What must the Operator develop first?

The Operator must first develop the Stormwater Pollution Prevention Plan (SWPPP) as it serves as a critical framework to manage stormwater runoff and prevent pollution during construction activities. The SWPPP outlines how to comply with the requirements of permitting and addresses potential sources of pollution that may affect stormwater. This plan not only identifies the best management practices (BMPs) to be used but also includes procedures for maintaining these BMPs throughout the project.

Developing the SWPPP is essential before any construction activities begin, as it sets the guidelines for environmental compliance and ensures that proper erosion and sediment control measures are in place. Without a solid SWPPP, operators may face issues with stormwater management, leading to potential non-compliance with regulations, environmental damage, and financial penalties.

While submitting the Notice of Intent (NOI) might seem like a priority, it is contingent upon having a thorough SWPPP developed to demonstrate that the operator is prepared to implement the necessary controls. Similarly, perimeter fencing and other construction activities cannot commence effectively without the foundational plan in place dictating how to handle stormwater responsibly and effectively.