The 2017 Construction General Permit (“CGP”) took effect on February 16, 2017. One item the EPA has implemented with the new CGP is a new NOI management system and certification process. The new system certainly is steps above the eNOI system and NOI certifiers will encounter a more straight-forward process to review and certify each NOI, Low Erosivity Waiver (“LEW”) and Notice of Termination (“NOT”).
CDX Net E-Reporting System
The EPA will now utilize the CGP NeT system through which it will accept, review and approve each NOI, LEW and NOT. Fortunately for existing users, the steps you will need to perform to be able to certify your project permits are quick and simple.
- Go to: https://npdes-ereporting.epa.gov/cgp
- Login with the same username and password you used for the CDX eNOI system.
- Add the NeT Program:
- On the MyCDX Homepage click ‘Add Program’.
- Select ‘NeT: NPDES eReporting Tool’; and then
- Select ‘NeT – EPA Stormwater Construction General Permit’.
- Select the ‘Certifier’ role
- Complete the Electronic Service Agreement (“ESA”)If you previously completed the ESA you will only need to answer the security questions you created during the initial account set-up to authenticate your account. If you have not completed the ESA, you will need to provide certain pieces of information which will be verified via LexisNexis. This information is for verification purposes only and is not saved or stored. You can choose to complete a paper ESA, but this will delay your account authentication.
The certification process will no longer require a certification key. Instead, after E2RC has prepared your NOI, LEW or NOT, we will route the document to you for review and certification. When we do this, you will receive an email notification indicating you have a form to review. After you log in to your CDX NeT account, the form will be ready to certify.
Ongoing Construction Projects
The 2017 CGP provides a May 17, 2017 deadline to transfer all NOIs for ongoing projects under the 2012 CGP to the NeT system. E2RC will do this for you. After the transferred NOI is active, we will then file the NOT for the previous NOI. This will prevent any gap in coverage and tie up loose ends. Note, however, the 14 - day activation period is still in effect for any new projects that will start under the 2017 permit.