EPA Requirements
How should we treat development?
As indicated previously, Phase II ushered in requirements whenever one or more acre(s) is disturbed.
The permittee is the responsible party. Therefore, Alpha Environmental Management Corporation's counsel is to create an objective program rather than simply passing responsibility to a party to "oversee themselves."
In the development phase, for example, some companies have chosen to place the responsibility for the NOI and inspections on a site contractor. The obvious issue here is "Why?" As the responsible party, it is advisable for the developer to utilize a professional service that works on behalf of the developer with an objective view of erosion control issues.
During the home construction phase, the issues are just as viable. Homeowners are now involved (they have the right to complain to the EPA) and the concern over improper infiltration of the MS4 is heightened.
Therefore, it is highly advisable to place this focus equally on development and home construction where applicable.
