What to Expect When CDMS Handles Your SWPPP

Most people don’t come to us at the start of a clean project. They inherited the stormwater file when someone left. Their consultant retired, or got hard to reach. They took over compliance a few months ago and are still figuring out what they’re responsible for. If that’s you, the first thing worth knowing is that handing this off is a normal, defined process. You don’t need to understand every part of the Industrial General Permit to get back into compliance. You need to know what we’ll ask you for, what we take care of, and what’s still yours to do.

Here’s what the SWPPP process looks like when CDMS handles it, from the first call through your first full sampling season.

For the bigger picture of how all the pieces fit together, see our SWPPP and stormwater compliance services in California overview. This piece stays focused on what working with us actually feels like.

Before We Start: What We’ll Ask You For

We can’t write a Stormwater Pollution Prevention Plan in a vacuum. The plan has to describe your facility, your processes, and your materials accurately, because that’s what an inspector or the Regional Water Quality Control Board compares against what they see on site. So before we draft anything, we gather a set of inputs from you.

We’ll ask for:

• Your SMARTS login (SMARTS is the state’s online stormwater reporting portal). We get added as a data entry person so we can do the work.
• Your Legally Responsible Person (LRP) details. This is whoever has authority to certify filings for your company.
• A copy of your current SWPPP and your previous Notice of Intent, if they exist.
• Your facility drawings (CAD files are ideal) and your current chemical inventory.
• Your SIC (Standard Industrial Classification) or NAICS (North American Industry Classification System) codes.
• Any significant spills or leaks from the last five years.
• The people who will fill your Pollution Prevention Team roles.

If you can’t find half of this, that’s fine, and it’s useful information on its own. When we take over a SWPPP someone else wrote, the gaps in the old file usually tell us where the previous provider stopped paying attention. We work from what you have and fill in the rest by talking with your team.

The Process, Step by Step

Every facility is a little different, but the path looks like this.

1. First conversation and quote. We talk through your permit status, building and property size, your industrial processes, your discharge points, and whether you already have a SWPPP and a SMARTS connection. Stormwater is compliance-mandated work, so there’s no qualifying hoop to jump through. We move straight to scope and a fixed-price quote, with a timeline included. The variables we scope against are laid out in what drives SWPPP cost.
2. We gather your information. You send us the inputs above. We review them and follow up on anything missing or unclear. This is the part that needs you most, and it’s mostly front-loaded.
3. We confirm your coverage and file what’s needed. If you need to be enrolled under the permit, we prepare and file the Notice of Intent. If your facility might qualify for a No Exposure Certification (NEC) instead of full permit coverage, we evaluate that first. A majority of our stormwater clients qualify for NEC, which is a lighter path. Either way, we set up or clean up your SMARTS account so the rest of the year runs smoothly.
4. We write the SWPPP. This is the document itself: your company profile, site maps, industrial materials list, an assessment of potential pollutant sources, your Best Management Practices (the permit requires a minimum of seven), and your monitoring plan. A registered Qualified Industrial Stormwater Practitioner (QISP) on our staff handles the technical certification where the permit calls for it.
5. We build your monitoring plan and send your sampling kits. Your plan spells out where you sample, what you sample for, and how often. We ship turnkey sampling kits to your facility: bottles, chain-of-custody forms, pH strips, a cooler, and instructions. More on how this works below.
6. First sampling season. When it rains and a storm qualifies, your team collects the samples. You’re already on site, so there’s no waiting for a technician to show up. You ship the samples to the lab. We coordinate the lab work, interpret the results, and prepare everything for reporting.
7. Reporting and the annual report. We load your results into SMARTS within the reporting window and prepare your annual report. We’ll walk through one piece of this that surprises people in a moment.

What You’re Actually Handing Off

The plan assigns five Pollution Prevention Team roles: an Implementation Manager, plus people responsible for sampling, site evaluation, the annual report, and recordkeeping and maintenance. Each role gets a primary and an alternate. That sounds like a lot of org chart for a small facility, and it can feel that way when you’re reading an inherited SWPPP for the first time.

In practice, most of those functions sit with us once you hand the work off. Your team’s real day-to-day job narrows to two things: collect the samples when it rains, and keep your team contacts current. We handle the plan, the monitoring design, the lab coordination, the reporting, and the annual evaluation. The most common relief we hear from people who just took this over is that the list of things they personally have to track gets short and predictable.

The Two Things That Stay Yours

Two parts of this process can’t be fully handed off, and it’s better to know that going in.

Sample collection. You collect the samples because you’re on site and the rain doesn’t wait for a scheduled visit. This is also why we use kits instead of sending a field technician. When consultants drive out to sample, there often isn’t enough rain to collect anything, and the client gets charged for the dry visit anyway. The kit model takes that cost and that uncertainty off the table. We cover what qualifies as a sampleable storm and how the collection works in more detail in our guide to SWPPP sampling in California.

The final submit click in SMARTS. The State Water Board requires your LRP to log in and submit certain filings personally. We prepare everything, line it up, and tell you exactly what to click, but the Water Board will not let us hit submit on your LRP’s behalf. We work around your LRP’s schedule so deadlines aren’t a scramble. Our guide to SMARTS reporting for California stormwater permits explains which filings need that LRP signature and which don’t.

After the First Year

The stormwater year runs July 1 through June 30, with the annual report due July 15. Once your first season is behind you, the work settles into a rhythm. We send kits ahead of the season, you sample through the rainy months, we report results and file your annual report, and we recertify your NEC each year if that’s your path.

We also reach out near the end of each season to line up the next one. As a rule, we contact our clients before the Water Board sends its notifications, so you’re not reacting to an agency email. If your results ever come back above a benchmark, the process changes and there are added steps and deadlines, but that’s a separate path we’ll walk you through if and when it happens.