Msgp Settlement Agreement

It is equally important that the transaction agreement establish a new three-step structure to address the excesses of benchmark monitoring thresholds. This new structure will require permits to adopt more aggressive measures (additional implementation measures) to respond to reference monitoring overruns. This regime indicates possible changes to the next MSGP and similar state approvals for rainwater, which could affect the wide range of industrial facilities approved in accordance with stormwater under the CWA. In particular, current MSGP permits, which continue to use coal tar joints on sidewalks and parking lots of their facilities, may be required to obtain an individual rainwater release authorization — often a tedious and tedious process. In anticipation of possible changes in 2020, members wishing to maintain eligibility for the MSGP should weigh the costs and benefits of non-coal tar sealing products and/or treatment costs for the disposal of rainwater sealants. Industrial facilities that are very concerned about possible changes to the next MSGP authorisation round should follow the proposed authorisation scheduled for September 2019 and issue formal notices. Industrial companies that are currently able to evacuate or evacuate rainwater should be aware that the settlement agreement is intended to ensure that the next iteration of the Industrial Stormwater MSGP will have much stricter requirements for monitoring and controlling rainwater. Members of the regulated community should begin planning for this when assessing and updating their stormwater management systems. Similarly, they should anticipate the need to actively participate in the public comment process leading up to the issuance of the next Industrial Stormwater MSGP, to ensure that the US EPA has a comprehensive and balanced administrative review to guide its regulatory decision-making. The EPA recently reached a settlement agreement with public sector stakeholders regarding stormwater licensing requirements, which are likely to have significant implications for industrial rainwater discharges throughout the United States. As noted above, at the end of 2016, the U.S.

EPA reached a settlement agreement with a group of environmental organizations requesting a review of the 2015 MSGP. Environmental groups found that the EPA published the 2015 MSGP without taking into account critical findings regarding the MSGP, which the National Research Council (NRC) had reached in a 2009 report. In accordance with the settlement agreement, the EPA has agreed to sponsor and fund another report evaluating some possible improvements for the next edition of the MSGP by the Agency. Earlier this year, the National Academies of Science, Engineering and Medicine released the planned report Improving the EPA Multi-Sector General Permit for Industrial Stormwater Discharges (NASEM report). Finally, the transaction agreement requires the EPA, the U.S. Environmental Agency, to pay $US 165,000 in legal fees to the plaintiffs. The transaction requires the EPA, the U.S. Environmental Agency, to take a series of steps regarding the reissue of the Industrial Stormwater MSGP at the end of its five-year term. These measures include funding a study to be carried out by the National Research Council (NRC), which includes other key requirements of the comparison agreement: (i) may delay the authorization to discharge rainwater when the facility is subject to ongoing storm control (including citizen complaints); (ii) the possible prohibition of rainwater discharges from coal-paved surfaces; and (iii) extensive monitoring requirements for discharges into degraded waters.

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