Moving The Compliance Point

Leadership author Dr. John Maxwell says that two of the most difficult things to teach employees are; to think, and to do things in odrer of importance.  There is not much more important to our work than the quality of our discharge at the outfall.  Wouldn’t it be nice if we could choose the topography of our treatment area, delay the discharge, and give ourselves some cushion between treatment and discharge?

Sometimes we feel that we have zero room for error.  But, in many cases, with some upfront thinking and focused effort, we can change our situation.

We cannot literally or regulatorily (real word?) change the location of our discharge or “point of compliance.”  However, we do have the freedom to choose the point at which runoff from our project is wothy of releasing.

My first successful experience with the concept of moving the compliance point, like most great innovation, involved a regulatory action.  We had been unsuuccessfully battling sediment at a stream bank for months.  The stream was at the bottom of a narrow valley with very long and steep slopes.  The project involved a roadway on new alignment with a planned bridge which was to be approximately one hundred feet above the stream.  The planned approach  was to stick with the traditional focus on sediment control until the foundation and substructure of the bridge was completed.   As we all know, sediment control alone is simply ineffective.  The huge volumes of sediment laden water coming from the roadway construction was simply too much to handle at the creek bank.

A light bulb went off one day as we realized that if we treated the water at the top, we would simply make sure it stayed clean until it reached the bottom.  There was nothing stopping us from installing the planned rip rap lined ditches that would eventually take the post construction runoff to the creek.  We installed adequate treatment measures at the top of the slopes; limited the bridge contractor to a few designated crane pads and an aggregate covered access road; and we installed the planned permanent slope protection and lined conveyances on the abutment slopes.

By moving the bulk of the treatment work to the top of the slope, we were able to increase the treatment capacity and cause BMP maintenance to be much more efficient and effective.

Since that experience, we’ve been looking for ways to apply the new concept in all sorts of scenarios.  We have found that the concept of moving the compliance point is appropriate anytime we need runoff to be clean before it reaches some critical spot.  This “spot” may be in the form of a long fast conveyance directly to a stream as described above.  It might be an environmentally (or politically) sensitive fetaure or property.  Or it could be a drainage structure that while well within the site, happens to be the very last opportunity to treat before discharge.

Roadway inlets come to mind with the last example.  They often convey water directly to the outfall, and in many cases we would rather not treat the water on the roadway.  The water must be treated before it makes its way over the curb and into the gutter.  The compliance point would be moved from the throat of the inlet to the back of curb, to provide another specific example.

Tell us about your experiences with moving the discharge point.  Leave a comment below.

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