2020 Environmental Real Estate Issues

Effective August 14, 2021, the Texas Commission on Environmental Quality (TCEQ) has issued the new 2021 Multi-Sector General Permit (MSGP) for industrial facilities.

Renewals Due by November 12, 2021
Existing permittees have until November 12, 2021 to renew their existing authorizations by submitting a renewal Notice of Intent (NOI) or No Exposure Certification (NEC), as applicable.  Submissions should be made using TCEQ’s online e-permitting system, SEERS/ePermits.
For facilities that discharge stormwater to a municipal separate storm sewer system (MS4), a copy of the NOI or NEC must be provided to the MS4 operator.

Key Changes from 2016 Version
MSGPs expire every five years.  Key changes from the 2016 version include:

  • An updated Stormwater Pollution Prevention Plan (SWPPP) must be developed and implemented before submitting the NOI.
  • The Delegation of Signatory Authority must be submitted to TCEQ, electronically, and kept with the SWPPP.
  • Some facilities may be able to use a representative weather station instead of an on-site rain gauge to monitor rain events.
  • TCEQ added requirements for best management practices for rubber, miscellaneous plastic products, and other miscellaneous manufacturing facilities.

Fact Sheet and Text of New 2021 MSGP
To see the Fact Sheet for the New 2021 MSGP, which includes a summary of principal changes from the 2016 version https://www.tceq.texas.gov/assets/public/permitting/stormwater/2021-msgp-fact-sheet.pdf

To see the New MSGP https://www.tceq.texas.gov/assets/public/permitting/stormwater/txr050000-2021.pdf