If you are hiring a contractor for your project, there are several questions you should ask prior to making your contracting and scheduling decisions, for instance:

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Q.  Is your contractor/landscape design professional Panhandle SEEP certified or otherwise trained in Best Management Practice (BMP) Installation and application? 

A.  It is important that your contractors understand and be willing to address the problems associated with stormwater, erosion and sediment control.  Proper planning from the beginning of the project will save time, money and frustration.
 

 

Q.  Do you know what permits are necessary for this job, and who is the responsible person for permit compliance?

A.  Permitting requirements vary depending on the type of job, location, site conditions, size, etc. The property owner is ultimately responsible for obtaining permits, and ensuring compliance.  Discuss who is responsible for all aspects of the permitting process before the project starts, fines and stop work orders can be detrimental and costly.

 

 

Q.  What is the schedule for each phase of the project?

 

A.  While it may be easier and less expensive to the contractor, to level the entire job site at one time, it may not be best for the overall project, or you the owner.  Leaving vegetative cover in place is one of the most effective methods of erosion control.  The cost of covering bare portions of the project, particularly if the site must sit over the winter, could far outweigh the savings of using the equipment one time to level the entire site.

 

 

Q.  When will the site be cleared and what will be cleared from the site?

 

A.  Fall is traditionally the rainiest season in North Idaho, but spring can be a close second.  Additionally, the water table tends to be quite high in certain areas of North Idaho during the spring months.  Establish a clear plan with your contractor regarding when vegetation and soils will be moved, and how run-off and erosion will be addressed.

 

 

Q.  What vegetation is to be maintained and how will it be protected?

 

A.  Vegetation to be retained should be clearly identified on the SWPP or ESC, and described in a narrative.  Sections or individual trees should be flagged, paint marked, or otherwise distinguished to avoid accidental damage or removal.

 

 

Q.  What temporary and permanent BMPs will be used and when will they be in place and maintained?

 

A.  Best Management Practices (BMPs) differ according to the type of project, and site conditions.  There is no list of absolute BMPs for your contractor to produce.  Your landscape design professional/contractor should be able to tell you what the runoff/erosion/sediment control concerns are for your site, and how they can best be mitigated.  Beware of unsubstantiated quick answers, such as "you don't need to worry about erosion, the site is flat." or "all we need is some silt fence."  Every site has a potential for erosion, and the proposed BMPs should make sense.

 

 

Q.  What is the contractor's inspection plan?

 

A.  The Construction General Permit requires regular inspections, and describes a minimum frequency for those inspections.  (Weekly, and after each rainfall event exceeding one-half inch.)  Every site is different, and certain circumstances may necessitate more frequent inspections, for instance, if the site could be considered an attractive nuisance, due to it's location in close proximity to a park.  Even if your project does not require a Construction General Permit, you should have a written inspection plan for BMPs.

 

 

Other questions you may have:

 

Q.  Why retain native and climate-adapted vegetation on the construction site?

 

A.  Native plants have evolved in the region where they are found by adapting to the local conditions such as soil, geology, and climate.  Because of this, they are resistant to most pets and diseases, need less maintenance than non-native vegetation, and require little or no irrigation or fertilizers once they are established.  Other benefits of retaining native vegetation include: stabilizes soil to prevent erosion, decreases storm water runoff, moderates temperature, provides buffers and screens, filters pollutants fro the air, supplies oxygen, offers habitat for wildlife and increases property values.

 

 

Q.  What are the five types of erosion caused by water?

 

A.  Raindrop (dislodges soil particles), sheet (shallow sheet of water running off the land), rill (small, but well defined channels), gully (rills come together larger), and channel, sometimes call stream bank erosion (may be large enough and forceful enough to move a streambed itself, or it's bank.)

 

 

Q.  When do you need a Construction General Permit?

 

A.  If your construction site disturbs one or more acres, or is a smaller site that is part of a larger, common plan of development or sale that is greater than one acre in size, and/or contains a point source discharge to waters of the United States.

 

 

Q.  If my project requires a Construction General Permit, what forms do I need to submit to the Environmental Protection Agency (EPA)?

 

A.  Submit a Notice of Intent (NOI) to comply with the Construction General Permit before construction starts.

 

 

Q.  If my construction site is in or near a wetland, is there anything specific I need to know?

 

A.  Under Section 404 of the Clean Water Act, an Army Corps of Engineers (ACOE) permit is required for discharges of dredged or fill material into waters of the U.S., including wetlands.  If a construction project will cause damage or a discharge of fill into a suspected wetland, the local ACOE office should be consulted on the specifics of the site area and whether a permit will be required.  In Idaho, the permit is Joint Application for Permits, administered by the ACOE, Idaho Department of Lands, and Idaho Department of Water Resources.

 

 

Q.  What does the acronym NPDES stand for?  National Pollutant Discharge Elimination System

 

A.  This is a federal permit system for point source discharges (waste discharges coming from a discrete source such as a pipe or channel).  In Idaho, NPDES permits are issued by EPA, not the State of Idaho.  A common permit would be for a Wastewater Treatment Plant, such as the Coeur d'Alene WWTP which discharges treated effluent into the Spokane River.  In the development arena, stormwater discharges from a construction site flowing into the waters of the United States, from a site where the disturbance is an acre or more, comes under the NPDES in the way a nation-wide Construction General Permit.

 

 

Q.  What is a SWPPP, and when do I need one?  Stormwater Pollution Prevention Plan

 

A.  If a construction project has the criteria of having to obtain permit coverage from EPA under the NPDES Construction General Permit, then a SWPPP will be required.  A SWPPP is a comprehensive plan on how erosion, stormwater, and hazardous materials will be controlled for the site construction project.  When a CGP Notice of Intent is filed with EPA, the assumption is that a SWPPP has already been completed, and that the contractor will adhere to SWPPP and other requirements of CGP coverage.

 

 

Q.  What does TMDL stand for? Total Maximum Daily Load (TMDL)

 

A.  A TMDL is a process under the federal Clean Water Act (CWA) which first requires states to identify streams, rivers, and lakes that have become impaired by pollutants such as sediment, metals, bacteria, or nutrients (phosphorus and nitrogen).  While these materials are naturally occurring, the pollution comes from an excess amount going into our waters created by human land-use activities.  There is a scientific process and analysis to determine if a waterbody's beneficial use has been impaired by pollution.  Beneficial uses include: health of cold water aquatic life (trout and the insects they feed on, which can be impaired by excess sediment), swimming as impaired by fecal bacteria from sources such as sewage wastewater, and drinking water as could be impaired from pollution.  In Idaho, there are many surface waters that have been identified as impaired and formally listed as such under the CWA §303(d) list.

 

A TMDL is a watershed plan to reduce the amount (load) of an identified pollutant to the point where the beneficial use of a §303(d) waterbody is no longer impaired.  Or in other words, a TMDL is a waterbody's maximum load capacity of an identified pollutant in which beneficial uses are fully supported.  This is the initial, pollutant reduction target of a TMDL.  Commonly, a TMDL is calculated on an annual basis rather than daily.

 

If a construction job is adjacent to a listed TMDL stream, river, or lake, there may be additional permit requirements to insure that a pollutant such as sediment does not reach the waterbody.

 

 

Q.  What does ICP stand for, and what does it require?  Institutional Controls Program

 

A.  An ICP is often a requirement when an area becomes designated as a federal Superfund site, such as the Bunker Hill Superfund Site along the South Fork Coeur d'Alene River (Silver Valley).  This site was originally within a 21 square mile box centered around the city of Kellogg.  The ICP boundaries now extend down the lower Coeur d'Alene River to Harrison.

 

Within the ICP boundaries for the Bunker Hill site, there are locally enforced regulations, permits, and even required training, administered by the Panhandle Health District 1 from their Kellogg office.  In regards to construction activities, the ICP regulations are designed to maintain the integrity of clean soil and other protective barriers that have been part of the Superfund clean-up and decontamination efforts since the mid 1980s', and to deal with soils that still have high concentrations of metals such as lead.

 

 

Q.  What site characteristics should be assessed before construction begins?

 

A.  The "Site Assessment" list should include: 1) proximity to a stream, river, or lake, 2) mapping and photographs of existing vegetation, 3) soil characteristics of the site (e.g. soil erodibility), and underlying parent geology, 4) the various slopes of the site (topography), 5) local precipitation patterns, 6) pattern of water run-on to the site, and pattern of water run-off from the site, and 7) critical areas of special value including floodplains, wetlands, riparian zones, and aquifers.

 

 

Q.  What is a BMP?  Best Management Practice

 

A.  Accepted methods and technologies for controlling or minimizing nonpoint source pollution (pollution from diverse sources which can be difficult to trace to a specific source) and point source pollution (coming from a discrete, identified source such as a pipe).  BMPs are applied in most categories of land-use activities such as forest practices, agriculture, roads, construction, and wastewater treatment.

 

 

Q.  How many types of BMPs are there?

 

A.  BMPS include: 1) structural devices such as silt fences, straw waddles, sediment settling basins, 2) application practices such as spreading straw mulch, hydro-mulching, hydro-seeding, 3) planning practices such as minimizing site disturbance, maintain existing vegetation filter strips, phasing construction activities to minimize disturbance area at any given time, and even 4) political practices such county or city site disturbance ordinances, and regulations requiring minimum setback distance of septic drainfields to a surface water.  In construction, there are erosion control BMPs and sedimentation control BMP.