INDOT Storm Water Management Field Guide Interest

INDOT has provided hard copies of its Storm Water Management Field Guides to INDOT Storm Water Management training course participants in the past. In 2018 INDOT will allow ICI to provide hard copies for general sale at a cost of $10-12 each (final price TBD). To assist in estimating the number of books to publish, we would appreciate your input about your company’s interest in the book. Please complete the form, and we’ll get back to you when the books are available for sale. Contact Dan Osborn with questions.

Storm Water Management Training Update

There is a new INDOT Construction Storm Water Management Training scheduled for March 30 from 9:00 a.m. to 2:30 p.m. at the Traffic Management Center, 8620 East 21st Street in Indianapolis. The cost is $140. Sign up today on the INDOT University webpage.

INDOT Construction Storm Water Management Training is a required training as per RSP 205-R-636 for Level I and Level II Storm Water Quality Managers. An additional certification is required for Level II contracts, please review RSP 205-R-636 for details. This Storm Water Management Training class covers the basics of implementing and maintaining a storm water management plan on INDOT road and bridge projects. Upon passing the exam, the training will remain active for an additional three years.

Individuals who took this training in 2014 are up for renewal this year. In a week or so each person who attended a 2014 class will receive an email with a link to start the renewal process. The renewal training will be all online.

Spring CISEC and CESSWI Certification Courses

The CISEC and CESSWI erosion & sediment control certifications are scheduled to take place in Indianapolis and Ft. Wayne this spring. Either of the two certifications are a requirement of INDOT’s Recurring Special Provision (RSP 205-R-636) Storm Water Quality Management Level II Storm Water Quality Manager.

The CISEC training modules and certification examination are scheduled on April 12 & 13 at Richard A. Carlucci Recreation and Aquatic Center, 651 Vestal Road, Plainfield, Indiana 46168.

The CESSWI certification examination review courses are scheduled in Indianapolis and Ft. Wayne, March 17 and March 31 respectively. Locations have not been determined as of January 10. Please contact Melissa Parry, Envirocert Internation, Inc., to get additional information. CESSWI certification examinations are offered at PSI Testing centers.

StormCon Set for August 22-25

EnviroCert International, Inc. (ECI) invites you to The 15th Annual StormCon Conference and Exposition at the Indiana Convention Center August 22-25 in Indianapolis.

StormCon is designed to provide you with opportunities to increase your knowledge and advance your career in the stormwater management industry.

ECI review courses will be offered August 20 and exams will be offered August 21 for the following certifications:

Certified Professional in Erosion and Sediment Control® (CPESC)
Certified Professional in Storm Water Quality® (CPSWQ)
Certified Erosion, Sediment and Storm Water Inspector™ (CESSWI)
Certified Professional in Municipal Stormwater Management ™ (CPMSM)
Certified Inspector of Sediment and Erosion Control (CISEC)

For questions regarding review course registration, please email Melissa Parry or call 828-655-1600 ext. 133.

The last date to sign up for the review courses and exams is Wednesday, August 10. The CISEC and CESSWI courses are accepted by INDOT under the Recurring Special Revision 205-R-236, Storm Water Management, effective for contracts awarded after August 31, 2016.

INDOT Storm Water Management Training

ICI members can attend INDOT’s next storm water management training session:

When: August 17 from 9:00 a.m. to 1:00 p.m.
Where: INDOT Indy Sub District Office, 7105 Brookville Road, Indianapolis
Cost: $140

Space is limited. Please email Michele Meyer to enroll and pay for the course. Only those who RSVP through Michele Meyer will be permitted to attend.

ICI and ACEC comment on EPA’s Draft 2017 General Permit

EPA is preparing to reissue the Construction General Permit. The general permit, issued under the Clean Water Act’s National Pollutant Discharge Elimination System, authorizes stormwater discharges from construction activities. Learn more about it from the EPA or AGC of America.

ICI partnered with ACEC Indiana to submit the following comments on behalf of the industry:

Comments regarding U.S. EPA’s Draft 2017 General Permit
Offered by:  Indiana Constructors, Inc. and American Council of Engineering Companies of Indiana
Date:  May 10, 2016

Public Accessibility (Online) of Storm Water Pollution Prevention Plan (SWPPP) Information
SWPPPs are fluid documents that are modified to accommodate changed conditions, utilities and multi-phase construction. Public access to the initial SWPPP will create issues for taxpayers, owners, designers, and contractors due to costly delays and production interference as owners/operators, designers and contractors will be forced to respond to unsolicited public oversite and scrutiny based off of initial SWPPP documents that do not reflect the current work site conditions.

Public Notice of Permit Coverage
EPA proposes a new requirement that the permittee’s sign/posting (or other public notice) of permit coverage must also include information informing the public on how to contact EPA if storm water pollution is observed in the discharge. There were 1,725 permits open during 2015 in Indiana. We recommend that the EPA remove this proposed requirement due to the potential inquiry backlog that could be generated from posting EPA’s contact information at every permitted site.

More Frequent Site Inspections
We request that EPA provide evidence that substantiates the lower inspection trigger threshold as observations in Indiana do not warrant such a significant increase in inspection frequency. Decreasing the inspection trigger threshold from .5 to .25 inches is a very significant change. For example, in review of two Indiana locations (Plainfield and Ft. Wayne) and their respective daily rainfall measurements between March 15, 2015 and November 15, 2015, the number of rainfall events over .5 inches were 28 (Plainfield) and 17 (Ft. Wayne). The rainfall events over .25 inches were 48 and 36, respectively. If the State of Indiana adopts the .25 inch threshold, contractors would be required to increase inspections by around 90%, using the example locations. To put this in terms of dollars, the cost to project owners and taxpayers, will be in the millions of dollars per year in Indiana.

Numeric Reporting Requirements vs. BMPs
It is critically important to industry that, in the final regulatory text, EPA clearly state that numeric permit requirements are not mandatory. Industry is concerned about proposed modifications to the current regulations at 40 C.F.R. § 122.34 that would delete the word “narrative” as it relates to effluent limitations, and also delete the additional explanatory text that “BMPs are generally the most appropriate form of effluent limits.” Again, we oppose these changes, which directly contradict CWA intent, fall outside the scope of the court’s remand and are improper actions for this rule-making. We request that EPA retain the above-referenced language in the final rule to make clear that effluent limitations may be in the form of non-numeric BMPs.

Construction vs. Real Estate Development Industries
The construction and real estate development industries are separate and distinct from each other; contractors cannot warrant the post-construction performance of storm water controls that others design, operate and maintain. Storm water BMPs are designed and constructed per known conditions. Future performance of properly designed and constructed BMPs and storm water controls systems can be negatively affected by post-construction modifications to on-site and off-site characteristics. Industry is increasingly concerned about scenarios that would burden the contractor with the long-term, legal liability for the performance of permanent storm water controls after the design and/or construction firm leaves the project.

Expanded and Transparent (Online) NOI Reporting
We will be interested in the ease of use of electronic reporting tools and will be motivated to provide feedback on future EPA drafts regarding this topic.

Thank you for considering our comments.

 Dan Osborn  Beth Bauer, CAE
 Director of Government Affairs  Executive Director
 Indiana Constructors, Inc.  American Council of Engineering Companies of Indiana
 One N. Capitol Ave., Ste. 1000  55 Monument Circle, Ste. 819
 Indianapolis, IN 46204  Indianapolis, IN 46204