Often, when a builder gets in trouble with faulty stormwater regulatory compliance, one enforcement tool used by regulators and judges is to order the builder to attend stormwater training. I think proper training is an important element in any company’s stormwater management program.

But who really needs this training?

Over the decades we’ve been in business, we’ve found that the root cause of most recalcitrant stormwater permit violations is lack of a corporate commitment to achieve compliance. A failure of corporate strategy.

Where does this lack of commitment come from?

With few but the most radical exceptions, corporate resistance to compliance is usually not due to a desire to openly resist environmental laws. Instead, most resistance comes from a lack of understanding and awareness of regulatory expectations at the corporate level.

There are obviously many other contributing factors such as, cost, competitive pressures, lack of established compliance systems, low or no penalties, etc., that play a role. And lots of bad excuses too. Training, however, can’t address these other issues anyway.

So how can training affect the root cause of non-compliance?

To really solve the recalcitrant violator problem, whenever training is prescribe by regulators or judges, training should be required in this order:

1. Corporate Executive training
2. Preconstruction Services and Estimator training
3. Project Management training
4. SWPPP Administrator and field force training.

The training does not need to be very different for any of these groups, so it can be provided to all groups at once (which is time- and cost-effective). When companies we work with voluntarily take this approach, we know we are going to see excellent results in day-to-day field compliance on all projects.

Can anyone make the argument that this enforcement approach would not have a profound and positive impact on the culture of compliance at a company and ultimately on the results in the field?

In our experience, they can’t.