Both erosion control specialists and stormwater management professionals should expertly understand the development of sediment and erosion control plans, according to author Jerald S. Fifield, who reviewed the accepted standards of professionalism for engineers and environmental scientists in the previous segment. Here, in Part 2 of this three-part series, Fifield reviews the regulatory guidelines that project professionals should consider in planning and implementing construction projects that demonstrate sound erosion control methods and stormwater management best practices.
Are Professional Engineers Qualified to Develop, Sign, and Review Sediment and Erosion Control Plans?
(Part 2) By Jerald S. Fifield
Developing Effective Sediment and Erosion Control (S&EC) Plans
What does the development of S&EC plans entail? Essentially, such plans consist of a narrative section and accompanying drawings for contractors to implement on construction sites. Often, narrative guidelines are very prescriptive (e.g., in California and Georgia) in their requirement for information, data, and calculations, whereas drawing guidelines can result in excessive illustrations, confusing detail sheets, and unclear specifications.
Most states and/or regulatory agencies often use their own guidelines for developing a narrative or may emulate what appears in EPA’s (2007) template. They also usually provide checklists that often result in the creation of redundant, excessive, and voluminous material that few individuals have time to review or assess. As a result, S&EC plan narratives often become “cookie-cutter” submittals on a variety of topics ranging from risk analyses of water-quality issues to detailed best management practice (BMP) descriptions.
Comprehensive S&EC narratives do little for development of effective and practical drawings. Yet, it is the S&EC drawings that designers and reviewers must professionally develop and review so that contractors can implement and maintain BMPs in a cost-effective and practical manner.
Regulatory agencies usually provide check lists for S&EC drawing submittals. Unless these checklists are comprehensive and clearly written, they often result in designers developing cookie-cutter submittals that can be confusing, not practical, and that often cause non-compliant situations for the contractor. However, such submittals provide a trouble-free method of ensuring S&EC plans will be approved with minimal problems, even though they may not be effective or practical to implement.
In defense of the cookie-cutter syndrome, checklists do provide guidelines for designers to ensure adequate information is submitted to address potential environmental problems. However, approximately 70% to 90% of what appears on checklists is associated with narratives about pollution prevention or identifying site conditions (e.g., topographic features, soils, hydrologic information). Only about 10% to 30% of checklist requirements are related to the professional development of construction drawings, which is the most important part of an S&EC plan.
As discussed by Fifield (2011), designers and reviewers often overlook for whom they are developing and reviewing S&EC drawings. It is critical that S&EC drawings always be developed for contractors! If the contractor does not comprehend the drawings or determines that BMPs cannot be implemented in a practical manner, then non-compliant conditions may become the norm instead of an exception while construction activities occur.
Finally, it is important that S&EC drawings adhere to the KISS (keep it simple, stupid) principle. The challenge for designers is to incorporate regulatory requirements and create KISS plans that are effective, practical, and cost effective. Equally challenging for reviewers is to assess S&EC drawings for meaningful and practical content to ensure they meet regulatory requirements while providing environmental protection.
Requirements for Developing Effective S&EC Drawings
Being “qualified” means professionals must be able to design and review effective S&EC drawings by having an adroit understanding of the following:
- What BMPs to install, inspect, and maintain
- When and where to install BMPs
- BMP limitations
- When to remove BMPs
Knowing what BMPs to install, inspect, and maintain requires knowing how to complete drainage assessments as well as being aware of the risk in, and limitations of, using sediment and erosion control BMPs on construction sites. This requires applying the knowledge of natural science in a practical and effective manner; incorporating the expertise of hydrologists, soil scientists, geologists, engineers, and other professionals; and working closely with contractors.
Knowing when and where to install BMPs is critical for developing effective S&EC drawings. Knowing when to install BMPs requires designers and reviewers to be familiar with scheduling issues. They also must be cognizant of where sediment and erosion control BMPs have optimal use and have the ability to assess whether the use of specific mitigation measures will cause non-compliant conditions. Often this knowledge is best obtained by working with and communicating frequently with contractors and inspectors, as well as obtaining professional advice from agronomists, biologists, soil scientists, and others.
Knowing BMP limitations is essential for developing effective S&EC drawings, because all mitigation measures have their shortcomings. Designers and reviewers must be cognizant of BMPs that might divert runoff and cause downstream flooding and sedimentation. Both also need to understand the limitations of stabilizing hillsides and drainage channels by assessing seed mixtures, use of mulches, soil conditions, climatic conditions, and so forth. Such items (along with many others) require completing site inspections before and after severe climatic events and conferring with those having expertise on using BMPs to control sediment and erosion.
When to remove BMPs is a topic often omitted from S&EC drawings. Removal of sediment control BMPs is just as important as installing them. Clear guidelines must exist for contractors that identify when removal of sediment control BMPs should occur to ensure erosion control measures become established in an optimal manner. Often, these guidelines require designers and reviewers to complete inspections of post-construction conditions.
The above implies that the professional design of S&EC drawings requires having access to a variety of expertise and skills, including:
- Agriculture and silviculture
- Physics and chemistry
- Soil science
- Common sense
Perhaps the most important skills qualified designers and reviewers must possess are political savvy and common sense. Unfortunately, these skills usually do not evolve until an individual gains lots of experience in the development, review, and implementation of S&EC drawings.