Ordinance does not specifically mention the use of City SWPPP template for CGP projects.  The result is some inequality between CGP operator’s and increased staff work load.  The City SWPPP template is a revised native State SWPPP Template that answers many of the questions by Operators.  Recommendation: Ordinance should require that CGP operator’s use the City SWPPP template to improve the quality of SWPPPs and create equality between CGP operators.  See 4.3 Land Disturbance Permit program for support documentation.