Avoid the pitfalls. According to Willobee, there are common design concerns that SWPPPs frequently overlook. He sees the following problems in many construction SWPPPs:
- Failure to specify appropriate stabilization measures for temporary diversion ditches
- Excessive reliance on sediment control practices such as silt fences, sediment basins, and inlet protection
- Lack of run-on controls
- Insufficient information for transition between construction phases
- Failure to include instructions for management of flows during stream work
- Undersized best management practices (BMPs)
Sequence BMP implementation. Willobee encourages SWPPP designers to provide detailed instructions for the timing of BMP installation with respect to construction activities. The plan should be specific as to how and when BMPs should be implemented and the intent behind their integration. When sequencing BMPs, the plan should be flexible as construction activities may change, and all sequencing should be reviewed by someone with construction experience.
Consider weather conditions. When creating a SWPPP, designers should look at the longevity of the project and how the project could be affected by the changing of the seasons. Specifically, Willobee pointed to the following BMP concerns:
- Inlet protection: will the selected inlet protection measures cause flooding or ice formation on public roadways?
- Dust control: will a water truck be sufficient or economical if construction occurs during a dry season?
- Seeding information: will planting occur at a specific time and is it temporary or permanent?
Include permit requirements. Willobee stated that one of the major goals of a good SWPPP is to set a contractor up for success in erosion and sediment control and to do that, the SWPPP should set out both state and local requirements in plain language, highlighting the most stringent applicable requirements to avoid confusion. A SWPPP should clearly state required inspection frequencies, monitoring requirements, and temporary and permanent stabilization criteria, and include necessary forms and logs. The contractor and site operator will be implementing the SWPPP to prevent stormwater contamination, control sediment and erosion, and comply with the Clean Water Act, and it’s in every stakeholder’s interest to make sure that the SWPPP is straight-forward, detailed, and complete in order to minimize risk and be in compliance.
Amanda Czepiel, J.D.,., is a Legal Editor for BLR’s environmental law publications. Ms. Czepiel has over 8 years of experience as an attorney and writer in the field of environmental compliance resources and has published numerous articles on a variety of environmental law topics, including wastewater and NPDES permitting, brownfields and contaminated sites remediation, oil spill prevention, wetlands, and corporate sustainability. Before starting her career in publishing, Ms. Czepiel worked in hospitality consulting and for various non-profit organizations and government agencies in the environmental field. Ms. Czepiel received her law degree from the University of Connecticut School of Law.