Recently, the Pennsylvania Department of Environmental Protection made a change to the renewal coverage associated with General NPDES Permits. Previously, when an applicant would submit the required information for a General NPDES Permit renewal, DEP or the local Conservation District would reply with an updated coverage window that extended five years from the previous expiration date. The Pennsylvania Department of Environmental Protection has made the decision to standardize the General NPDES Permit expiration dates to five (5) years after the latest General NPDES Permit was approved, which was on December 8, 2019. This means that ALL General NPDES Permits will expire on December 7, 2024, regardless of when the renewal information was/is submitted. Here are two examples of how the new expiration date could affect you:
Example 1
An active General NPDES Permit is set to expire on August 1, 2022. The applicable renewal paperwork has been submitted to the local County Conservation District. A renewal approval is issued, with the new expiration date of December 7, 2024. This results in a renewal window of 2 years and 129 days.
Example 2
An active General NPDES Permit is set to expire on August 1, 2024. The applicable renewal paperwork has been submitted to the local County Conservation District. A renewal approval is issued, with the new expiration date of December 7, 2024. This results in a renewal window of only 129 days.
At this time, it is uncertain when the Pennsylvania DEP will amend the General NPDES renewal coverage period. It has been rumored that a streamlined renewal process is in the works. One thing that is certain is the tidal wave of renewals that will all be set to expire at the same time. It should be noted that Individual NPDES Permit renewals will continue to have the familiar 5-year window for renewal approvals.
Don’t get caught off guard! If you have any questions regarding your current or expiring NPDES Permit, please reach out to D.L. Howell & Associates, Inc. and we will be more than happy to discuss the renewal process with you.