Thinking Outside Linear Compliance – Permit Efficiency through Multi-Discipline-icity
Once upon a time in a California long, long ago, stormwater regulations represented targeted, prescriptive requirements that could be “dealt with” using templated, paper-based inspection forms and reports, minimum best management practices (BMPs), and the expertise of a compliance generalist. In 2018, many agencies implement multiple stormwater permits at the same time. Regulatory requirements have become more complex, but resources available for program implementation remain static (limited). As a result, the regulated stormwater community is seeking opportunities to be proactively efficient and effective.
Leveraging resources across environmental Programs requires taking a step back from Permits and box checking regulatory requirements. The concept of integrated water resource management (IWRM) is being embraced by regulators and regulated communities as the stormwater panacea. The audience’s baseline understanding of IWRM concepts and tools will polled at the start of the presentation. This will be followed by a brief overview of planning and implementation tools originally conceptualized in Convention on the Law of Non-Navigational Uses of International Watercourses, an international treaty adopted by the United Nations that provides the framework for IWRM of surface and groundwaters that cross international boundaries. These IWRM tools will be compared to elements of the CASQA vision and strategy that have been developed based on regional boots-on-the-ground experience. From this framework, the presenter will explore how regions in California have been succeeding and struggling to translate the IWRM -CASQA tool box to stormwater programs. Throughout the presentation, the audience will be polled on use of (and appetite for) these tools, such as internet based data tools and stakeholder engagement. Finally, three cross-permit case studies will be used to illustrate “new” resource leveraging opportunities. Case studies will include:
• Industrial Permit versus SPCC requirements – overlaps and challenges,
• Trash Amendments versus Landfill diversion goals – leveraging “Zero Waste” Management goals and other sustainable waste management practices, and
• Post-construction hydromodification minimization versus water quality – opportunities to retro-fit constructed flow control BMPs to address new pollutant load reduction requirements.
Through these case studies, the presenter will discuss strategies and challenges related to stakeholder engagement, goal setting, monitoring program design and data collection/sharing tools. The goal of this presentation is to encourage environmental multi-disciplinary approaches and help managers become more adept at identifying the nexuses between the drops that make up the sea of regulatory compliance.