You have a Stormwater Pollution Prevention Plan (SWPPP) and an authorization to start construction. That’s great! But what if the provided SWPPP is insufficient to help you successfully execute stormwater management at your construction site?

The SWPPP serves as a road map outlining how the stormwater management aspects of a project will comply with the Construction General Permit (CGP), whether for the U.S. Environmental Protection Agency or the state. An inadequately prepared SWPPP could be missing information, contain references to other projects or requirements from other permits, or include an inadequate erosion and sediment control plan.

Getting a deficient SWPPP into functional shape may take more than a few simple redlines. This six-step process will help turn an unusable SWPPP into a workable one with input from all interested parties, moving your project forward and into compliance.

Step 1: Understand the conditions of the CGP, then identify where the SWPPP is deficient or has weak areas such as those mentioned above.

Step 2: Conduct a training session for management, permittee(s), site operators and the craft. This session should provide an overview of the CGP and SWPPP. Compliance depends on a shared understanding of the requirements and responsibilities.

Step 3: Identify priorities. Each project is different, so it is important to evaluate the largest weaknesses of the SWPPP and identify the order in which the following steps will most benefit your project.

Step 4: Redline the SWPPP and any corresponding erosion and sediment control plan to reflect existing site conditions.

Step 5: File any amendments or paperwork as needed, in accordance with the CGP.

Step 6: Work as a team with project participants to improve and implement the SWPPP, and create a culture of compliance.

You want your project to start on the right foot and meet all obligations with efficiency and effectiveness. If you inherit a poorly prepared SWPPP, this process will help you systematically turn it into a workable plan that gathers valuable information, moves the project forward and achieves compliance.


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Lauren Gates is an assistant environmental scientist who specializes in National Pollutant Discharge Elimination System (NPDES) permitting, focusing on the development of SWPPPs, construction and local permits, and environmental compliance during construction.