With the 2016 - 2017 reporting year drawing to a close on June 30th, California industrial facilities were eagerly waiting to see how their stormwater sampling results would shake out in terms of Baseline, Exceedance Resonse Action (ERA) Level 1 or ERA Level 2. Here at Mapistry, stormwater compliance is not a one time thing (cough, cough consultants who prepare a SWPPP, only to leave their clients high and dry with a giant binder). As part of our active stormwater compliance platform, we are engaged through out the reporting year with companies, especially as they work to bring their sample results down. So how did we do?
Last year, about 25% of California companies under the Industrial General Permit (IGP) went into ERA Level 1 from Baseline (approximately 2,200 facilities out of 8,800 permitted facilities under the IGP in California). In our July 11th webinar with California Water Board staff, they reported about 900 of those 2,200 facilities moved into ERA Level 2. That means across California approximately 41% of facilities in Level 1 kept going and not meeting the Numeric Action Levels (NALs), which pushed them into ERA Level 2. For the 2017 - 2018 reporting year, approximately 10% of facilities under the California IGP will be in ERA Level 2.
In the interest of transparency and to keep ourselves accountable, I ran the numbers on the facilities for which we did ERA Level 1 evaluations and reports for at the beginning of the reporting year (aka Qualified Industrial Stormwater Practitioner [QISP] services). In these Level 1 reports and evaluations, we dealt with pollutants of concern from copper and zinc, plus other metals, to Chemical Oxygen Demand (COD) and Total Suspended Solids (TSS). Our customers operate businesses from wineries to trucking companies to landfills to scrap metal recyclers. This means we saw it all for pollutants and sources. In some cases, we were conducting ERA Level 1 evaluations and reports after they had collected samples during the 2016-2017 reporting, because they did not realize they were in Level 1. This put us at somewhat of a disadvantage in terms of changing or updating Best Management Practices (BMPs). Okay, enough excuses....how did we do?
Out of all our ERA Level 1 evaluations, only 27% of the facilities went into Level 2, the next (and highest) tier up in the stormwater exceedance world (Tiers are Baseline, Level 1, and Level 2). In this situation, we were well below the industry average (41%). For the facilities, who also used our stormwater compliance software, which promotes active stormwater compliance, 83% of Mapistry customers in Level 1 stayed out of Level 2. In addition, as a qualifier, the facilities that did go into Level 2 are on large dirt lots and their pollutant of concern was TSS. These situations were challenging, because it is extremely difficult to control TSS in stormwater discharges coming from large open, unpaved sites with few structural, advanced BMPs. I consider our record in 2016-2017 a big succes, even though I am very frustrated that we could not keep everyone out of ERA Level 2. For those who did not use our software, 35% went into Level 2. This year proved a few things for us:
Well, what does this mean for the 2017-2018 reporting year in California? We still have a ton of work to do. There are too many companies in ERA Level 2 that are our customers. In addition, we have doubled the number of companies working with us in the past year and almost all of them are working with Mapistry, because they are in ERA Level 1 or Level 2. So, how are we going to tackle the new reporting year:
Of the Level 1 evaluations Mapistry did, 83% stayed out of Level 2.
Only 19% of our customers had exceedances in 2016 - 2017. Our goal is 0% in 2017 - 2018.
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