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Implementing Technology for “Effective” Environmental Compliance
- 1. Observations on Implementing Technology for “Effective” Stormwater Compliance Jesse Poore, CFM Felsburg Holt & Ullevig Colorado Stormwater Council Denver, Colorado August 10, 2011
- 5. 2007 29 MS4 projects - 485 filed inspection records 16.7 per project 0 Enforcements 2010 25 MS4 projects - 450 filed inspection records 18 per project 0 Enforcements
- 8. http://workawesome.com/ NPDES Inspections Reports Database Effectiveness
- 18. What’s the Problem? What’s the Corrective Action? Is it Immediate?
- 35. Parting Words of MS4 Advice
Editor's Notes
- We have all the best design guides and pocket guides in the field, but not the consistent oversight to ensure they are being followed! MS4s have to do education. What makes your audience pay more attention? Corrective Actions must be completed within 7-days of the finding. Or, Acme Construction company made Corrective Actions within 7-days 92% of the time which was 25% better year to year and here is how we did it! EPA doesn’t shake their stick at the low-hanging fruit! They don’t have time to mess with that. They want to make a splash and they make damn sure they have the documentation to support their findings and Notice of Violation. We wouldn’t be facing numeric effluent limits for construction stormwater runoff and possible new regulations for new development and redevelopment if they weren’t.
- Most days, this is my working universe. Only recently have I started to venture outside of the Cornhusker state.
- I’ve learned that every MS4 operates differently, even among the traditional MS4s. NDOR is no exception. Here is a snapshot of who has Construction stormwater oversight for NDOR. District Engineer Construction Engineer Project Manager Third Party Inspectors
- Only had to look across the state line to CDOT which had just received a consent order to improve recordkeeping and construction program oversight.
- This graphic from workawesome.com is a great illustration of the current state of affairs of many compliance oversight programs. A regulation without a framework for field implementation and enforcement is not actionable Performance measures that do not support effectiveness measures and benchmarks will get lost in data likely cause regulatory scrutiny and wasted internal resources.
- We need better glasses to see the information that is in front of us or that we need to be collecting through an existing process that we already conduct.
- The Target Audience is always the first priority to consider. Who are we trying to educate? Who are we trying to get to listen and what do we need them to do to respond? How can we collect data that will feed that Target Audience what they need to hear, learn and implement? Contractor – in 2009, 35 inspections in Parker, Colorado projects identified stockpiles to close to a waterway. Corrective actions in 2010 will include… Project Manager – Inspection records were not up to date in 25% of the projects inspected in 2011. This is an immediate fine $200 according to local ordinance. Public Works Director – The new education effort implemented in 2009-2010 reduced BMP maintenance-related findings by 40% in Colorado Springs. Regulator – 480 contractor inspections were completed, 115 municipal inspections were completed, corrective actions were achieved within 7 days 89% of the time which is 4% above Commerce City’s target for the reporting year. Then you get to work and start building a system around those Target Audience needs. If it isn’t relevant and actionable, don’t track it.
- Development of a method for syncing machines as opposed to working in a live web-space has accounted for at least 65% of the total project cost. NDOR was not willing to go that way do to internet access restrictions in the field.
- Inspections are listed on the log in screen and are specific to the user logged in at the time. At Headquarters, access to Districts and individual projects are assigned. Leveraged another program within NDOR (SiteManager) to ensure Project Manager is up to date through frequent syncing. You can see Inspections on the left and CAL or Corrective Action Log on the right as well as Comprehensive CAL link at the top for all projects displayed in my project list. Yellow indicates that something is pending completion (inspection or CA)
- Historical inspections can be viewed in one location.
- Inspection Start Screen
- After setting project inspection, inspector answers pre-set checklist questions (Y/N/NA).
- Inspector uses Field BMPs section to enter any findings related to the condition of implementing BMPs on the ground. This is where a major level of sophistication occurs. This interface is dynamic and provides a wealth of compliance assistance and consistency for inspectors in the field.
- Selecting a BMP Category populates the BMP types adjacent Selecting a BMP Type populates the informational Notes about that BMP Inspectors list standard items about the condition of the BMP in a sequence the defines each step. Location Problem BMP Non-compliance Action Items
- Add some summary information boxes and violas! You have a standardized inspection form.
- The sky is the limit