MSGP Industrial Stormwater Permit — New Mexico Facilities Guide
The Multi-Sector General Permit (MSGP) covers industrial stormwater discharges — not construction activities. If your facility stores materials, fuels, or equipment exposed to stormwater, you likely need MSGP coverage in addition to any construction SWPPP. The MSGP 2021 expired February 28, 2026 — facilities currently operating under administrative continuance.
Facilities with prior MSGP 2021 coverage continue operating under its terms during administrative continuance. All inspection, SWPPP update, and DMR reporting obligations remain in effect. Inspections Plus will update client documents when EPA issues the new MSGP.
Who Needs MSGP Coverage — 11 Industrial Sectors
The MSGP applies to facilities that discharge stormwater associated with industrial activity through a point source to a water of the United States. The permit covers 11 sector groups — many of which are common in New Mexico's construction supply chain, energy sector, and mining industry.
| Sector | Industry | NM Examples |
|---|---|---|
| A | Timber & Wood Products | Lumber mills, sawmills |
| C | Chemical & Allied Products | Fertilizer, pesticide facilities |
| D | Asphalt Paving & Roofing | Asphalt hot plants, roofing materials |
| E | Glass, Clay, Cement, Concrete | Ready-mix concrete, block plants |
| F | Primary Metals | Metal fabricators, scrap yards |
| G | Metal Mining | Gold, copper, silver mines (NM active) |
| H | Coal Mining & Processing | San Juan Basin coal operations |
| I | Oil & Gas Extraction | Permian Basin support facilities |
| J | Mineral Mining & Processing | Aggregate, sand, gravel operations |
| K | Hazardous Waste Treatment | Licensed TSDFs |
| AD | Steam Electric Power | Power generation facilities |
MSGP 2021 Administrative Continuance — What It Means Now
When a general permit expires without a replacement in effect, EPA's administrative continuance provision allows facilities to continue operating under the expired permit's terms without interruption of coverage. This is not a waiver of requirements — it is a legal bridge that maintains your permit coverage while EPA processes the replacement permit.
What Continues
- All SWPPP requirements remain in effect
- Quarterly routine inspections required
- Post-storm inspections (within 24 hrs) required
- Annual SWPPP review and update
- Benchmark monitoring and sampling
- Discharge Monitoring Reports (DMRs)
What Changes
- New NOI filings paused (no new coverage until new permit)
- MSGP renewal NOIs on hold pending EPA action
- EPA tracking facilities on continuance
- New MSGP may have stricter benchmark limits
- Sector reclassification possible in new permit
- Monitor EPA Region 6 for new permit announcement
SWPPP Requirements Under MSGP vs. CGP
| Requirement | CGP (NMR100000) | MSGP 2021 |
|---|---|---|
| Activity type | Construction earthmoving | Ongoing industrial operations |
| SWPPP lifespan | Project duration | Facility lifespan (annual update) |
| Inspection frequency | 14-day + post-storm (0.25") | Quarterly + post-storm (0.25") |
| Benchmark monitoring | Not required | Required — sector-specific limits |
| Pollution Prevention Team | Not required | Required — named team members |
| Good housekeeping | BMP maintenance focus | Materials management + spill prevention |
| Annual reports | Not required | Annual SWPPP certification |
| Corrective action triggers | Inspection deficiency | Benchmark exceedance + inspection |
NM Industrial Facilities Commonly Affected
New Mexico's economy includes significant industrial sectors that commonly fall under MSGP requirements. If your facility fits any of the following descriptions, MSGP applicability review is warranted:
IPLLC MSGP Inspection & Compliance Services
Inspections Plus provides full-spectrum MSGP compliance for New Mexico industrial facilities, including:
- Industrial SWPPP development — sector-specific, benchmark-compliant
- Facility drainage mapping and stormwater exposure assessment
- Quarterly routine inspections with ComplianceGO digital reports
- Post-storm inspections within 24 hours of qualifying events
- Annual SWPPP review, update, and recertification
- Benchmark monitoring sampling coordination and lab submittals
- Discharge Monitoring Report (DMR) preparation and submission
- Corrective action documentation and follow-through verification
- Administrative continuance compliance tracking
- Coordination with co-located CGP construction SWPPP
Industrial SWPPP Deep Dives
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