Does Your Business Need IGP Coverage?
Senate Bill (SB) 205 was signed into California State Law by Governor Newsom on October 2nd, 2019 and became effective on January 1, 2020. This is a groundbreaking law that that requires businesses to provide proof of compliance with the Industrial General Storm Water Permit (IGP) in order to obtain or renew a business license. The intent of the law is to find companies that are required to meet the requirements of the IGP but are not doing so (referred to as non-filers by the Water Board). How much of a change is this new law? There are approximately 10,000 industrial facilities regulated under the IGP in CA; the Senate Floor Analysis estimates that there are 6,000 non-filers just in Los Angeles!
What Does This Mean for My Business?
Each city or county may approach their outreach differently. We've seen many examples of questionnaires being sent to businesses asking for information regarding your Standard Classification Code (SIC) and proof of registration under the IGP, such as WDID#, WDID Application #, NONA ID#, and/or NEC #. This is because the requirement to enroll under the IGP depends on what type of business you are, i.e., your SIC code. If it turns out that you need to enroll under the IGP but have not yet done so, your city or county may allow three months to meet all requirements. However, this regulation has been in its current form since 2015 and most businesses subject to this regulation should have had coverage since the 1990s. Therefore, it is important to be proactive and come into compliance as soon as possible.
Enrolling in the IGP could potentially be simple if your operations are indoors, under cover, or otherwise not exposed to storm water. However, if outdoor exposure to industrial materials or activities exists, your compliance obligations could be greatly increased. This includes implementing minimum Best Management Practices (BMPs), conducting storm water sampling and visual monitoring, developing a Storm Water Pollution Prevention Plan (SWPPP), staff training, recordkeeping, reporting to the State Water Board, and paying annual registration fees.
Where Can I Find More Information?
The best way to find out more is to give us a call. ALG has several Water Board-certified storm water professionals available to answer your questions:
Jayme Dryden: 805-764-6005, QISP-ToR Cert No. 00029
Lisa Kiehl (QISP Cert. No. 00927) 805-705-7601, or
Elliott Ripley (QISP Cert. No 00354) 805-764-6004
Please see the following link for more information on SB 205: