Annual Reporting for the California NPDES Permit for Construction Activities
It’s that time of year again. If you have an active California NPDES (National Pollutant Elimination System) Permit for Construction Activities you, or your project owner’s representative, will likely be receiving that friendly reminder email from the State Water Resources Control Board (SWRCB) letting you know that September 1st deadline is just around the corner. If this is your first annual report, I’ve provided some information here to make the process a little less painful.
The permit requires that all construction projects submit a summary of the activities covered to the state for the reporting year. The reporting year is July 1st to June 30th of every year. Reports for construction projects are due to the state by September 1st. The report needs to be submitted to the California SWRCB on the SMARTS (Stormwater Multiple Application and Reporting Tracking System) database, so make sure you allow time to coordinate with the Data Entry users and/or the LRP (Legally Responsible Party) for preparation and submittal. If your project happens to have the low erosivity waiver, then you don’t need to worry about filing an annual report, but it’s a good idea to use this time to reevaluate the waiver for any needed changes in coverage. As a side note, an Annual Report will also likely be due at the same time as filing the Notice of Termination, so don’t be surprised if you need another right after filing in September.
If you have a storm water management company performing inspections and maintaining your permit, then chances are most of the work is already done and you should just need to coordinate with the LRP to make sure it is certified on time. If not, you will have more to do. It’s easiest to have the QSP (Qualified SWPPP Practitioner) or the inspector delegated by the QSP to prepare or assist in preparing the report as they would have more familiarity with the site compliance throughout the reporting year. Alternatively, a review off all the inspections will need to be completed to summarize corrective actions, sampling and analysis and any possible discharges among other information.
If your Annual Report has not been submitted, it may leave your project at risk for enforcement action and more attention by the local Regional Water Quality Control Board. An important consideration to keep in mind when you get that email from the SWRCB or the project owner notifying you that there is an Annual Report due for your project.
If you have any questions or would like more information regarding Annual Reporting for Construction Sites in California, please feel free to email me at email@example.com.