When preparing to execute a significant construction project, stormwater pollution prevention is likely the last thing on your mind. However, if your project requires a permit, you’ve probably been confronted with SWPPP. Likely, this isn’t the first time you’ve heard about pollution prevention, but understanding what goes into compliance is another story.
What is a Stormwater Pollution Prevention Plan?
A stormwater pollution prevention plan (SWPPP) is an element of your site plan that identifies steps to control erosion and runoff from areas where pollutants may be present. In some cases, facilities that reduce their stormwater pollution below compliance requirements can actually generate a profit from their stormwater pollution prevention activities. (More on that later)
Although the title of your state-specific stormwater compliance policies may have different labels (look for keywords like Erosion, Sediment, Stormwater, and Best Management Practices), they tend to have many common elements. For further details on federal water quality standards, you can look at the Official EPA SWPPP Guide. For the scope of this article, we’ll try to stick to understanding compliance and the application process versus a fully comprehensive overview.
So, let’s dive into what you need to get your site compliant to file your permitting application ONCE and break ground ASAP.
Basic Steps on Preparing a Compliant SWPPP:
- Get a basic lay of the land. You’ll want to survey, identify, and understand your soil, site grade, and relevant local watersheds. This is also a great time to start doing research on commercial incentives* available to Green Infrastructure. Create a Free Rainplan account to search for incentives by site address and view options on your Rainplan Dashboard.
- Review EPA Considerations, both federal and local. Here is a Summary of State Stormwater Standards provided by the EPA. You’ll likely still want to check your state website for the most updated information. Here’s a list of state EPA agencies.
- Identify on-site and resulting pollutants from the project to identify the specific stormwater controls necessary for your project.
- Select stormwater control options, including green infrastructure solutions and SRCs.
- Submit “Construction Ready” SWPPP to the stormwater management department in your state.
- Upon getting approval, implement your stormwater prevention plans.
- Submit your permitting application.**
- Schedule your inspection.**
* Most states offer considerable Commercial Incentives for Green Infrastructure. For the latest information, schedule an appointment with a Rainplanner. You can also browse a list of Commercial Incentives
** Depending on your state, your local EPA may need the inspection before applying. Some states provide a list of approved third-party inspectors. Others yet, schedule the inspection for you upon submitting your application.
What Details Go Into an SWPPP?
The SWPPP must list steps taken to control erosion and runoff before, during, and after construction. At a high level, the goal is to prevent pollutants from entering any waters of the United States during rainstorms. You’ll need to visit your local and municipal agency for specific quantities and calculations. Find your state here.
Primary EPA Considerations for your SWPPP
The state requires an SWPPP for any construction activity where erosion and runoff could add pollutants to stormwater. Important considerations the EPA will care about include:
- changes the existing grade level of at least one acre of land (Important if your project includes site excavations or grading)
- discharges to United States waters during construction activities (Important for excavations, filling operations, and disposals of dredged or fill material, excluding de minimis discharges)
- Areas with “Temporary Impacts” (land-disturbing activities that have a “temporary water quality impact”) including construction activity that has impacts less than or equal to one acre
- Local Permits/Specific General Permits – it’s crucial to review specifications with your state environmental quality agency for any outliers that may apply to your project. (More on that below)
State or Regional Specific Considerations
It’s essential to check with the Environmental Protection Agency in your state. (find a list of EPA regions & State Agencies here) to ensure you don’t lose time resubmitting your application. Different states have different standards, so make sure that you’ve included all the relevant schematics and summaries.
Standard documents to look for may be titled any of the following:
- Construction Site Best Management Practices Plan
- Best Management Practices Plan
- Construction Best Practices Plan
- Erosion Control Plan and Best Management Practices
- Erosion, Sediment, and Pollution Prevention Plan
- Erosion and Sediment Control Plan
- Sediment and Stormwater Plan
Types of Pollutants that could be present on the construction site:
All identified or suspected pollutants present on the construction site must be disclosed in the stormwater pollution prevention plan. Different construction sites create various yet specific pollutants and degrees of pollution. These may include water-borne materials, petroleum products, pesticides, fertilizers, and chemicals used for equipment operations. Sediment is also an important factor and consideration that could interfere with SWPPP compliance and prevent approval of your permit application, so be sure you account for it. This may also include sediment impacts resulting from erosion control measures.
Standard Stormwater Mitigation Options
- Green Infrastructure – for commercial projects planting trees, installing a bioswale, and using permeable pavement for hardscapes are popular and scalable measures to mitigate stormwater runoff. This option is advantageous for most because a majority of states offer considerable incentives for commercial, non-profit, HOA, educational and government construction projects. Green infrastructure also allows some projects to produce stormwater retention credits (SRCs).
The SRC instrument allows projects that reduce their stormwater pollution below the requirements to generate a profit from their stormwater pollution prevention activities. - Sediment Fences – Temporary fencing designed to prevent soil erosion. While sediment fences are not required controls, they may positively enhance some permit applications for more permanent erosion controls.
- Soil Binders – Another tool that is not required but may offer leverage by keeping soil on construction sites. Some examples are straw bales, balled mulches, or biodegradable netting.
- Daily Cover – A temporary erosion control measure that prevents exposed soils from absorbing rainwater. Examples include large wood chips, straw, landscape fabric, and gravel.
- Properly Storing and Containing Materials – This includes keeping any material piles covered in areas where rain could wash them into the waters of the United States.
Other Considerations for SWPPP Compliance
SRCs (stormwater retention credits) – This option is available to offset stormwater pollution in a few states. Commercial properties can sell stormwater “credits” to other entities to offset the latter entity’s stormwater mitigation obligation by building additional green infrastructure. Read more on stormwater retention credits.
Passing the SWPPP Inspection
Once your plan is submitted (usually), it will be reviewed for compliance with EPA regulations by an approved third-party inspector. In some cases, depending on the state and project size, the state may hire a certified inspector to analyze your property.
What Does an SWPPP Inspector Look For
When inspecting SWPPP compliance, an inspector will ensure all necessary measures are in place. In virtually all cases, stormwater controls must be implemented (not just planned) according to the SWPPP to pass the SWPPP inspection.
An approved plan that addresses stormwater controls includes doing the following:
- Covering exposed soils to prevent erosion
- Removing all pollutants from work areas before they enter the waters of the United States
- Plans should ensure construction vehicles don’t cross waterways, if possible. Vehicles that cross waterways must be treated before leaving the site to prevent the spread of pollutants.
- An outline of sediment control measures prevents stormwater from carrying soils or pollutants into nearby water bodies. Sites can install a sediment fence or vegetation cover to absorb rainfall and prevent runoff from leaving the construction area.
What if there is a stormwater violation at the construction site?
Any stormwater controls that are not installed or maintained according to the SWPPP could lead to a stormwater violation. In addition, both state and (federal) EPA inspectors may conduct separate inspections of construction sites, and both can issue violations.
Navigating Your SWPPP Application Process
Having a plan to reduce your pollution is good for a lot of reasons, but it’s essential if you’re looking to break ground on a new construction project. Hopefully, this guide has helped you understand a bit more about what you need to have in order for your SWPPP.
Large-scale projects often have a huge impact on water quality, which can either be a blessing or a blight to the local community. This is one of the many reasons that states, counties, and municipalities offer large-scale grants, rebates, and incentives to help implement green infrastructure for these types of projects.
If you are located in the DMV area (Maryland, Northern Virginia, or Washington DC) we can offer comprehensive support for your project. We’ve rolled out early access to concierge services like contractor-matching services and incentive program application assistance. Please go to myrainplan.com and enter your property address to get started. You can also schedule a chat with a Rainplanner to start putting together a more comprehensive plan.
If you are not in the DMV area, don’t despair! We can still help you find the best incentives for green infrastructure and guide you on the next steps, even though we haven’t completely finished our vetting process for local RainPros. Create your Free Account and set up a chat with your local Rainplanner.