Erosion and Sediment Control
Quest to Capturing Sites Under the Common Plan of Development
Historically in NC, we have had a strong Sediment and Erosion Control Program and cooperating Construction Stormwater Permit that previously did not contain language that fully captured projects that are under a common plan of development. Instead, the State and locally delegated erosion and sediment control programs mostly covered projects that were at the threshold of disturbed acreage indicated by Statute or ordinance.
In April of 2018 public meetings began to introduce language in the newly proposed General Permit that would include the common plan of development. Written in the permit was a clear process for applicants to follow that included the development of a sediment and erosion control plan that had to be approved by either the state or locally delegated program. After an applicant was successful at those first two steps, they could apply for coverage under the General Permit. For some locally delegated programs these updates mentioned would not appear to be problematic, as their thresholds for permitting land disturbing activity were already low, some as little as 12,000sqft. For other locally delegated erosion and sediment control programs, especially those with 1-acre thresholds, this update is a game changer.
What industry could we see this big change impacting? Vertical Construction - homebuilding, specifically. Essentially, all smaller disturbed lots within a subdivision totaling the 1-acre threshold would need to submit erosion control plans and gain coverage under the general construction stormwater permit. Immediately we saw signs that everyone’s workload was going to increase. We projected the impacts would begin with the need to provide the regulated community with information about the changes-Outreach, projected significant increase in plan submittals to be reviewed, more inspections to be performed, more enforcement, and more monitoring to name a few. With this additional workload fees will be generated to support providing services to more customers. This will also mean that everyone is going to be busy.
This industry roundtable will provide an opportunity for attendees to interact and discuss some of the lessons learned thus far. A few discussion topics to start this conversation are:
How did you help inform the regulated community?
How are you capturing these sites that will need plan approvals/permits? At what stage - planning?
What changes did you make to the structure and timeframe processes affiliated with plan review?
In the short term - Did you anticipate hiring temporary staff to facilitate the increases to plan review and project inspections?
How do you think it will affect the quality of your inspections and the numbers achievable?
What do you anticipate to be the enforcement changes needed to effectively address this quick construction activity?
What were any unanticipated benefits to this updated permit?