaw.com