I think we can all agree to that goal. However, how we get there is a where environmental groups, companies, and regulators usually diverge. Setting aside the argument of whether we need stricter or looser environmental regulations, let’s focus on the regulations we currently have. Are we doing everything possible to make it easy for companies to comply with the existing environmental regulations and permits?
Open Data External Stakeholder Panel
Last month, I participated in the California State Water Resources Control Board (SWRCB) open data discussion. They asked me to provide a perspective as an external stakeholder on the SWRCB’s existing datasets the SWRCB. The panel covered two areas 1) how do we currently use SWRCB data and 2) where would we like to see SWRCB technology and data go. As you can hear in the recording from the panel (open data panel discussion), I am concerned that technology is working against facilities and not for them.
With the new California industrial stormwater permit (IGP), I have heard countless stories of facility managers, owners, and environmental managers spend hours battling the SWRCB’s online system (SMARTS). In addition, other companies did not file their stormwater permit documents because they got too fed up or their applications were marked as incomplete because they did not pay. Easy, fast online checkout has been around for many, many years. It is a financial and environmental problem if companies are not complying with the environmental regulations here in California.
Sadly, this is a problem across the United States. Our government enacts environmental regulations, including stormwater permits, with the intention of protecting the environment and ensuring clean water. However, the regulations are often very convoluted, especially for small businesses, and road blocks are created to compliance.
Fixing the California Industrial Stormwater Permit
So what is to be done about? We cannot solve all problems with specific government agencies and environmental regulations in this post. However, let’s take the California industrial stormwater permit as our example.
Give companies examples of what you, as a regulator, would like. For example, many states publish on their websites template Stormwater Pollution Prevention Plans (SWPPPs) for various industry sectors (e.g. metal recycling). The same is true for Best Management Practices (BMPs). A fact sheet based on the major industries would help out everyone. Not ten page long description of one BMP, such as drain inlet protection. Rather, a simple one page long factsheet with a description, how it works, pollutants the stormwater BMP removes, and basic inspection/maintenance requirements. Bonus features would be the costs and where to find them.
The template SWPPP is even more important for the small businesses, such as wineries, that are struggling under the IGP. A winery with a few hundred cases of wine a year doesn’t have the budget to hire a consultant or have an internal environmental manager. Empathy and clear explanation of what they need to do would go a long way towards compliance with environmental regulations.
2. Clean User Experience
Make SMARTS (or any reporting system) have a simple, clean user interface that walks a company step by step through the reporting or application process. Give users clear questions or buttons to click on such as “Submit Sample Results”.
3. Easy Payment
We can all shop online. Make the checkout like Amazon. There is no reason the permit fee cannot be collected today. Last time I checked the State of California did not want to spend extra on trying to collect money or losing money, because companies don’t pay. At a minimum, online checkout greatly improves the State of California’s operating cash flow.
4. Answer Questions
The stormwater helpdesk is often overwhelmed. I get it, budgets are tight. However, most companies are asking the same questions as other companies. At a minimum, why not post the common email and phone questions and staff responses. A more robust FAQ could be developed at some point, even with intern help. However, long delays in response (or not at all) makes it even harder for the thousands of large and small businesses to follow the regulations.
5. Direct Integration
Allow integrations of third-parties (like Mapistry) into the system, so sampling data can be sent automatically. If you fill out your taxes with TurboTax, at the end you can click submit and your taxes are sent automatically to the state and federal IRS. This info is far more important than sampling data (which becomes publicly available as soon as a facility submits it) and can be done securely.
6. Improve Your Own Employees’ Efficiency
Enable the RWQCB staff to directly integrate into SMARTS. When an inspector goes to a company/facility and conducts an inspection, they should be completing the inspection form on their phone or tablet. When done, a push of the button sends it to SMARTS and emails a copy to the company. Transparency, communication, and ease of access….yes!