SWPPP Frequently Asked Questions

SWPPP stands for Stormwater Pollution Prevention Plan, but depending on the state or agency, it may also be called a SWP3, SW3P, SWMP (Stormwater Management Plan), CBMPP (Construction Best Management Practices Plan), CSMP (Construction Stormwater Management Plan), or ESCP (Erosion and Sediment Control Plan). While the acronyms vary, they all refer to the same core requirement originally established by the U.S. EPA.

A SWPPP, or Stormwater Pollution Prevention Plan, is a document that outlines in narrative form how a construction project will minimize stormwater pollution. It includes site-specific and state required details, control measures for erosion and sediment control, and best practice principles such as spill prevention methods and contingencies and Good Housekeeping practices.

You need a SWPPP to comply with federal regulations under the Clean Water Act (CWA). Additionally, each state also issues its own version of the Construction General Permit for Stormwater Discharges from Construction Activities (CGP). The CWA and CGP require all construction sites disturbing one acre or more of land to put together a SWPPP narrative and obtain a version of permit coverage from the state the site is located in.

A SWPPP includes site descriptions, potential pollutant sources and activities, best management practices (BMPs), inspection schedules, and stormwater monitoring details specific to the construction site or industrial facility.

BMPs are practices, techniques, or structures designed to prevent or reduce stormwater pollution. Examples include silt fences, sediment basins, wattles, and stabilized construction entrances.

For most states, inspections are typically required once every seven to fourteen days and within 24 hours of a significant rainfall event of 0.5 inches or more. Inspection frequency will differ between state policies.

The project owner or primary operator (often the general contractor) are responsible for developing, implementing, and maintaining the SWPPP, but they may delegate this task to a qualified professional. A Certified Professional in Erosion and Sediment Control is the only certification recognized by the EPA as being a qualified preparer of a Stormwater Pollution Prevention Plan.

A SWPPP is valid as long as the project is active and covered under the NPDES permit. It must be updated to reflect any changes in site conditions or operations as they occur. NPDES permits are typically issued and billed in annual cycles.

Often a civil engineer will prepare a drawing sheet within the civil package depicting where to place BMPs such as silt fence, wattles, or inlet protection barriers. This civil sheet is considered the Erosion Control Plan, though often it is mislabeled as a SWPPP. A SWPPP is a comprehensive packet that includes the controls listed on the Erosion Control plan and describes the controls, contingencies, and housekeeping practices the site will employ in narrative form as required by the Clean Water Act and associated State Construction General Permit.

SWPPP submittal depends on the local, governing municipality. Some regulatory authorities may require approval of the SWPPP before allowing a construction project to mobilize. The NPDES permit application is applied for through the associated state’s environmental regulatory office and often requires certification that a SWPPP is in place.

While templates can help, each SWPPP must be site-specific and tailored to the unique conditions of your project. Talk to a professional today to make sure you are covered!

Common violations include an inadequate or missing SWPPP at the construction site or industrial facility, failure to implement and/or maintain BMPs, lack of regular site inspections, and unauthorized discharges of stormwater. Penalties for SWPPP violations can include:

1. Fines: Up to $25,000 per day, per violation under the Clean Water Act, plus additional state/local fines.

2. Criminal Charges: For willful violations, fines up to $50,000 per day and up to 3 years of imprisonment.

3. Stop-Work Orders: Regulatory agencies may halt construction until compliance is achieved.

4. Increased Costs: Violations may lead to stricter monitoring, reporting, and additional stormwater controls, increasing project expenses.