Industrial SWPPP & MSGP Compliance — New Mexico Facilities Guide
Industrial stormwater is a separate compliance path from construction. If your facility stores materials, fuels, or equipment exposed to stormwater, you likely need a Stormwater Pollution Prevention Plan (SWPPP) under the EPA Multi-Sector General Permit (MSGP) — not the Construction General Permit (CGP). New Mexico does not administer the industrial program, so MSGP coverage runs through EPA directly. The 2021 MSGP expired February 28, 2026 and is on administrative continuance.
Construction vs. Industrial SWPPP at a Glance
The two NPDES stormwater programs require a SWPPP, but they cover different activities, run on different lifecycles, and carry different inspection and monitoring obligations. Treating one as a substitute for the other is a compliance failure with real enforcement exposure.
| Dimension | Construction — CGP | Industrial — MSGP |
|---|---|---|
| Activity covered | Land-disturbing construction | Ongoing industrial operations |
| Permit | CGP — NMR100000 (NM) | MSGP 2021 (federal EPA) |
| Trigger | 1+ acre disturbance | Facility in a covered industrial sector |
| SWPPP lifespan | Project duration → NOT | Facility lifespan, reviewed annually |
| Routine inspections | Every 14 days | Quarterly visual observations |
| Stormwater sampling | Not required (visual) | Sector-specific benchmark monitoring |
| Pollution Prevention Team | Not required | Required — named team members |
| Closeout | File NOT at final stabilization | Renew every 5-year permit term |
See the full breakdown on CGP vs. MSGP.
Industrial SWPPP Deep-Dive Pages
Does Your Facility Need an Industrial SWPPP?
The MSGP applies to facilities that discharge stormwater associated with industrial activity through a point source to a water of the United States. If any of the following describe your operation, an MSGP applicability review is warranted:
What Industrial Operators Should Do Now
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