Devising a storm water management program for highway construction projects is one thing; implementing it effectively is another
As holder of a statewide permit, the California Department of Transportation (Caltrans) is responsible for managing storm water on all of its highway construction projects. At any given time, those projects include approximately $2 billion worth of activity, affecting a total of about 1,200 hectares of soil in locations scattered throughout the state’s 405,431 sq km of land area.
Permit violations can carry substantial penalties, ranging from fines to work stoppages. Compliance, however, generates benefits that go far beyond just the avoidance of penalties. Conserving soil on the site and preventing water pollution are the most obvious ones. Whether motivated by a pragmatic need to comply with regulations or by a desire to protect the environment, highway builders must find effective ways to manage storm water.
The Caltrans’ approach
Caltrans developed a four-pronged approach for its storm water management program. In addition to promulgating formal compliance manuals, Caltrans supplemented its technical directives with a vigorous education program and ongoing inspections. By disseminating and publicizing technical innovations—whether developed by Caltrans or on-site contractors—they also leveraged improvements to enhance storm water management statewide.
Like many agencies, Caltrans bases its storm water management program (SWMP) on manuals that describe how to select and implement approved procedures. These “best management practices” (BMPs) are specific techniques for tasks such as stabilizing soil, controlling sediment, diverting water and containing pollutants. For example, a combination of erosion blankets and silt fences might be needed on an embankment to stabilize disturbed soil and control sediment. Examples of BMPs that are less visible include preserving vegetation to the extent possible and scheduling project activities to minimize soil disturbance during the rainy season.
The information in the manuals is essential, but successful implementation of the program requires more than just printing and distributing documents. Recognizing this, in 1997 Caltrans created a storm water task force consisting of Caltrans employees, private consulting firms and university experts.
“The task force was originally envisioned as a way to get an overview of how well we’re deploying storm water management techniques within our construction projects,” said Mark Rayback, Caltrans’s chief environmental engineer and storm water program manager. “We look at it as a ‘lessons learned’ and ‘best practices’ identifier to find what’s working well programmatically and what programmatic areas need some improvement.”
In implementing the SWMP, the task force concentrates on three key areas of activity: education, inspection and improvement.
The education component takes several forms. One is actual classroom instruction. During the early phases of developing the SWMP, the task force created and taught classes for resident engineers, field inspectors and contractors. Now that the program is widely known and used, there is less demand for those classes. Still, the water pollution control manager for each construction contract must have received 24 hours of classroom instruction (available for a fee from consultants).
A second form of education was delivered through a printed bulletin that the task force published for almost six years. The bulletins were concise (one page long), attractive (printed in color) and useful (informative text accompanied by photographs and drawings). They explained the objectives and processes of the SWMP and the task force, demonstrated proper use of common BMPs, described typical problems with BMP implementation and maintenance and profiled particularly successful projects. The bulletin was initially produced twice a month, then once a month, before being discontinued in November 2002. All 83 issues are archived on the Internet (www.dot.ca.gov/hq/env/stormwater/publicat/const/acrobat.htm). Although some of the information in early issues has since been revised, the electronic collection is a useful, easily accessible resource.
A third form of education has been delivered informally by the field inspectors. When they find a deficiency on a site, they teach the contractor how to correct it. This personal interaction also gives them an opportunity to promote storm water management as a worthwhile effort that requires a comparatively small investment of time and effort. Another function of the inspectors is to help contractors devise treatments for unusual or complex site conditions. As an additional resource, Caltrans assigns a construction storm water coordinator to each of its districts to provide information and guidance for contractors.
To be effective educators, inspectors must have a solid technical background and be able to establish a good rapport with field workers.
No matter how good a BMP manual may be, the task force has little confidence that contractors would fully comply with the program’s guidelines unless they were being monitored. David Sluga, project manager for task force member DMJM+Harris, offered several reasons for this.
For one, he said, “The water pollution control on a site doesn’t have any bearing on the final product—how good your concrete pavement is or how good your building is.”
Second, he observed, “If you’re going to implement something like this, the biggest hurdle is you don’t see the immediate effect of what you’re doing or not doing. The contractor thinks, ‘I’m spending money, but what’s the gain?’” And money is always the bottom line. Spending money cuts into the contractor’s profits—or even creates losses.
“When things are going badly, storm water management is probably one of the first things that will get dropped, so you have to pay attention to it,” Sluga concluded.
Four inspectors stationed in different parts of the state conduct the site evaluations. Current projects with budgets of at least $1 million are ranked according to their sensitivity. Those in the most sensitive locations (e.g., in wet areas, on hillsides or near polluted lakes or bays) are ranked highest and designated as Priority 1. They are scheduled for inspection every six weeks. Priority 3 jobs, those with the lowest sensitivity, are scheduled for visits every three months. If a site receives an unfavorable rating, the inspector will return in a week or two to make sure the problems have been corrected.
“New ideas were paramount with us—ideas that we gleaned from the contractors and the resident engineers,” Santori said. “We used that information to develop different BMPs and different ways to approach problems; carried those ideas over to the next job; and then spread that information all over the place. That really helped us.”
This willingness to adapt extends beyond improving solutions to technical problems in the field. One example is that the bidding process for construction projects was recently revised. In the past, bidders included a lump-sum price for storm water management. Now, however, they must itemize costs for various BMPs. Caltrans expects that being more specific will force bidders to plan more realistically for the materials and activities that will be needed.
“We had contractors complain that the sophisticated contractor wasn’t getting the job because the unsophisticated contractors didn’t really know what they were bidding on and therefore would submit unrealistically low bids,” explained Mike Flake, the Caltrans contract manager for the task force. “Then when we got to the construction site, we had to educate those contractors. It cost us a lot of time and money to bring projects up to the standards that we wanted. Itemizing the work separately eliminates a good portion of that problem.”
Changing the process in response to experience sometimes means clarifying or easing theoretical thresholds. For example, early guidelines included vague or overly restrictive language, such as “during the rainy season, all of the site’s active areas must be stabilized.” As a practical matter that cannot be done, short of shutting the project down for the entire rainy season. So the task force developed a more workable guideline. Depending on site characteristics, contractors are now allowed to have as much as four hectares open for work, using only sediment control on that area (rather than soil stabilization).
Measuring the results
The relationship among the four key elements of Caltrans’s SWMP is dynamic. Thorough, usable manuals are updated as necessary to reflect advances in technology and practical limitations in the field. Contractors—who have already been educated in the basic components of storm water management—have access to expert advice when they face unusual situations. Periodic, well-structured inspections provide feedback to contractors on their performance and to Caltrans on the effectiveness of the program. The evaluations also alert Caltrans to the difficulties contractors face and highlight the successful innovations that field personnel develop. These innovations, in turn, lead to improved techniques that can be used statewide.
“Managing storm water is not a stand-alone or a separate thing,” Rayback said. “You should strive to integrate it so it just becomes part of what you do. As you do that, you increase your awareness of what you are doing, and ultimately you get more effective and more efficient.”
Convincing contractors to integrate more tasks into their already complex projects—and giving them the necessary skills and tools—has taken time and effort. Sluga, who has worked on the SWMP for six years, said, “When I was first here, contractors were putting up a lot of resistance to the storm water management program. We’ve gotten past that now, and I think it’s accepted as a necessity. But that acceptance hasn’t yet reached a level that says, ‘We’re really helping the environment, and this is great!’”
The results have been dramatic, though. Moreover, they are measurable. In formulating its inspection process, the task force developed a rating system to document what they found at each construction site. Inspectors assign each applicable location or activity a number ranging from 1 (appropriate BMP being installed and maintained correctly) to 4 (lack of needed BMP). Combining those individual scores generates an overall rating for the site, also expressed on a scale of 1 to 4. When inspections began in 1997, some 60% to 70% of the projects received a “favorable” rating, meaning their composite score was 1 or 2. In 2003, 96% of inspected projects achieved the “favorable” level.
“The improvement over the past six years is just phenomenal,” Sluga said. And these accomplishments are particularly noteworthy because the contractors had to make significant changes in their daily operations.
New paradigm, new opportunities
This is not the first time the industry has faced major new requirements. Approximately 25 years ago safety was the hot issue.
“Now, it’s automatic; people put on hard hats and safety shoes and safety glasses without even thinking about it. That’s where we’re getting to in storm water, and that’s where we want to go,” Santori said. “When I first started out, I was really skeptical about it. As I came to understand the problem and the benefits, and as I learned that we could do it cheaply if we just thought about it, I changed my mind completely. In fact, now I think we can improve the environment in other ways we are just beginning to understand.”