Understand when you can create your own SWPPP, and when you should let the environmental experts handle it.
Virtually every NPDES stormwater permit in the United States, whether issued by a delegated state or the USEPA, requires a SWPPP be created and implemented. The thing about stormwater permits is, they can be complicated depending on your state and the industry you're in. Some are simple, while some are overly complicated with confusing language, so it's only natural that many, many organizations out there struggle with various environmental permits and approvals.
Fortunately, we do an awful lot of stormwater work all over the U.S., and understand most permits pretty well. We get asked a lot of questions by folks from all sorts of industries many different questions about stormwater permits.
- What's a stormwater permit?
- What's a stormwater pollution prevention plan?
- What are the best stormwater BMPs?
There's one question that sticks out though with regards to stormwater plans, which is...
"Can I write my own SWPPP? Can I develop my own stormwater plan? Do I need to hire an expert?"
Great questions. It's vital to make the correct, informed decision since it can mean the difference between a good, easy to use and understand plan that adheres to the regulations, or a confusing, incomplete plan that doesn't adequately address stormwater regulations. We've seen folks make their own plans and they came out amazing! Conversely, we've seen plans other consultants have created that are pieces of junk.
Can I create my own stormwater plan?
Let's answer this right here. The answer is… YES! You can. You do not need to hire a consultant to create a SWPPP. You can save the money and do it yourself. Just like you can fix your car's transmission instead of taking it to a mechanic!
Wait a second. Can you fix your own transmission? I know I can't.
And that's the point I want to illustrate. While creating your own Stormwater Pollution Prevention Plan is well within some folks capabilities, others have no business tinkering around with them at all. They can be complicated, and to folks who don't completely understand them and what's at stake, much like how your car's transmission works, you can end up making errors and paying for them later.
So let's look at the pros and cons about diving into your stormwater permit and developing your own plan before you decide to head out on your own and get started.
The Pros of Developing Your Own SWPPP
- There's a lot of help available. And, a lot of that help is usually free! You can find templates, instructions, guidebooks, and a lot more from your regulatory agency. For example, most delegated states will give you the "recipe" that they expect you to follow to prepare your own plan. Follow these steps and you're all set, right?
- It's not that hard. Folks this isn't rocket science. Where does rainfall on your site flow? What materials are exposed to rainfall and possibly pollute runoff? Can you come up with some easy strategies to reduce or eliminate that polluted runoff? Your runoff is not expected to be Aquafina quality, so it's not too hard to meet your limits or benchmarks, right?
- No one knows your facility better than you. If you hire an expert, they'll need to inspect your operation, and learn about what you do to write your Stormwater Pollution Prevention Plan. Chances are you already have a pretty good handle on your own facility and operation.
- It's a technical manual, not Shakespeare. No one is expecting a highly graphical work of art here. This is a technical document, and one that's not even that overly technical! You're not writing the landing procedures for the next rocket to Mars. If you follow the requirements, do your best job, write it plainly and clearly so both you and regulators understand it, you've probably done a good enough job.
- It's for you, not regulators. Remember it's meant for you to use, you're the audience, no one else. You have to understand and use this document on a regular basis, not regulators. In most cases you won't have to turn the SWPPP in to anyone for review or approval. No one's going to judge your work - until you get inspected. But as long as it gets across what the regulations say it has to, you'll be fine.
- You can save money. I'm sure you'd like to show your boss you've saved the company some money. Or maybe you're the boss and you're trying to be fiscally responsible. Either way, doing your own work can, but doesn't always save you money.
Ready to get started? Not so fast… Let's look at...
The Cons of Creating Your Own Stormwater Plan
- There's a lot of help available. That's a good thing, right? Not necessarily. How easy is it to read the tax code and then do your own taxes? Don't you hire an accountant? Just because regulatory agencies tell you how to create one doesn't necessarily mean the instructions will be clear, understandable, or even up to date. We've seen guidance documents that make zero sense, and we're experts on this stuff! Most permits have fairly complicated aspects that you probably won't be able to handle on your own. Unless you're an expert in things like pollutant removal techniques and strategies, outfall management, conducting detailed site inspections, thoroughly evaluating all source materials and their pollutants, discharges to impaired waterbodies, stormwater training topics, etc., as well as the law regarding all of these issues, you are probably in way over your head. And I'm not even going to mention permits that require site plans or drainage controls maps developed by a professional engineer…
- It can be hard. You know where stormwater flows, but do you know the optimal location to designate as a stormwater outfall location in order to get the best stormwater sample possible? Probably not. Do you know best practices that are cost effective and easy to implement to help you get better samples? Power to you if you do! From our experience, folks who create their own plan often overlook painstakingly simple stormwater BMPs and end up spending money unnecessarily.
- It's a technical manual. Meaning you have to create a document that adheres to regulations. You can't just make things up, or call things whatever you want. Your document has to comply with the regulations or it's useless.
- It's for you, but inspected by regulators. They're going to grill that document. They'll read it front to cover, with a keen eye for inadequacies in the document. If it's not addressing the regulations correctly, expect a warning at the very least, but more often than not you'll be getting a violation (usually meaning monetary fine). You have to get the information across correctly.
- You can waste money. Time is money, and your time is valuable. Wasting your valuable time creating this document is going to cost you, even if you're not thinking in dollars and cents. You'll have to research, write, and spend time working on this document, and chances are, you've got better things to do. And, you'll have to implement stormwater BMPs you've outlined in your document. If the document isn't good enough, or your BMPs don't work, regulators will force you to get a new plan, or they'll force you to develop stormwater BMPs that work. Experts can do it quicker, and more cost effectively. For most folks it's simply not cost effective to develop a plan on their own.
- You have legal responsibilities to do this right. Don't risk botching this. Your permit coverage depends on you having a plan that makes sense, adheres to the regulations, and works! Making mistakes or overlooking some part of your plan can (and we've seen it) result in serious penalties. It's not worth it. These are federal laws concerning the water quality all over the United States which are enforceable by environmental agencies and 3rd parties. Don't risk screwing it up.
- They don't cost as much as you think. We're not talking tens of thousands of dollars here. A plan created by an expert will most likely save you money in the long run. You won't have to deal with violations, penalties, or fines, as long as you're sticking to your plan correctly. Chances are you'll come out ahead if you stick with using an expert to develop a plan instead of trying it on your own. We charge anywhere from $1,250 to upwards of $6,000 for plans, depending on a lot of variables.
Ready to create your own stormwater plan?
We've been doing this for 20+ years, and you can obviously tell I'm a bit biased about which direction you should go in. I'm not saying only hire us because we're experts, I'm simply stating hiring an expert, for most people, is a better idea. I strongly feel the cons outweigh the pros, but again, it's entirely up to you.
I'll also say this - most folks we help with stormwater work tend to hire us after they've received a violation, penalty, or fine from regulators because their plan was insufficient. We see a lot of plans slapped together by an expert for a cheap price, or plans created by staff members, and they're usually far from good enough. Again, why waste time doing it yourself or hiring the low bidder (but that's another rant for another day) when you can get someone competent to do it once and be done with it.
Again, I'm not saying we're your only choice. Just make sure you evaluate your options before you hire an expert. From our experience, facilities that are in compliance, free from fines and penalties, and have a plan that's easy to understand and meets regulatory requirements almost always have hired an expert.
But, it's entirely up to you. You can develop your own plan. You can have an intern create a Stormwater Pollution Prevention Plan if you really trust them (I definitely don’t advise this). Point is, you don't normally need to have any credentials to tackle this regulatory requirement (unless you need a professional engineer at some point in the process).
Our recommendation is to hire a stormwater expert to prepare your plan for you. Just bite the bullet and spend the money to get yourself into compliance. It will be well worth it in the long run.