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Environmental Issues Demand Diligence
By Geoff Rabinowitz Due to the
current slowdown of Floridas housing market, it may be tempting for some
builder-developers to delete various storm water line items, such as extra
street sweeping or bringing the permit required inspections in-house.
Dont do it. Resist the temptation! Now is the worst time to
skimp on environmental compliance. While reducing line-items for
environmental compliance may show a quick budget reduction, you are not
making a sound financial decision in your companys future.
The cost-benefit ratio and ultimate risk is too great.
Environmental compliance problems can actually be magnified in a time of
economic downturn. As the market continues to cool, regulators will have
more time on their hands to spend on permits and examine your projects
environmental compliance. Simply stated, the cost of non-compliance far
outweighs the cost of compliance. Thus,
now is the perfect time to take a step back and develop a sound plan for
dealing with National Pollutant Discharge Elimination System (NPDES) storm
water, sediment, and erosion control issues.
To draw an analogy, if you had a sprained knee and took some
aspirin to make the pain go away, the sprained knee would still exist.
Deleting storm water budget line items in a vacuum is basically like taking
aspirin for a sprained knee; the underlying problem is still there and may
become aggravated and more costly if not properly treated initially. A
better approach would be to look at the broader spectrum and develop a
strategic plan. Approach environmental compliance with the following three
ideas in mind: 1. Hire a qualified
person. A qualified person hired by a builder to perform inspections is
a valuable commodity and falls within the adage: an ounce of prevention is
worth a pound of cure. Such an individuals purpose is to protect the
interest of the builders financial bottom-line by limiting the builders
environmental liability and exposure. A qualified person has experience in
inspecting and recommending sediment erosion control. Specifically, the
person should have a clear understanding of Best Management Practices (BMP),
NPDES Storm water Construction Generic Permit criteria (including
performance standards) and the Storm water Pollution Prevention Plan. The
person should be able to grasp multiple environmental rules and have basic
wetland identification skills. 2.
Environmental compliance is a benefit to the industry and your wallet.
If home builders make a concerted effort to comply with the NPDES storm
water permit, the industry as a whole should benefit from a reduction of or
at least arguably the need to reduce the severity and complexity of future
regulations, including the implementation of Total Maximum Daily Loads
(TMDL). But, in order to do this, the industry cannot take a wait and see
attitude on enforcement in times of economic slow-down.
3. Save your company money in the long run. A truly
sound way to save your company money is to maintain a storm water budget,
have a storm water management expert look at your overall storm water
/sediment-erosion control program, and implement clear and direct behavioral
changes across the board. The majority of the money spent on your storm
water budget is for sweeping, BMP replacement and corrective actions. If you
can learn how to minimize these risks, your savings should be substantial.
This will afford you the advantage of letting the experts handle the
administrative portion of your program (inspections, storm water pollution
prevention plan development, etc.) which will in turn better protect you and
the entire home building industry. In addition, by maintaining an
environmental compliance program, an inherent public relations advantage
exists. Dont let regulators fine you on the back-end; spend a little on the
front-end for your financial insurance. It is a win-win for your company,
the industry and your customers. Geoff
Rabinowitz is the Vice President of Professional and Consulting Services at
Alpha Environmental Management Corp
Alpha Environmental Management Corp.
grabinowitz@alphaemc.com
Toll Free: 866-707-3480
http://alphaemc.com/
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