Phasing of Plans Yields Better Compliance.

Looking Back

Back in the stone age, when our experience with stormwater regulations in Colorado began in the mid 1990s, most Stormwater Management Plans (SWMPs) had single map included to show the location of specific items. This helped a lot with getting the initial perimeter controls installed, but left some gaps.

In 2019, it is common to have at least two BMP plans (Best Management Plans) in most SWMPs. One for construction phase BMPs, and one for final stabilization plans. Certainly, this is an improvement. At a minimum it avoids layering final stabilization measures like seeding or landscaping over the construction phase maps, so project owners and all their subs have more clarity about the location and timing of important BMPs.

Phasing creates clarity.

Not all construction projects have exactly the same challenges, but this example of how phasing can create clarity will demonstrate how having phased BMP plans in your SWMP can benefit the owner and project manager. Imagine a site of approximately 10 acres on which the following activities were required to complete the project.

• Clearing and grubbing, with a setback from a wetland area
• Mass grading, which results in new drainage patterns and brings the site near to final grade
• Construction of a major retaining wall along one property line to expand buildable area
• Going vertical on a retail structure, with multiple trades using potential pollutants
• Curb and gutter, with paving of internal roads and parking lots,
• Installation of landscaping and irrigation on part of the project

Implementing stabilization measures on areas with native seeding Each of these major activities may have specific BMPs associated with them. For example, perimeters controls would be installed prior to clearing and grubbing, but may be changed or amended when the large retaining wall is built. And clearly the curb/gutter and paving activities will be followed by the need to add inlet protection devices, and possibly some back-of-curb erosion control once the grade behind the new curb is at fine grade.

We certainly don’t think you need seven maps to reflect the seven major activities named in this example, but this level of complexity may be best served by at least having an Initial, Interim, and Final phase plan. The benefits of this level of clarity include more precise bidding and reduced maintenance due to BMPs not being installed too early or remaining in place too long. In addition, the availability of phased BMP maps allows regulators who visit a more clear picture of what is needed at the particular phase of construction during which they visit, so they can focus on only what is needed at that time. In short, a clear plan avoids confusion and misdirected effort.

Phased plans yield better compliance

Clarity around the BMP plans will translate into higher levels of compliance as well, as fewer field items will be missed when the plan is clear, and removing BMPs that are no longer needed will avoid findings on irrelevant BMPs. But the big compliance win associated with phased plans is on the documentation side of the equation.

A properly managed BMP plan will have items highlighted, or at least dated and initialed, when installation occurs, when BMPs are removed, and when BMPs are changed to adapt to changing site conditions. Even when done carefully, this practice can create visual clutter on the map. Transitioning to the next map in the phased approach creates a fresh start since only actively used BMPs will be carried over to the new map. The fresh new map serves as clear visual documentation to the owner’s representative, the stormwater inspector, the BMP contractor, and any regulators who pay a visit. This clear visual depiction serves to focus efforts on the items needing attention currently, resulting in higher levels of compliance.

Clear Plans = Clear Winner

In Summit’s experience, clear plans are clear winners. When you choose Summit to prepare your SWMP plan, including the BMP maps, we will ensure that you get more than the bare minimum required by your permit. You’ll get plans that help drive your compliance program, and you’ll get the clarity needed to keep everyone on the same page with you. If you want to explore how Summit’s plans can help you, please call us to start a discussion.

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