Advocacy Submits Comments on EPA’s Proposed Industrial Stormwater Multi-Sector General Permit
On March 2, 2020, the Environmental Protection Agency (EPA) announced a public comment period for the proposed 2020 National Pollutant Discharge Elimination System (NPDES) general permit for stormwater discharges associated with industrial activity, also referred to as the “2020 Multi-Sector General Permit (MSGP)”.
On June 1, 2020 the Office of Advocacy filed public comments. Advocacy believes that EPA must fully comply with the Regulatory Flexibility Act when promulgating the MSGP. It must evaluate the economic impacts of the proposed revisions to the MSGP on small entities, and it should reconsider the elements of the proposed 2020 MSGP that impose an unreasonable burden without a clear scientific justification. Advocacy recommends that EPA adopt a tiered approach to benchmark monitoring, with a focus on gathering high quality data for future rulemakings rather than immediate burdensome regulatory requirements, to ensure that the 2020 MSGP will not have a significant economic impact on a substantial number of small entities.
For further information, please contact David Rostker with the Office of Advocacy.
 85 Fed. Reg. 12288 (March 2, 2020).