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IBS Meeting to Look at New Effluent Limitation Guidelines
A new U.S. Environmental Protection Agency proposal that will likely have a substantial financial impact on many home builders and developers is the subject of a special meeting next week at the International Builders’ Show.
On Nov. 28, the EPA published new Effluent Limitation Guidelines for the construction and development industry. Comments are due to the agency by Feb. 26.
The NAHB Environmental Issues Research and Education Subcommittee of the Environmental Issues Committee will meet at 1:30 p.m. on Jan 18 in Room North 102, Level One of the Las Vegas Convention Center to discuss the ELG proposal and NAHB’s comments. The meeting is open to all NAHB members.
The new ELGs establish steps that all construction site operators must follow to reduce the amount of soil and similar pollutants that leave the site through storm water runoff. Once finalized, the ELGs will be part of all state- and EPA-issued National Pollutant Discharge Elimination System (NPDES) Construction General Permits.
EPA has requested comment on three options:
- Option 1 relies primarily on existing techniques, including erosion and sediment control requirements (i.e., best management practices), and mandates the use of sediment basins for certain sites.
- Option 2 imposes all of the requirements of Option 1, plus a numeric turbidity limit for sites consisting of more than 30 acres that have high rainfall and high clay content.
This option would be expensive for all industries that disturb land, such as the home building industry, because the EPA has based its turbidity limit on the use of advanced treatment systems that use costly chemicals to treat and filter storm water discharges. A requirement to sample and monitor discharge is also a part of this option.
- Option 3 expands the requirements of Option 2 to all construction sites that include 10 or more disturbed acres at one time — the most broadly ranging and expensive of the EPA options.
EPA has indicated a preference for Option 2, which the agency said is expected to reduce the amount of sediment discharged from construction sites by up to 27 billion pounds per year, at an annual cost of $1.9 billion.
NAHB disagrees. “Our preliminary analysis shows that the EPA’s cost figures are extremely low and unrealistic,” said NABH environmental policy analyst Ty Asfaw.
“If the EPA selects any option other than Option 1, implementation of the ELG will fundamentally change the way that many construction and development activities occur — with a corresponding effect on housing affordability,” she added.
Various environmental groups have vociferously complained that the proposal does not require numeric limits for all sites or require post-construction controls, she said. “We fully expect these groups to put forth a strong letter-writing campaign to try to convince the EPA to make significant changes to the ELGs before they are finalized in February,” Asfaw said.
To reduce the burdens associated with ELGs, NAHB has thus far been successful in encouraging the EPA to study the impact of the proposal on small businesses and in limiting the application of the more expensive and complicated aspects of the proposal to larger sites with high erosion risk potential.
But more examples from builders on the impact of these proposals will be necessary to keep up the pressure, Asfaw said. “The EPA needs to hear from practitioners in the field and others who will be impacted by the proposal.”
State and local home builders association leaders and staff members are urged to attend the ELG meeting on Jan. 18 armed with comments and stories from members.
In addition, NAHB wants to conduct a grassroots effort to include advocacy from real estate agents, commercial builders, state and municipal government officials, state and local storm water program coordinators, and road and transportation builders.
The NAHB staff particularly needs sediment basin influent and effluent water quality concentration data for turbidity from active construction sites. After the IBS meeting, NAHB will make available in February a draft template that members can personalize and submit to the EPA.
For additional information, e-mail Ty Asfaw, or call her at 800-368-5242 x8124.
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