NMR100000 vs. NMPDES: Side-by-Side Permit Comparison
NMR100000 is the current EPA Construction General Permit for New Mexico construction stormwater. NMPDES is the emerging state-administered permit program under Senate Bill 21. For 2026, both may apply simultaneously during the administrative continuance period.
Last updated: April 2026
8-Dimension Permit Comparison
Key Takeaway for NM Contractors
The NMR100000 permit does not expire or become invalid when NMPDES takes effect. Under administrative continuance, operators with existing NMR100000 permit coverage remain in compliance with state requirements while NMED formally transitions the program. No action is required during the continuance window other than maintaining full NMR100000 compliance.
For construction projects beginning after the NMPDES effective date, operators will file NOIs directly through NMED eDMR. The permit number, forms, and regulatory contact will be different. Inspections Plus monitors the WQCC docket and handles all transition filings for active clients.
The most important action now: watch for the WQCC's decision on the NMPDES rules (the June 8–18 hearing has concluded), and ensure your SWPPP includes NM-specific provisions so you're ready before the transition takes effect.
Frequently asked questions
What is the difference between NMR100000 and NMPDES?
NMR100000 is the current EPA Construction General Permit for New Mexico construction stormwater, while NMPDES is the emerging state-administered permit program under Senate Bill 21. For 2026, both may apply simultaneously during the administrative continuance period.
Does NMR100000 expire when NMPDES takes effect?
No. The NMR100000 permit does not expire or become invalid when NMPDES takes effect. Under administrative continuance, operators with existing NMR100000 coverage remain in compliance while NMED transitions the program, with no lapse in coverage.
Who administers each permit?
NMR100000 is issued by U.S. EPA Region 6 in Dallas, while NMPDES is administered by the NMED Surface Water Quality Bureau in Santa Fe, which handles compliance, inspections, and violations.
Where are NOIs filed under each permit?
Under NMR100000, NOIs are filed through EPA NeT at cdx.epa.gov. Under NMPDES, filing moves to the NMED eDMR system, and operators must create a new NMED eDMR account.
What triggers permit coverage?
NMR100000 requires coverage for 1 or more acres of soil disturbance or activity that is part of a common plan of development. NMPDES is expected to retain an equivalent 1-acre threshold and may add state-specific thresholds.
Related resources
Ready to get started?
Inspections Plus provides transparent, itemized estimates — not fixed-price contracts. Call or submit a request and we'll follow up within 1 business day.