Pre-Construction Planning & Site Evaluation
Before any earth is moved, the project must determine permit applicability, identify receiving waters, assess site conditions, and establish the regulatory framework. This phase sets the foundation for the entire compliance effort.
Calculate total land disturbance (including all phases and the common plan of development) to determine if the 1-acre NPDES threshold is triggered.
Identify all receiving water bodies within the project's drainage area. Check the state 303(d) impaired waters list — discharges to impaired waters may trigger enhanced BMP requirements or individual permit coverage.
Conduct Endangered Species Act (ESA) and National Historic Preservation Act (NHPA) eligibility screening. Federal permits require documented compliance with both.
ESA/NHPA screening: 2–4 weeks if consultation required
Determine whether the project falls under state-administered NPDES or EPA-administered NPDES. This determines which agency receives your NOI, which permit applies, and the fee structure.
Check for local MS4 (Municipal Separate Storm Sewer System) overlay requirements. Many cities and counties require a separate local stormwater permit on top of the state/federal CGP.