SWPPP and Updates to the 2022 CGP

Contributed by Teri Gibbs, PE, Land Development Engineering Practice Area Leader

What is SWPPP?

The acronym SWPPP stands for Storm Water Pollution Prevention Plan. It addresses stormwater discharges from a project site throughout construction (until final stabilization). The plan includes details on source control, sampling, locations of the Best Management Practices (BMPs), and more to ensure compliance with the latest version of the Construction General Permit (CGP).

How is this different than a WQMP?

Both a Water Quality Management Plan (WQMP) and a SWPPP address water quality discharges to comply with the Clean Water Act, but they apply at different stages:

• SWPPP applies during construction (temporary),
• WQMP applies for the life of the project upon construction completion (permanent).

A SWPPP is prepared by a Qualified SWPPP Developer (QSD) and uploaded directly to the Stormwater Multiple Application and Report Tracking System (SMARTS) website. In contrast, a WQMP is typically plan-checked and approved directly by the project site’s governing agency (i.e., the city or county plan-checking agency).

When is a SWPPP needed?

A SWPPP is needed if:

• The project site disturbs more than one acre or
• The project site is part of a larger common plan of development.

Does My Project Need Updates for the 2022 CGP?

In 2022, California adopted a new CGP, replacing the 2009 CGP. The new CGP took effect in 2023 and had a two-year period in which projects could transition to the 2022 CGP. This two-year transition period ends on September 1, 2025.

What This Means for Your Project:

If your project will finish construction before September 1, 2025:

• No changes are required.
• A Notice of Termination (NOT) must be filed through SMARTS before the deadline.

If your project will continue past September 1, 2025, and is currently under the 2009 CGP:

• You must file a Notice of Termination (NOT) in SMARTS to end coverage with the 2009 CGP.
• You must reapply for a new Notice of Intent (NOI) under the 2022 CGP, which requires a new SWPPP and updated application fees.
• Risk level dates will not change with this update and should still be calculated based on the actual construction start date, not September 1, 2025.

If your project was already submitted under the 2022 CGP:

• No changes are required

Key Changes in the 2022 CGP

The 2022 CGP includes several important updates. Below are some key changes:

*All updates can be found in the 2022 CGP Order, Fact Sheet, and Amendments on the CA State Water Resources Control Board website.

1. Post-Construction Document Requirements

• A WQMP must be uploaded to SMARTS in addition to the SWPPP.
• If the WQMP is not yet approved, a preliminary version may be uploaded.
• Once the WQMP is approved, it must be uploaded to SMARTS within 14 days.

2. Increased QSD Site Inspections

Qualified SWPPP Developers (QSDs) are now required to visit the site:

• Within 30 days of construction commencement
• Within 30 days of being replaced as QSD
• Within 14 days after a Numeric Action Level (NAL) exceedance
• Twice annually:

o   Once between August – October

o   Once between January – March

Note: The threshold for qualifying precipitation events has changed in the 2022 CGP.

3. Additional Compliance Requirements

• Trash capture provisions must be addressed in the SWPPP.
• TMDL (total maximum daily load) limits must be addressed for projects discharging into an impaired water body.
• Projects can change to an inactive status in SMARTS using a Change of Information (COI).