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SBA Environmental Roundtable Meeting

Teleconference Number:  888-858-2144     Access Code:  9232939

***SBA Environmental Roundtable Meeting***

WEDNESDAY, July 13, 2016 10 a.m. – noon


TO:                 Interested Persons


FROM:           Kevin Bromberg, Assistant Chief Counsel

        David Rostker, Assistant Chief Counsel

        Tabby Waqar, Assistant Chief Counsel


SUBJECT:     Next SBA Environmental Roundtable Meeting


The next U.S. Small Business Administration, Office of Advocacy Environmental Roundtable will meet to discuss the following topics, beginning at 10 a.m. on Wednesday, July 13, 2016.  The meeting will be held in Washington, D.C., at the Small Business Administration Headquarters, 409 Third Street SW.  Send RSVP to  We have adopted a casual clothes option for all Roundtable meetings.

Draft Agenda


10:00 – noon   Draft 2017 Construction General Permit (CGP)


            Chris Kloss, Office of Wastewater Management, Office of Water, EPA

            Greg Schaner, Office of Wastewater Management, Office of Water, EPA


Roundtable meetings are open to all interested persons, with the exception of the press, in order to facilitate open and frank discussion about the impacts of Federal regulatory activities on small entities.   Agendas and presentations are available to all, including the press.  Anyone who wants to receive roundtable agendas or presentations, or to be included in the distribution list, should forward such requests to  The purpose of these Roundtable meetings is to exchange opinions, facts and information and to obtain the attendees’ individual views and opinions regarding small business concerns.  The meetings are not intended to achieve or communicate any consensus positions of the attendees.


Small Business Environmental Roundtable

Issue for Discussion


July 13, 2016


2017 Draft General Permit for Construction Site Stormwater Discharges (CGP)

EPA is authorized under Clean Water Act section 402(a) to issue a National Pollutant Discharge Elimination System (NPDES) permit for the discharge of any pollutant from a point source.  These NPDES permits are issued by EPA regional offices or NPDES authorized state or tribal agencies. 

10 EPA Regions are proposing for public comment the draft 2017 NPDES general permit for stormwater discharges from construction activities, also referred to as the “2017 Construction General Permit (CGP)”.   The draft permit, once finalized, will replace the existing general permit covering stormwater discharges from construction activities that will expire on February 16, 2017. EPA seeks comment on the draft permit and on the accompanying fact sheet, which contains supporting documentation. 

This draft permit affects only the projects where EPA is the permitting authority, but it provides model guidance for the states and tribal permitting authorities.  This CGP and related state and tribal general permits address approximately 200,000 construction sites.   Construction firms are typically small, and such firms make up a large portion of the construction activity affected by these general permits.   The changes since the 2012 CGP, including revised provisions implementing the related effluent limitations guideline for construction and development (C&D), are of interest here.  The CGP requirements have been the subject of substantial small business concern during every previous permit comment cycle.  

The key components of EPA’s current CGP are the C&D requirements that require the permittee to minimize discharges of pollutants in stormwater discharges using control measures that reflect best engineering practices.  Dischargers must minimize their discharge of pollutants in stormwater using appropriate erosion and sediment controls and control measures for other pollutants such as litter, construction debris, and construction chemicals that could be exposed to stormwater and other wastewater.  Other requirements in the CGP include conducting regular inspections and reporting releases of reportable quantities of hazardous substances. 

The public comment period expired on May 26, but EPA welcomes the opportunity to have this post-comment period discussion to hear small business views as it considers the written comments.