If you already know your facility needs a SWPPP and you are looking for someone to handle it, here is the short version: CDMS develops your stormwater pollution prevention plan, ships you the sampling kits, runs the lab coordination, reports your results to the state, and prepares your annual evaluation. We have done this for California industrial facilities since 1988. You can call us at (925) 551-7300 and we will give you a fixed-price quote.
If you are not sure whether any of that applies to you, this page is the longer version. Maybe you inherited the stormwater file from someone who left. Maybe your results came back high and the state portal says you owe them an “ERA.” Maybe a letter showed up from an environmental group claiming you aren’t following the regulations correctly. A SWPPP, short for stormwater pollution prevention plan, is the document the State Water Board requires from many California facilities that store materials or run industrial operations outdoors where rain can reach them. Below is how to tell whether you need one, what the work involves, and how CDMS handles it.
Why Facilities Call Us
Most people do not go looking for a stormwater consultant out of curiosity. Something happens first. When we walk facilities and talk to the people responsible for this, the reason almost always falls into one of these:
- Your previous consultant is gone. They retired, passed away, or stopped returning calls, and the stormwater program came with the job nobody warned you about. This is the most common reason facilities call.
- You inherited it. You took over compliance in September, or your boss handed it off, and now the paperwork is yours with no training and no background on what was filed before.
- Your results came back high. A sample exceeded a benchmark, and SMARTS (the state’s online stormwater reporting portal) is telling you that you need a Level 1 or Level 2 evaluation. You are not sure what that means or how serious it is.
- You are overloaded. You run EHS for the whole site and the stormwater piece keeps slipping. You want it off your plate and handled correctly.
- The facility changed hands. An acquisition, a new location, or a business license renewal triggered a compliance review, and stormwater surfaced as an open question.
- You received a notice from a private group. A letter arrived threatening a lawsuit over stormwater discharges. This is real, it is legal, and it is not the same as a notice from a regulator.
If you recognize your situation here, the rest of this page tells you what the program actually requires and what working with us looks like. If you received a lawsuit threat, read what California facilities need to know about citizen-suit stormwater enforcement first.
What Stormwater Compliance Actually Involves
“SWPPP compliance” is not one document filed once. It is a permit you stay enrolled in, with work that repeats every year and every time it rains. Here is the full scope, and CDMS handles all of it:
- NOI and SWPPP development. Filing the Notice of Intent to enroll under the permit, then building the plan itself. Our SWPPP template runs eleven sections: company profile, site maps, an industrial materials list, an assessment of pollutant sources, your best management practices, a monitoring plan, and the recordkeeping and reporting that hold it together.
- Sampling. Collecting stormwater samples during qualifying rain events, from two qualifying storm events in each half of the reporting year (four total per year), and getting them to a lab.
- SMARTS reporting. Uploading sampling results, the annual report, and any other required documents to the state portal within the deadlines.
- Annual evaluation (SWAR, the Stormwater Annual Report). A yearly facility compliance evaluation, with the report due every July 15.
- NEC certification. For facilities that keep everything indoors or under cover, a No Exposure Certification can replace the full permit. More on that below.
- ERA evaluations. When results exceed benchmarks, Level 1 and Level 2 Exceedance Response Action reports, action plans, and technical reports. All of this work is certified by a registered QISP (Qualified Industrial Stormwater Practitioner) on our staff.
- Sampling frequency reductions. When your results stay consistently below the permit’s action levels, the Industrial General Permit allows a reduced sampling schedule. We prepare and submit the demonstration to the Water Board and routinely secure these reductions for facilities that qualify.
You can read more detail on stormwater sampling and what’s required, SMARTS reporting, and the best management practices inspectors actually look for in the dedicated guides.
The California Regulatory Picture
Stormwater is a water program, not a fire department program, so the agency is different from the CUPA, or Certified Unified Program Agency (which may be a county environmental health department, fire department, or another local agency depending on jurisdiction) most facilities deal with for hazardous materials. The rules trace back to the federal Clean Water Act, but in California the program runs through the State Water Resources Control Board and nine Regional Water Quality Control Boards.
The permit itself is the Industrial General Permit, or IGP. Its formal name is Water Quality Order 2014-0057-DWQ, as amended by Orders 2015-0122-DWQ and 2018-0028-DWQ, under federal NPDES General Permit No. CAS000001. You do not need to memorize that. What matters is that one statewide permit covers most regulated industrial facilities, and your Regional Water Board is the office that enforces it for your area.
A few things about this program catch facilities off guard:
- The sampling season runs July 1 through June 30, and the annual report is due July 15. The calendar does not follow the calendar year.
- In some watersheds, TMDL-related requirements set stricter limits than the statewide Numeric Action Levels (NALs). A facility can be within the permit’s standard numeric action level for a parameter but still in exceedance under TMDL-specific limits that apply to its receiving water. We cover this in the exceedance and ERA guide.
- Enforcement is not only the government. Private environmental groups in Southern California and the Bay Area use the Clean Water Act’s citizen-suit provision to pursue facilities directly.
Who Needs Coverage and What It Requires
| What triggers it | Who enforces it | What’s required |
|---|---|---|
| Industrial operations with outdoor exposure to rain (manufacturing, recycling, warehousing with outdoor activity, and other covered SIC codes) | Your Regional Water Quality Control Board, under the State Water Board’s IGP | File an NOI, develop and implement a SWPPP, sample four qualifying storm events per year (two per half-year), report to SMARTS, file an annual report by July 15 |
| Covered activity, but nothing exposed to rain (everything indoors or under cover) | Regional Water Board | No Exposure Certification (NEC) in place of a full SWPPP; annual evaluation and recertification still required |
| A sample exceeds a permit benchmark (NAL) | Regional Water Board, through SMARTS | Level 1 or Level 2 Exceedance Response Action: evaluation, additional BMPs, and in some cases a technical report, all QISP-certified |
| You believe you are exempt | Regional Water Board | Verify it. The old light-industrial exemption changed; many facilities in covered SIC categories need at least an NEC |
Not sure which row is you? Walk through the full “do I need a SWPPP” decision guide, or read the California Industrial General Permit overview for the regulatory detail.
Not sure whether your facility is covered, or whether an old filing still stands? Call (925) 551-7300 or request a consultation. Tell us what you do on site and we will tell you what the permit requires of you.
How CDMS Handles It
We come to you. Stormwater is a field-service program, and our consultants work from your facility, your drawings, and your operations, not from a desk with a generic template.
Before we start, we ask for a defined set of information: your SMARTS login, your Legally Responsible Person’s details, a copy of any previous SWPPP and NOI, your current chemical inventory, your facility drawings, and your SIC code. We also ask you to name your Pollution Prevention Team. The SWPPP defines five roles, each with a primary and an alternate, covering implementation, sampling, site evaluation, the annual report, and recordkeeping. Naming those people early is part of building a plan that actually works on your site. What to expect when CDMS handles your SWPPP walks through this step by step.
The sampling model: kits, not site visits
Here is where we differ from how this is often done. Many consultants send a field technician to your site to collect stormwater samples. The problem is rain. The technician shows up, there is not enough rain to collect a qualifying sample, and you get charged for the visit anyway. Those dry-visit charges add up, and they rarely appear in the original proposal.
CDMS uses a kit-based model instead. We ship you turnkey sampling kits: bottles, chain-of-custody forms, pH strips, a cooler, and instructions. Your team is already on site when it rains, so you collect the sample at the right moment. We train on how to take the sample, handle the lab coordination, interpret the results, and upload them to SMARTS. We send the kits one at a time across the season so the timing stays right. This is the whole reason behind why we don’t send a technician to collect your samples.
One requirement we cannot remove: the Water Board makes your Legally Responsible Person log in and click submit in SMARTS. We prepare and upload everything, but the final submission has to come from your LRP. We tell clients this up front so nobody is surprised at the deadline.
NEC: You Might Not Need a Full SWPPP
Many of the facilities we enroll qualify for a No Exposure Certification. That means if nothing industrial is exposed to rain, you may not need the full sampling and SWPPP program at all.
NEC is not a guess. We evaluate it against a structured checklist across five categories: whether non-stormwater discharges are eliminated, whether significant materials are kept out of the rain, whether industrial activities and equipment are covered, whether there is indirect exposure such as dust or particulate settling from stacks, and whether the registration and annual maintenance are in place. A facility passes only if every category holds up.
NEC is not “file once and forget.” It carries its own obligations: a SMARTS submission, an annual facility evaluation, and recertification due each October 1. And “no discharge” does not mean “no obligations.” Even a closed-loop or infiltration facility still has annual reporting and may not qualify for NEC. We figure out which path legally fits your site before any sampling kit gets ordered, which often saves facilities a season of work they did not need.
Wondering if your facility could skip the full SWPPP with a No Exposure Certification? Call (925) 551-7300 or request a consultation. We will run your operations against the NEC criteria and tell you straight whether you qualify.
What It Costs and What You Get
We do not publish a price because there is no single price. What drives the cost is your facility: its size, how many storm drains or discharge points it has, how many chemicals and industrial processes are in play, whether you already have a SWPPP and drawings on file, and whether you have an exceedance history that adds ERA work. NEC-eligible sites cost less than full-permit sites. You can read the full breakdown of what drives SWPPP cost.
What you get is a single point of contact who knows your site, handles the recurring deadlines before the Water Board comes looking, and keeps your documentation defensible. That last point matters more than it sounds. If a private group ever sends a notice of intent to sue, your sampling records and your SWPPP are your defense. We also keep stormwater connected to the rest of your compliance, because your stormwater program overlaps with your other California EHS obligations, and a facility change, closure, or ownership transfer almost always triggers a stormwater review even when operations stay the same.
One thing you will never get from us: we do not report our clients to agencies. Not while we work for you, and not after. Facilities ask us this often, and the answer is the same every time.
Frequently Asked Questions
What is a SWPPP?
A SWPPP is a stormwater pollution prevention plan. It is the document the State Water Board requires from many California industrial facilities to identify how rain could pick up pollutants on your site and what you do to prevent it. The plan covers your materials, your pollutant sources, your control measures, and how you monitor and report.
When is a SWPPP required in California?
You generally need coverage if your facility falls under one of the regulated industry categories (defined by SIC code) and has industrial activities or materials exposed to rain. If nothing is exposed, you may qualify for a No Exposure Certification instead. The do I need a SWPPP guide walks through the specifics.
Who needs a SWPPP?
Manufacturers, chemical distributors, recyclers, warehouses with outdoor activity, and other facilities in covered SIC code ranges that store materials or run operations outdoors. If you are unsure, the safest move is to verify rather than assume you are exempt, because the old light-industrial exemption changed.
What is SMARTS?
SMARTS is the Stormwater Multi-Application and Report Tracking System, the State Water Board’s online portal. Your NOI, sampling results, annual report, and any ERA documents are all submitted there. It is not always intuitive, and its automated exceedance determinations are not always reliable, which is why we verify requirements independently. We often know you have a report due before the state does, so you get a head start.
What is NEC certification?
A No Exposure Certification lets a facility out of the full SWPPP and sampling program if nothing industrial is exposed to stormwater. A majority of the facilities we enroll qualify. It still requires a SMARTS submission, an annual evaluation, and recertification each October 1.
What happens if my samples come back high?
An exceedance of a permit benchmark (a Numeric Action Level) moves you into an Exceedance Response Action. Level 1 is an evaluation and report; Level 2 adds an action plan and a technical report. A registered QISP has to certify the work. It is manageable, and we handle it. See the exceedance and ERA guide for how the process works.