Filing An NOE? EPA now requires electronic submission Reply

Did you know? The EPA issued a new No Exposure Certification (NOE) form under the 2015 Multi-Sector General Permit on June 4, 2015. You now must submit your No Exposure Certification electronically using the NPDES eReporting Tool on the EPA Central Data Exchange CDX website, unless you have a waiver from the EPA Regional office to use the paper form.

Please refer to the following guidance on using the NeT:

If you are given a waiver from your local EPA office corresponding to your facility location to use a paper NOE form, you may complete and submit the paper form available at:

For assistance or further information, please contact

Have you missed the August 3 deadline for Endangered Species? Reply

For existing permit holders

If you missed the August 3 deadline and realize you have endangered species on your property,  the EPA may be able to provide an expedited ESA review or provide an extension to the September 2, 2015 deadline on a case-by-case basis. Please call or email Lucy Servidio at CAPACCIO at 508-970-0033 ext. 114 or for additional information. Visit our stormwater portal for valuable information and tools to assist you with your MSGP submittal on our home page at

Annual Rideshare Reports Due December 31, 2015 Reply

As you may be aware, the Massachusetts Department of Environmental Protection’s (MassDEP’s) Rideshare Regulation (310 CMR 7.16) requires facilities that meet certain criteria to complete and submit an annual Rideshare Report summarizing their rideshare program.

The criteria that must be met to be applicable to these requirements includes:

  • Businesses with 250 or more applicable commuters that are subject to the MassDEP Air Operating Permit Program (310 CMR 7.00, Appendix C) or
  • Businesses with 1,000 or more applicable commuters
  • Educational institutions with 1,000 or more applicable students or applicable commuters combined

The definition of “applicable commuters” is employees that work 17 hours or more per week for 20 or more weeks per year; that commute to work between the hours of 6:00 a.m. and 8:00 p.m.; and use their vehicle for work purposes during work hours less than 5 times per month. “Applicable students” are students that are full-time commuting students and live off campus; are scheduled to begin and complete classes between 6 a.m. and 8 p.m.; and need their vehicle for class assignments or for after-school work less than five times per month.

For further details, please visit:

If you meet the rideshare requirements, your annual report is due December 31, 2015.

What must you do if your business/educational facility meets the requirements?

  • Collect data by surveying your employees/students current commuting patterns*
  • Identify available commuting options
  • Set goals and develop a plan for reducing drive-alone commute trips by 25 percent
  • Offer options and incentives to reduce drive-alone commute trips
  • Review how commuting patterns will change as a result

*For the majority of businesses and educational institutions this year is a short form year so a survey is not required; however, many companies choose to conduct a survey each year.

Many facilities find collecting rideshare data from employees a challenge. CAPACCIO has been helping clients make the process easier and more efficient. Using web-based forms we developed, CAPACCIO can host your custom commuter survey online and collect data in a database for easy analysis. The findings can be shared with employees online and also be tailored to report commuter trends for your environmental management system (EMS) objectives and targets and help facilitate the completion of your rideshare report. The tool may also be tailored to your facility’s internal programs where employee transportation has been identified as a significant environmental aspect in your EMS goals and targets. Please see CAPACCIO’s rideshare service sheet for more details or visit our website for our entire suite of services.

For more information on CAPACCIO’s rideshare services, please contact Dan Forsythe at (508) 970-0033 ext. 135 or

How could this cute little creature impact your stormwater NOI? Reply

LONG EARED BATAccording to the Natural Heritage & Endangered Species Program, the Northern Long-eared Bat is listed as Endangered and protected under the Massachusetts Endangered Species Act. This population of bat has been devastated by the spread of White-nose Syndrome, a type of fungus found in caves that grows over the bat during hibernation, causing them to periodically wake from hibernation, lose valuable stored fat, and fail to survive the winter.

While the delineation of most endangered species’ habitats are limited to certain areas like low lands, marshes, fields, etc, the critical habitat for the Northern Long-eared Bat is the entire state. As a result, when using the US Fish and Wildlife Service’s (FWS) “Information, Planning, and Consultation” (IPaC) mapping system to delineate your stormwater action area, the Northern Long-eared Bat will show up.  According to the instructions in Appendix E of the Multi-Sector General Permit (MSGP), “if you have determined that there are, or may be listed, species and/or designated critical habitat in your action area, you are not eligible under Criterion A and must complete the Criterion C Eligibility Form 30 days prior to submitting your NOI for permit coverage.” Therefore, all Massachusetts Notice Of Intent (NOI) filers under the MSGP would need to submit the Criterion C Eligibility Form by August 3, 2015.

In conversations with the EPA, this is not what they had intended.  According to the EPA, they are working with FWS to develop additional guidance for filers to use when making a Criterion A or Criterion C determination. Stay tuned. As soon as CAPACCIO has more information on this guidance, we will be sure to share it.

For more information about the MSGP, check the home page of our website where we have a Stormwater Information page which includes numerous resources like recorded webinars, presentation slides, and frequently asked questions regarding the MSGP. Feel free to submit a question through our Ask The Experts button on the home page of our website if you have any further questions.

More information about the Northern Long-Eared Bat is available at this link;