Storm Water Design Implementation - Where Intent Meets Reality.

Section 402 of the Clean Water Act, AKA the National Pollutant Discharge Elimination System (NPDES) requires a Construction General Permit (CGP) coverage for construction activities disturbing more than 1 acre of ground.  Prior to filing a Notice of Intent (NOI) for authorization under the CGP, the applicant must generate a Storm Water Pollution Prevention Plan (SWPPP) to address Erosion and Sediment Controls for both during and post construction Storm Water discharge management.  Although 402is a federal permit, most states and tribes manage the permitting process under the authority of the Environmental Protection Agency (EPA).  This dispersed designated jurisdiction creates a wide range of applications, standards, and submittal monitoring, inspection, and compliance documentation requirements.  Based on my experience with hundreds of NPDES authorizations and Storm Water, Erosion, and Sediment Control plans and performing Construction Management (CM) and Compliance Inspections (CI), this presentation is focused on the reality, or often times the lack thereof, of implementing plans that appear to be fine on paper, but prove to be problematic to implement consistently and in strict compliance to the plan.  We will review the critical need for SWPPP designers to be directly involved from initial on-site evaluations, through development planning, and reviewing the actual implementation for adaptive management and adjustment until the project is closed and the Notice of Termination (NOT) is filed.