NJCAA Concrete Industry
Stormwater Permitting Project Update
By: Doug Ruhlin, Resource Management Associates

Doug Ruhlin of Resource Management Associates, Inc. (RMA) and Bill Layton, Executive Director of the NJCAA, recently met with the NJDEP regarding the "next phase" of the NJCAA Group Stormwater Permitting project. A status report of the project, and a summary of the next phase, are presented for your information:

1. The General Permit that currently covers virtually every concrete plant in New Jersey, known as the Concrete Industries Alternative General Permit is a 5-year NJDEP permit, like all other state water quality permits. The permit is due to expire, for all facilities, on 7/31/00 (about 6 months from now!).
   
2. The NJDEP will be reissuing this permit through their normal course of events: this means a renewal for the permit as a whole. Each facility's coverage will remain in force until a renewal permit is in place. You will have no gap in your permitting!
3. Doug Ruhlin and Bill Layton have spent a great deal of time negotiating several key points regarding this renewal permit with the NJDEP. We are happy to report that in almost all cases, we have received what we asked for. This is due in great part to the entire concrete industries efforts over the last 4-5 years.
   
4. As you know, the permit has been "paperwork extensive". The NJDEP has agreed that individual facility "renewals" are not needed-rather, your facility will be rolled over in the new renewal permit for the next 5 years without having to do any application (NOI) paperwork on our part.
5. Secondly, NJCAA discussed with the NJDEP the future of stormwater monitoring. As in the past, it was our goal to eliminate the stormwater monitoring beyond the first 5 year permit provided that our first monitoring plan worked. It has! The NJDEP is quite impressed with the stormwater monitoring data we have obtained and submitted, which clearly shows that as an industry we have done a great job at our sites, and that the BMP's we've employed really do make a difference. As a result, the NJCAA was successful in getting the NJDEP to agree to no further monitoring! In other words, no concrete facility will have to monitor stormwater in the future. This is a major success for the industry. This alone will result in hundreds, if not thousands, of dollars of savings over the next 5 years for each and every concrete plant. Congratulations!
6. Unfortunately, permit fees will remain the same ($1,300 per year), or face the NJDEP's fee increases. We could not negotiate lower fees. However, remember, if we didn't do this program, every concrete plant would require an individual permit, with fees starting at $2,350 per year. Over the course of a 5-year permit, this means a savings of $5,000 in permit fees alone!
7. Speaking of savings.... We estimate that between permit fees, and not having to do quarterly stormwater monitoring, each plant is saving a minimum of $7,500 over the next 5-years period. For the approximately 90 plants in the program, this means a total savings to the concrete industry of over $600,000 over the next five years. This is a fantastic savings to our industry and one that our competition doesn't get.
8. Unless there is a change to your facility, you do not need to revise your Stormwater Pollution Prevention Plan (SWP3). If you choose not to, you continue on, into the next 5 years of your permit. However, we strongly suggest that you let RMA revise your SWP3 for the next 5 years. As you know, the NJDEP enforcement arm has been ridiculously vigilant with the concrete industry. My goal is to revise as many SWP3's as RMA can to reduce the amount of information contained in and to streamline them. Our goal should be to make them easier for you to use, and giving the enforcement folks less ammunition to use against us. Look for more information in the near future on this, or make sure to attend the Stormwater Permitting Seminar at the Mid-Atlantic Concrete and Aggregate Forum in Atlantic City in early March.
9. Also, for anyone choosing to participate again, note that the total cost will be a lot less than the first time. Secondly, we are going to try to use e-mail and the NJCAA's web page to streamline the paperwork aspects of this project. You will be receiving communications, forms, etc. via e-mail (if you have it). This should help us all immensely. If you do not have access to e-mail, don't worry, we can still handle things the "old-fashioned" way.
10. Your participation in the NJCAA group project comes to an end at the completion of this 5-year project in August. Before that, we will notify you to see if you would like to continue this project through the NJCAA by having your SWP3 revised by RMA, as well as continuing to let us oversee your paperwork aspects of this program. Whether you choose to or not, you will definitely be realizing significant savings for each and every plant you own because of your past participation in this program. We hope you will want to continue for the next five years. If you need further information, please contact Doug Ruhlin at 609-693-8301.

NJCAA Meets With Pinelands Commissions Staff
Members of the NJCAA met with Pinelands Commission Executive Director Bill Harrison to discuss mineral extraction in the region. As a result of these discussions, the Pinelands Commission has assured the NJCAA that they will leave resource extraction in the Comprehensive Management Plan alone. In addition, members of Pinelands Commission Staff will work with the NJCAA and its members in talking to local elected officials to change the mining permit time periods from two to five years. If your company is interested in changing its current permit, please contact Bill Layton of the New Jersey Concrete and Aggregate Association.