Picture this: It’s late August 2025. Your construction site is making great progress; steel is going up, concrete curing, the trades are on schedule. But while everyone’s eyes are on the next inspection or milestone, a quiet deadline is sneaking up fast: September 1, 2025. That’s when California’s updated Construction General Permit (CGP), adopted in 2022, becomes fully enforceable.
This isn’t just a bureaucratic update. It’s a shift in how stormwater compliance works, from who’s accountable to what gets inspected and reported. If you’re a Legally Responsible Person (LRP), builder, QSD, QSP, or project manager, you need to be ready.
Let’s break it down.
What the Legally Responsible Person (LRP) Needs to Know
The LRP is the leader and ultimately the one responsible. With the updated Construction General Permit, things are a bit more complex.
- New Permit Enrollment: The new permit isn’t automatic. You’ll need to submit a Notice of Intent (NOI) for all active projects under the new 2022 Construction General Permit, even if you’re already covered under the old one.
- Updated SWPPP Requirements: Your Storm Water Pollution Prevention Plan (SWPPP) will need to be reviewed. Plans must reflect new monitoring requirements, updated Numeric Action Levels (NALs), and revised risk calculations.
- Role Clarification: The LRP is now more squarely responsible for ensuring the site’s QSD/QSP team is qualified, up-to-date, and actively managing compliance under the new standards.
Action Items
- Re-enroll all active sites under the new Construction General Permit.
- Have a QSD update your SWPPP.
- Ensure your team knows how to implement the new monitoring, mapping, and reporting rules.
What Builders & Project Managers Need to Know
If you’re running a project or construction site, the rules are changing, and you’re still expected to hit your deadlines. Here are some key things to know about a Construction General Permit:
- More Frequent Monitoring: Consider post-storm inspections, sampling, and BMP checks, especially after big weather events. You’ll need a process and system to track it all in real time.
- BMPs That Actually Work: The new CGP emphasizes effectiveness. It’s not just about throwing down wattles anymore, it’s about demonstrating that they work. Poor BMP maintenance could now trigger enforcement actions much faster.
- Tighter Closeout Process: Final stabilization and your Notice of Termination (NOT) just got a little more challenging. Expect new requirements for mapping and photographic documentation.
Action Items
- Budget and plan for ongoing BMP maintenance, not just installation.
- Assign someone to handle storm response and documentation.
- Meet with your QSP or SWPPP vendor to review site readiness.
New Risk Calculations and Receiving Water Considerations
One of the biggest technical changes involves how project risk is calculated. The 2022 Construction General Permit includes updated worksheets and expanded GIS-based tools, such as the TMDL Map Tool, High-Risk Receiving Waters Map, and new LS and K Factor Map Tools. These tools help determine:
- Your site’s sediment risk.
- Proximity to impaired or sensitive water bodies.
- Required BMP tiers and monitoring frequency.
If your project discharges to a water body with a Total Maximum Daily Load (TMDL), you may be subject to additional, location-specific monitoring and reporting.
Pro Tip: Don’t wait until the rainy season to assess this, your site’s proximity to high-risk waters can significantly affect compliance strategy.
Whose Role Is Changing?
It’s not just a shift in paperwork; it’s a shift in responsibility.
Qualified SWPPP Developers (QSDs) must now provide enhanced site assessments and detailed runoff evaluations. This includes evaluating pollutant sources, the use of updated risk calculation tools, and identifying site-specific stormwater vulnerabilities. QSDs are also expected to propose targeted BMP strategies based on their findings, tailored to the site’s evolving construction phases and storm patterns.
Qualified SWPPP Practitioners (QSPs) are taking on a larger role in ongoing monitoring, sampling, and documentation. This includes more frequent inspections, especially after Qualifying Precipitation Events (QPEs), and must follow stricter protocols for collecting and reporting water quality samples. QSPs also play a critical role in evaluating BMP performance and triggering corrective actions when stormwater benchmarks are exceeded.
The LRP, as always, signs the dotted line, but under the new permit, they’re expected to have clearer lines of oversight and active engagement.
Builders, project managers, and superintendents need to communicate with these roles like never before, because disconnection could now mean noncompliance.
Training & Certification Updates
The new CGP also tightens the rules around who can serve as a QSD or QSP. Certification now requires:
- Approved credentials from agencies like CASQA, EnviroCert, or the CA Board of Engineers and Geologists.
- Updated training on 2022 CGP standards.
- Registration through the Stormwater Multiple Application and Report Tracking System (SMARTS).
The California Stormwater Quality Association (CASQA) is administering the certification process. Details are available here.
Make sure your team’s credentials are valid and reflect the new prerequisites, especially if they were certified before 2023.
Your 90-Day Countdown Checklist
If you haven’t started preparing for a Construction General Permit, the time is now. Here’s a simplified roadmap to stay ahead:
- ASAP: Schedule a call with your QSD/QSP team. Ask: “Is my SWPPP ready for the new permit?”
- June 2025: Begin re-enrolling your projects under the 2022 CGP. Update your NOI, SWPPP, and site map.
- July 2025: Ensure your field crews are trained on new inspection forms, sampling protocols, and BMP expectations.
- August 2025: Confirm that all data management systems are ready for reporting under the new format.
- September 1, 2025: You’re either compliant or at risk. Don’t wait until the first rainstorm to find out which.
Final Thought
This isn’t just another compliance checkbox. It’s a shift in how stormwater is managed on California construction sites. The state is making it clear: protection of water quality is a project-wide, shared responsibility.
So, whether you’re in the field, the office, or reviewing final punch lists, take the time now to get aligned, get educated, and get your documentation dialed in.
Use of a single point of contact for your SWPPP planning, inspections, and BMP maintenance streamlines communication, ensures consistency in effective compliance strategies, and minimizes the risk between planning and execution. It simplifies oversight and helps keep your projects ‘inspection-ready’ from start to finish.
Need help with your SWPPP updates or BMP maintenance plans? Contact SWIMS today and let’s make sure your site is inspection-ready before September 1.