About the author: Danielle Kurek is a regional storm water manager in the construction industry. Kurek can be reached at [email protected].
Many of us enter the storm water field by chance. In 2010, I found myself in Southern California at the cusp of its overdue and expansive construction general permit (CGP) renewal. At that time, I obtained my CESSWI certification to qualify for the California Qualified Stormwater Pollution Prevention Plan (SWPPP) Practitioner (QSP) designation required to perform inspections for construction projects. During the first few years of the new requirements for QSP and Qualified SWPPP Developer certifications, I noticed a trend across California: not enough qualified and certified personnel were available to meet the demands and needs of the CGP requirements.
Fast forward to 2017, and I am feeling a bit of déjà vu. I have started noticed other states following suit, requiring either a state-specific training and certification program or relying on some industry-known certifications. This evolution has been a somewhat slow process for the past 20 years, with the U.S. Environmental Protection Agency (EPA) first introducing the term “qualified personnel” in the 1998 CGP. The term has since become better defined and increasingly prevalent. The current 2017 EPA CGP definition of a qualified person is as follows:
“A person knowledgeable in the principles and practice of erosion and sediment controls and pollution prevention, who possesses the appropriate skills and training to assess conditions at the construction site that could impact storm water quality, and the appropriate skills and training to assess the effectiveness of any storm water controls selected and installed to meet the requirements of this permit.”
Per the EnviroCert website, the Certified Professional in Erosion and Sediment Control (CPESC) Council was formed in 1977, beginning the framework of the CPESC certification. In 1996, the council received a request from the EPA “…to develop a certification program for specialists working on storm water issues …” However, EPA has not mandated specific training required to prepare SWPPPs or perform inspections, but numerous states, counties and municipalities have.
Over the past six months, I have noticed several trends. First, a continued lack of understanding and non-acceptance of various training or certification programs across the industry. There still is confusion and debate among professionals as to whether certifications are needed and, if so, which are best. As many would agree, there is no “one-size fits all” for storm water. Each state is different in regulatory language and storm water concerns or needs.
Second, there are increasing numbers of states or local regulatory bodies developing either their own certification programs, or requiring Certified Inspector of Sediment and Erosion Control (CISEC), Certified Erosion, Sediment, and Stormwater Inspector (CESSWI), or CPESC as an underlying or stand-alone requirement. As I have discussed with regulators who have enacted these requirements, a common story is told: arriving at construction sites, often finding a SWPPP and the required postings, and noticing no one has been properly trained on the permit or storm water requirements. Posing questions to regulators who recently have or currently are renewing their CGP’s, comments have been vague, often stating certification or training requirements have been discussed but no decision has been made for the time being.
Third, just as I saw seven years ago in California, there has been or is an initial “drought” of qualified persons after the introduction of certification requirements. Currently, in Texas, there is no statewide program or requirement, but several counties and municipalities have included CISEC or CESSWI certifications in their definitions of “qualified personnel.” In contrast to California, which often is considered a stricter regulatory environment, these counties and municipalities are not accepting “in-training” or supervised status. California has allowed junior inspectors to work under qualified persons while they obtain required experience. In certain areas, there are not enough qualified professionals, and the industry is experiencing an unintended consequence of pushing new inspectors to obtain training and experience elsewhere.
Lastly, on top of the limited pool of qualified personnel, the inspectors often have limited tenure before moving on to longer-term career-focused positions. New college grads often get their feet wet as inspectors. Once they work for one to three years and qualify for certification, many move on, resulting in a cycle of consulting firms churning out certified individuals but rarely reaping the benefits or long-term retention.
