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Mid Permit-Cycle Changes for Stormwater Discharge Monitoring Reporting? Not Quite Yet.

StormwaterNormally there are not many expected changes to permit conditions or requirements when you are in the middle of a permit cycle, but if your site is subject to the Texas Commission on Environmental Quality’s (TCEQs) Multi-Sector General Permit (MSGP) for Industrial Stormwater discharges, then you should have been able to submit your numeric effluent limitations monitoring results via the TCEQ’s Network Discharge Monitoring Report (NetDMR) web-based system.

SLOW TRANSITION TO WEB-BASED REPORTING

However, since the current permit cycle began in 2016, the TCEQ has been issuing annual “electronic reporting waivers” that allow permittees to submit the annual DMR via the old, faithful pen and paper method.  Under the current MSGP, you are supposed to submit a request for an electronic reporting waiver to be able to use the approved paper version of the Discharge Monitoring Report (DMR) but the NetDMR has not been fully implemented and is currently not an option for submitting the DMR, so the TCEQ has been pre-emptively issuing the waivers.  Honestly, the waiver has probably been one of the most welcomed letters from the TCEQ.

ELECTRONIC WAIVERS TO CONTINUE

At the beginning of 2019, correspondence from the TCEQ indicated that electronic reporting waivers would again be issued for report year 2018 reporting (completed in 2019) but that they hoped to have the NetDMR fully functional for report year 2019 (completed in 2020).  However, when the TCEQ issued the electronic reporting waiver on February 28, 2019, the waiver was issued to expire on August 14, 2021 — the date that the current permit is set to expire.  That means you can submit the paper version of the DMR for at least the next two years (2020 and 2021).  There is no reason to wait and see if the NetDMR system will be up and running to complete your DMR.

BE READY WHEN THE TIME COMES

Our suggestion is to take advantage of the next two years and enjoy being able to put pen to paper and submit your DMRs.  I am not a gambling man, but if I was, more than likely, the NetDMR system will be prepared and ready to handle the electronic submittals of your DMRs beginning with the new permit cycle.  Which means you will have yet another webpage to favorite, set of instructions to read, and username and password to remember.

Please join us with Nick Foreman on November 21, 2019 as we discuss the Industrial and Construction Stormwater General Permits.  We will go over applicability for both stormwater permits, the general requirements, and some of the main differences between the two types of permits.  We’re looking forward to it!

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