Annual Report Certification - Did You Read It Before You Certified It?

It’s that time of year again, your Annual Report for the Construction General Storm Water Discharge Permit (CGP) is due on September 1. Hopefully this deadline didn’t sneak up on you. As the Legally Responsible Person (LRP), you are responsible for the validity of the information contained in that Annual Report. Typically, the project Qualified SWPPP Practitioner (QSP) will answer the questions in Storm Water Multiple Application Report Tracking System (SMARTS) and send you, the LRP or the Approved Signatory (AS), an email notification to log-in and certify the Annual Report. When that Annual Report is certified, the LRP/AS is doing so under the penalty of perjury that the information contained therein is accurate and reflective of the project for the previous reporting year (July 1 through June 30). Did you review that Report? ​

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Here are a few items that are important for the LRP/AS to know about what is in the Annual Report:

1. Do you have a Qualified SWPPP Practitioner (QSP) overseeing the project? Can you name them?
2. Were all inspections (weekly, quarterly, pre-storm, during storm and post storm) performed? If they were not performed (was a qualified storm pre or post storm inspection missed), is the explanation provided?
3. Were deficiencies with the implementation of the Best Management Practices actually reported? (Every project has BMP deficiencies, not fixing them is the bad part, reporting the fix is the right part).
4. If a Risk Level 2 or 3 project, were all qualified storm events sampled and the data uploaded as an Ad Hoc Report?
5. If the project’s identified QSP did not perform all of the required inspections, are the training records for the individuals that performed the other inspections located in the field Storm Water Pollution Prevention Plan (SWPPP)?

These preceding questions are easy compliance issues that a regulator or third party group can use against you if they are not reported accurately. Each of those questions are associated with Permit required documentation that, if not produced to verify the answer on the Annual Report, can lead to a Notice of Non-Compliance, a Notice of Violation, or worse, a third-party Notice of Intent to Sue.

Don’t let storm water compliance drive up costs on your project with fines or project shut downs. Hiring a firm that is project and client focused with an expertise in these regulations will save time and money in the long run. If you like to roll the dice, hire your foreman’s sister-in-law’s nephew who took a class in college about environmental policy to manage your project.

​If you want to ensure your project is executed efficiently, economically and most importantly free of regulatory interference, hire the experts at Alta Environmental to manage your Storm Water Compliance needs. Contact Matthew Renaud at (562) 495-5777 or email matthew.renaud@altaenviron.com to request a project review today!