Is your business required to maintain a Stormwater Pollution Prevention Plan (SWPPP)? To refresh your memory, all dischargers regulated under the California Stormwater Industrial General Permit (IGP) are required to submit their Annual Reports using SMARTS (Stormwater Multiple Application and Report Tracking System) by July 15th every year. What is the Annual Report? The Annual Report is a list of questions for dischargers to either a) verify that they are addressing all applicable IGP requirements for the reporting year or b) explain any areas not in compliance. The Report also includes a certification that the Annual Comprehensive Facility Compliance Evaluation (Annual Evaluation) was completed. The Annual Report must be submitted through SMARTS. It can be entered by any SMARTS user that is linked to the facility but can only be certified and submitted by the facility’s Legally Responsible Person (LRP) or Duly Authorized Representative (DAR) as long as they have a valid eAuthorization form on file. If the LRP or DAR have changed, whether because they are no longer with the company or will not be available to submit the report by July 15th, it is very important to assign a new LRP or DAR and submit the eAuthorization form to the Water Board for processing as soon as possible. Consultants or other SMARTS users who have a Data Entry Role will NOT be able to certify and submit on your behalf. What do I need to complete the Annual Report? The first step is to conduct an annual evaluation (the “Annual Comprehensive Site Compliance Evaluation,” or ACSCE), typically included in your SWPPP as an attachment or appendix. This evaluation includes a comprehensive review of:
- All stormwater records, including monthly visual and sampling observations and inspections;
- Drainage areas, industrial activity areas, and potential pollutants identified in your SWPPP as well as any that are new or were missed;
- The effectiveness of current Best Management Practices (BMPs) and availability of equipment needed for their implementation;
- Overall site compliance and needs for SWPPP revision.