Overcoming Challenges to Achieve and Maintain Regulatory Compliance
Challenges
Maintaining compliance with construction stormwater regulations is an especially difficult challenge for a long, linear project where space is at a premium and project schedules require that construction during the rainy season. TRC’s client, a transportation agency constructing one of the most ambitious transit system expansion in the country for a major metro area, was faced with this challenge and needed to understand the root causes of repeated discharges of polluted construction stormwater from construction projects in violation of their permit conditions.
Additionally, the stormwater run-off from these projects eventually discharges to pristine marine and freshwater ecosystems with international biological significance. There was little room for error from the construction site managers when obtaining, maintaining and adjusting the controls to consistently meet the construction stormwater compliance requirements.
Solutions
TRC provided third-party construction stormwater compliance audits of multiple segments of this project to help the agency assess the methods and procedures used by multiple general contractors and their subcontractors for maintaining compliance with stormwater permits and to use this information to identify opportunities for improvement.
TRC’s audit team used their deep subject matter expertise in construction stormwater compliance management and management systems, to evaluate how multiple layers of a complex organizational structure within the client’s, general contractors’ and subcontractors’ organizations, impact the effectiveness of the management and oversight of stormwater compliance.
We went above and beyond typical auditing practices to uncover the root causes of the lapses in compliance management by general contractors and their subcontractors. In addition to extensive in-depth interviews with the various contractors involved, we interviewed the staff of the transit agency tasked with overseeing compliance and staff from third-party construction management teams to better understand the systems and controls in place to achieve and maintain compliance.
Results
TRC audit findings provided the transportation agency and their contractors with key insight and actional information about how the organizational structure and resource factors affected compliance performance. TRC’s key recommendations were implemented, leading to an improvement in compliance oversight, management, and future performance.
Based on TRC’s findings and guidance, the transit agency was better positioned to meet its commitments to reducing the environmental impact of their projects, maintaining compliance, and controlling the risk that potential enforcement actions could have on construction schedules and budgets.