Using IGP Enforcement Trends to Steer Clear of Violations
Through the accessibility of the Stormwater Multiple Application and Report Tracking System (SMARTS), California is leading the nation in the transparency of stormwater data submitted by regulated businesses and other entities. This, of course, is a double-edged sword: it can make enforcement much easier for regulators. In addition, it is well known that this data is used by citizen groups to file lawsuits against dischargers. However, when used in the right manner, SMARTS can be a great tool to access valuable compliance information. This technical presentation will use data obtained using SMARTS to provide an update of key enforcement trends in CA. The number of enforcement actions, along with the types of violations most commonly enforced, will be presented along with information on the frequency and amount of monetary penalties. It will also be discussed how enforcement trends may be expected to change given the new IGP amendment and the introduction of numeric effluent limits (NELs). Issues such as these will be broadened to compare enforcement efforts by the state and regional boards to the efforts and impact of citizen suits and their associated settlement costs. The most common violations and compliance issues statewide will be identified using charts, tables, and other visuals to clearly communicate information. A select small number of violations or categories of violations will be chosen for further analysis; for each violation type, one or more compliance tools will be introduced that will help avoid the violation. ALG will draw from its experience in managing a range of environmental programs to provide tips on effective procedures that can be established within a company structure. Importantly, the tools presented will be widely available and easy to implement. The presentation will conclude by looking forward, using the data presented to provide insight and vision to suggest effective compliance strategies and other actions.
Elliott has worked on a range of environmental issues in his career at Ashworth Leininger Group. He has a Masters in Civil and Environmental Engineering from Cal Poly, San Luis Obispo. At ALG, he has worked extensively with a wide range of individual and general NPDES permits, and has been focusing on in-depth pollutant source investigations to mitigate pollutants at their source. Elliott is a QISP and has been working hard to get facilities back on track to meet the requirements of the IGP amendment.