Draft 2026 Construction Stormwater General Permit - Formal Public Comment Period

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Comment From: Washington State Department of... (Jeannie McCully)

5/09/25 @ 8:39 PM

With this submittal, WSDOT is including both a cover letter and an excel spreadsheet with specific comments to the CSWGP organized by permit section and page number.

Thank you for the opportunity to provide comments on the draft 2026 CSWGP and Fact ...↓

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Comment From: Port of Bellingham (Brian Gouran)

5/09/25 @ 4:50 PM

Port of Bellingham Comments:

1. The language in S1.B.1.b.ii. is redundant, as construction support activity is
already explicitly listed in S1.B.1.a., and construction support activity is defined in
the appendices.

2. The separation of S1.B.1...↓

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Comment From: Gary Merlino Construction Comp... (Caylah Lunning)

5/09/25 @ 3:19 PM

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Comment From: Washington Public Ports Associ... (Carly Michiels)

5/09/25 @ 3:18 PM

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Comment From: Northwest Seaport Alliance (M Kellar)

5/09/25 @ 2:25 PM

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Comment From: Port of Tacoma (Mindi Kellar)

5/09/25 @ 2:24 PM

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Comment From: Tiffany Nibler

5/08/25 @ 11:56 PM

Please see the attached document for questions and comments on the 2026 CSWGP. Thank you for your time. Tiffany Nibler

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Comment From: Seattle Public Utilities (Nathan Hart)

5/08/25 @ 10:29 AM

Seattle Public Utilities appreciates the opportunity to comment on the draft construction stormwater general permit. SPU supports the proposed permit language but feels that additional language should be added to this permit to address the risks from...↓ PCB containing building material. Regional source control partners have invested decades of time and millions of dollars into controlling sources of pollutants that may impact municipal conveyance systems, to protect our waterways and the health of our communities. Polychlorinated biphenyls are one of the primary environmental and health risk drivers in the region.

One of the primary remaining sources of this pollutant are buildings which contain PCBs in certain building materials. Renovation and/or the demolition of buildings which include PCB building materials is likely to result in a discharge of this chemical to ground and the adjacent conveyance systems if appropriate BMPs are not implemented to control the chemical. Requiring the assessment of structures constructed prior to 1980 to determine if they contain PCBs would allow permittees to determine the potential risks and to choose appropriate BMPs to minimize this risk. Including language requiring assessment would align the CSWGP with the Municipal Stormwater General Permit. This section should reference the PCB in Building guidance that was drafted by Ecology and Ecology's Stormwater Management Manuals for Western and Eastern Washington. Alternatively, Ecology could opt to include the language from the Federal Construction General Permit:

"Condition 3.2: If you discharge to a water that is impaired for polychlorinated biphenyls (PCBs) and are engaging in demolition of any structure with at least 10,000 square feet of floor space built or renovated before January 1, 1980, you must:
a. Implement controls* to minimize the exposure of PCB-containing building materials, including paint, caulk, and pre-1980 fluorescent lighting fixtures, to precipitation and to stormwater; and
b. Ensure that disposal of such materials is performed in compliance with applicable State, Federal, and local laws.
* Examples of controls to minimize exposure of PCBs to precipitation and stormwater include separating work areas from non-work areas and selecting appropriate personal protective equipment and tools, constructing a containment area so that all dust or debris generated by the work remains within the protected area, and using tools that minimize dust and heat (<212°F). For additional information, refer to Part 2.3.3 of the CGP Fact Sheet."

The inclusion of language addressing the risks associated with PCB containing building materials will help the permittees prevent discharges of these pollutants into the environment, protecting the adjacent communities and preventing environmental damage. This also supports other permittees by reducing the risks of illicit discharges of these pollutants which may require remediation in the future.

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Comment From: Port of Seattle (Jane Dewell)

5/08/25 @ 10:05 AM

Please see attached PDF

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Comment From: Gregory Ewanitz

5/07/25 @ 7:43 AM

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Comment From: Alex Zimmerman

5/05/25 @ 11:53 AM

The requirement for pH sampling to be done with calibrated meter or probes should be removed. The use of wide range strips should be allowed. Keeping the pH instruments properly calibrated in the field is quite daunting. The required buffer solutions...↓

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Comment From: Bonnie Blessing

4/29/25 @ 7:19 AM

Thanks for reviewing my comments. I tried to link to conditions.

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Comment From: Diana Halladay

4/24/25 @ 6:10 PM

In S1.B.1.a, there is a reference to S1.B.1.a.ii that has been added in parentheses after "construction support activity or other soil disturbing activity". It does not appear that section S1.B.1.a.ii exists in the permit revisions.

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Comment From: Andrew Funk (Andrew Funk)

4/04/25 @ 11:30 AM

I work with permittees, helping them maintain compliance with their Construction Stormwater General Permit. I have a few questions for you and hope you can help clarify some permit requirements.

First, I sometimes come across a section of High Visi...↓bility Fencing (HVS) where there is ponded turbid water on both sides of the HVS. Since there is no observable flow from the project side of the HVS to the off site side of the HVS (water is simply ponded), I do not consider this a discharge. The Stormwater Manual defines a discharge as a flow per unit of time. When I cannot find a flow past the project boundary, there is no discharge. Sampling the off site ponded turbid water might be interesting, but it would not be representative of a discharge and I would not report it in the monthly Discharge Monitoring Report. Does that all sound correct to you?

Do the 2 & 7 day rules in S9.D.5.d. also apply to soil stockpiles, or is this intended primarily for land/soil areas that are cleared of vegetation or excavated and are bare soil?

Do the words in S9.D.5.e., "if needed", indicate it is up to the permittee's discretion when looking at the weather forecast? That is, if the weekend or holiday forecast looks dry, can the soils be left as is?

The language in S9.D.5.f. specifically calls out "soil stockpiles". Often times, the construction project has stockpiles of gravel, gravel barrow, CSBC. Granted, these can be dirty/dusty at times and it makes sense to locate away from inlets, waterways and drainage channels. However, I do not consider them "soil stockpiles". Also, gravel, gravel barrow and CSBC are by themselves stabilized, because they are not soil and not eroded by raindrops. Am I correct that the stabilization requirement of S9.D.5.f. does not apply to gravel, gravel barrow and CSBC? Specifically, do gravel, gravel barrow and CSBC stockpiles need to be covered with plastic?

I also do not consider gravel, gravel barrow and CSBC to be exposed unworked soils. So, I do not think the 2 & 7 day rules in S9.D.5.d. apply. Is that correct?

In S9.D.6.a.., if a slope is constructed using compacted gravel barrow, erosion is minimized because it is, well, compacted gravel barrow. So, I would use my own discretion, but likely not implement additional erosion control. Does that seem reasonable?

In Appendix A, the "Final Stabilization" mentions several "equivalent permanent stabilization measures". I am guessing this is not a comprehensive list. If an area of soil is hydroseeded with tackifier and there is no more soil disturbance in that area, does the tackifier qualify as an equivalent permanent stabilization measure? Or does the grass seed need to germinate first? Also, if bark is placed on an area of soils, does that count as an equivalent permanent stabilization measure?

Section S5.A. says to contact Ecology within 24 hours of "analysis". Sometimes there can be a delay between the time I grab a sample and when I analyze the sample. There have been times when a sample was collected late in the evening, but not run through a turbidity meter until the next day. Does the 24-hour time start when the sample is collected, or once it is analyzed? Also, I recall an Ecology guidance document that said a turbidity sample can be measured up to 22-hours after sample collection. Is that correct? And, does the 22-hour also apply to pH?

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Comment From: Willian Lider

3/21/25 @ 3:00 PM

Please see my comment letter attached responding to Ecology's email below requesting comments on the draft Construction Stormwater General Permit (CSPG) anticipated to be released in 2026. The CSGP pertains primarily to turbid stormwater water relea...↓

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Comment From: City of Hoquiam (Brian Shay)

3/20/25 @ 11:20 AM

Any changes to the permitting system for general storm water construction permits meet Governor's Ferguson's executive order to provide regulatory reform. What has been proposed seems to be the opposite creating more regulations and more expenses, w...↓

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