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CSGP Continuation of Coverage - What Should Local Authorities Expect

Posted 3/29/2022

Recently, IDEM sent out an automated notice to active Rule 5 permit owners notifying the project owners that a Continuation of Coverage is required for the new CSGP. As an MS4 or SWCD, here is what you might see from contractors/project owners:

  • Submittal of a Notice of Termination under Rule 5 for the project if the project meets the terms of termination and will be completed before May 12th (the due date on the notice from IDEM).
  • Submittal of a new Notice of Intent under the CSGP with the intent to comply with all terms and conditions of the CSGP.
  • Application of an Individual Permit to IDEM
  • Submittal of a Continuation of Coverage from the Rule 5 to the CSGP. As part of the submittal, the Continuation of Coverage should be submitted to the local authority (MS4 or SWCD). This needs to be completed by May 12th.

All contractors should be implementing erosion and sediment control practices at the project site and maintaining documentation. Major changes that will impact active projects changing from Rule 5 to the CSGP include:

  • Trained individuals are required for self-monitoring inspections.
  • Implementing appropriate measures to eliminate wastes from being carried off the site. Keep lids closed on trash receptacles and protect other wastes from exposure to stormwater.
  • Temporarily or permanently stabilize unvegetated areas that are scheduled or likely to be left inactive for 7 days or more with measures appropriate for the season to minimize erosion potential. Initiate stabilization activities by the end of the seventh day the area is inactive. Complete stabilization activities within the following 7 days.
  • The use of polymers requires IDEM approval.
  • Additional documentation for Self-Monitoring Program/Project Management Log including documentation of corrective actions, timeline for implementation of corrective actions, maintaining the NOI, public notice and NOS onsite, and records of SWPPP modifications.

Projects owned/operated by an MS4 under the Rule 5 will have to convert to the CSGP also. A MS4 could notify other city/town departments with active projects that they should also be receiving a notice and are required to submit the Continuation of Coverage. If the department has not, IDEM may not have current contact information for the project in their online system and the department should reach out to IDEM and the contractor.

Additionally, the MS4 or SWCD could use this as an educational moment with the contractors at active construction sites by reviewing this information with them to be sure they are aware the Continuation of Coverage needs to be obtained. If you do, be sure to track it under MCM 1 & 2 for training provided to builders, developers, contractors, and engineers (MS4GP 4.3 (a)(5)).

IDEM CSGP website: IDEM: Storm Water Permitting: Construction / Land Disturbance Permitting. Includes the new IDEM template for Self-Monitoring Reports to be performed by CSGP permittees.