ADVOCATING FOR THE INDUSTRY - REGULATORY


AGC Advocates in Action


AGC of California


immediately sprang into action following the release of the draft CGP. Working with an industrywide coalition, they secured a meeting with the Governor’s office to discuss their concerns. In addition, industry and labor sent several representatives— including AGC member contractor representatives from Teichert, Flatiron and Granite Construction – to an August 4, 2021 meeting of the Water Board. During this meeting they had the oppor- tunity to give an in-depth presentation outlining industry concerns with the draft permit and recom- mendations on how it could be changed to be fairer and more workable for all. AGC of California as well as AGC San Diego separately submitted formal written comments to the Water Board providing specific industry feedback and recommendations. Just of few of the broadscale


concerns from AGC and other industry


groups include:  Te draft permit would jeopardize infrastructure and economic development projects as the Numeric Effluent Limits (NEL) approach taken in the draft permit is unworkable and technically infeasible.


completed.  Te permit proposal opens the


door to frivolous “bounty hunter” type of lawsuits, with owners and construction companies bearing


the burden of compliance.  Tere are much more effective approaches available to protect water quality without jeopardizing projects. Te coalition argued in their presentation to the Water Board that the Best Management Practices (BMP) approach in the existing permit, combined with numeric action levels (NALs), is a feasible approach to achieve


by AGC partner the Construction Industry Coalition on Water Quality (CICWQ) estimates that cost increases on projects built by CICWQ members would range from 53% to 177% over the current CGP requirements. Tis increased cost is projected to result in fewer projects being bid on and


 Te permit proposal would significantly increase costs for all construction, hurting taxpayers and consumers. According to the presentation at the Water Board hearing in August, a recent analysis by Michael Baker Associates shows a minimum 46% compliance cost increase for linear transpor- tation projects. Additionally, an engineering case study outlined


www.AGC-CA.org


“We have continued to actively advocate on behalf of our members and stress the importance of what construction industry priorities are in relation to the


permit.” – Manny Leon, AGC Vice President of Government Affairs


environmental goals.  More expert staff would be required on jobsites to implement the stormwater pollution prevention plan (SWPPP) inspection and to engage in site monitoring and reporting require- ments, both on the compliance and enforcement site.


Advancing Construction Priorities


“We have continued to actively


advocate on behalf of our members and stress the importance of what construction industry priorities are in relation to the permit,” commented AGC of California Vice President of Government Affairs, Manny Leon. “Currently we are in a holding pattern to hear back (from the Water Board) but if we don’t, we will continue to reach out to actively advocate on this issue on behalf of our members.” Te Board may pass the proposed


CGP at any time and reportedly targets passage by fall 2021. While Leon expressed confidence that the construction industry concerns have been heard both by the Governor’s office and the Water Board, AGC will continue to vigorously advocate for industry interests. Should the adopted permit not adequately address industry concerns, “I think we could anticipate another legal challenge,” Leon added. 


Associated General Contractors of California 11


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