Even as enforcement begins to ramp up, it's still tempting for many GCs to roll a project's SWPPP mandated erosion and sedimentation controls into the earthwork contractor, or other trades, scope of work—perhaps even driving an 'at cost' deal that insures the sub's ability to get the job he actually bid. Money is tight in every project in today's economic climate, but what may seem like a good idea can have serious consequences.

• If the subcontractor's livelihood is driven by another trade or specialty, will he and his people be trained and experienced in SWPPP related problems and solutions?  Unmotivated, uninformed installers can quickly negate any 'savings' you'd hoped to achieve. And opportunities may turn into liabilities. For example, the SWPPP drawing for a project often requires adaptation to meet jobsite realities. These modifications can often save you money, but a contractor handling a storm water installation as an after thought isn't likely to have the expertise or the interest in making those modifications.

• Will spec materials be used, or will cheap and readily available 'contractor grade' products be installed—Ôø‡and will you know the difference?  A significant percentage of jobsites all across this region use silt fence fabric that you can read a book through—it's not even close to spec, it's not compliant and it won't do the job it's called on to do.

• Will the installation methods used provide a compliant solution, one that actually work—or one that costs you more in the long run?  'Trencheda' silt fence installations are rarely trenched properly. This means that an already weak installation method [see our Solutions Bulletin entitled The Problem with Silt Fence, for more information on this topic] is rendered nearly useless. Slashing a gash in the earth with the corner of a dozer blade, or the down-turned forks of a forklift, won't produce a viable installation, yet we see these methods used every day. Silt fence installed backwards is also incredibly common. Not only do these installation failures leave you out of compliance—but they also mean you've got to keep sending laborers out to repair the problems for the life of your project.

Rolling the SWPPP into another trade's scope may produce phantom savings at best, and the risk you may bear as a consequence grows more serious with each passing day. 'Cosmetic' compliance simply won't cut it anymore. As SWPPP specialists, creating cost-effective, high compliance solutions to your SWPPP problems are what we're all about

For more information on BMPs, please contact us at 832.456.1000.