OK, it has been a while since I last updated this Blog. The reason, we've been busy writing SWPPP's, WPCP's, doing Inspections, Training people how to spell BMP, and overall trying to provide the right combination of materials and labor to our many clients. It has been an interesting 6 months, many former clients are no longer around, many have downsized and others, well they're just waiting for the compliance violation shoe to drop. You're probably not surprised that compliance, viewed by many as unimportant in light of the economic times, has taken a backseat because of budget constraints, both on the part of contractors, as well as a lack of effective enforcement by Cities, and the State, etc. It's understandable, contractors are in a highly competitive environment just to win work and survive, and the state, which is virtually in a bankrupt position due to reasons best not discussed in polite company, have limited their resources. The result is that contractors seek to skirt around the regulations, and the City and State Inspectors are few and far between because lack of staff resources, lack of training resources, or just lack.
Hopefully, if you're in the business of storm water compliance in the State of California, you are aware that there is a new NPDES Permit...as in National Pollutant Discharge Elimination System Permit (September 2nd, 2009) that will be brought into force on July 1st, 2010. Translated, this is the states answer to past EPA/CWA non-compliance trespasses. Basically this permit is the state promising the Feds (for Federal $ of course) that they will follow and enforce the regulations established in the Clean Water Act in its current and ever evolving phasing process, as interpreted by the EPA. The new NPDES Permit has a number of things that will change and hopefully improve storm water runoff quality through the tightening up of the filing submittals process, the project evaluation process, and the runoff monitoring process including sample testing (TMDLs etc.).
Some basic rules, any site over an acre must have a SWPPP, Storm Water Pollution Prevention Plan. Every project requiring a SWPPP is required to file a NOI, Notice of Intent w/fees, unless there is a prior existing permit, e.g. some cities, water districts, Caltrans etc., and then they will require a NOC, Notice of Construction. Each project must be assessed individually, but some form of documentation is absolutely essential. ($5000 fine) for failure to file is hardly worth the cost of filing for the NOI, FYI the NOI fees are determined/stated in an established schedule published by the state and fees are based on acreage (remember always round up), e.g. one acre with the current surcharge is $317, subject to change of course. Currently there are many SWPPP formats, but the standards are CASQA and Caltrans, all others are typically hybrids of these two that have been developed by an energetic consulting community, helping Cities, Counties and Water Districts be different. Oh, and also making it difficult for amateurs to develop SWPPP's. The new NPDES Permit will hopefully usher in some standardization of the SWPPP Templates again.
The final point I wanted to make today is in regards to training and the qualifications of both inspectors and SWPPP developers. The new NPDES permit spells out the minimum requirements for an authorized storm water BMP inspector, specifically that a non-PE must be either a CISEC or CESSWI, a CISEC is a Certified Inspector in Sediment and Erosion Control, a CESSWI is a Certified Erosion, Sediment and Storm Water Inspector. The prep class for the tests are available frequently, but prior to testing an individual must be approved to sit for the exam by providing proof that they have an adequate understanding of the requirements to be an Erosion & Sediment Control Inspector through classes, seminars, field work etc. Once certified as a CISEC or CESSWI, the state will require additional coursework, currently under development, followed by the successful passing of a state exam by September 2011, to be considered state approved/certified.
The prerequisites to become a qualified SWPPP preparer requires that if you are not a qualified PE then you must be a CPESC, Certified Professional in Erosion and Sediment Control. Once qualified as a CPESC, the state will also require additional coursework, and a state exam prior to September 2011 to be considered state approved/certified.
