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“The CSEP has given us the tools and confidence to stay out of the gun sites of the regulators in addition to reducing unnecessary BMPs on projects that without question have saved us money as a result.”

Tim Williams, General Superintendent
Fransen Pittman General Contractors
(CSEP Stage I, Top Performer)

In March of 2005, Stormwater Risk Management (SRM), a private consultancy, and the Colorado Water Quality Control Division (Division) created the Colorado Stormwater Excellence Program (CSEP) for the state’s building industries. The CSEP is the first industry-standardized Environmental Management System (EMS)-based compliance program of its kind in the nation. To serve and protect the interests of the environment, as well as the building industry, a distinctive blend of public and private partnerships was formed. Voluntary self-policing and minimal regulatory oversight make the CSEP a truly unique program.

The CSEP began in March 2005 as a pilot program with five of Colorado’s most prominent builders and developers and a high level of interest from the Division and the EPA. Stage I ended in July 2005, returning very promising results and, consequently, the pilot program was expanded in order to integrate additional improvements, broader participation and to prove sustainability over a prolonged period. Upon once again producing great results, the CSEP was incorporated into the State of Colorado’s Discharge Permit System and begin being duplicated in other regions of the United States. CSEP participation has grown to include both small, local-based companies as well as large, nationally-based building and development organizations.

The Associated General Contractors of Colorado (AGC) demonstrated its support by joining the partnership as the first trade association to help promote the CSEP for the benefit of all sectors within the construction industry. In addition, a select group of private sponsors who share a common interest in preserving water quality in the state also provide their support and assistance in promoting the program.

CSEP Principles
  1. Corporate Commitment
  2. Pollution Prevention & Compliance Assurance
  3. Measurable Results & Continuous Improvement
  4. Accountability Structures
  5. Enabling Systems

The concepts behind the CSEP are rooted in those of the Environmental Management System (EMS) but are intentionally targeted and standardized to promote the goal of widespread construction industry acceptance and ease of use to achieve maximum stormwater quality improvements. Traditional EMS programs address all environmental concerns and, to date, are the primary systems that the regulatory community will consider when determining the level of enforcement in an environmental action. EMS programs also provide a means for organizations to demonstrate their commitment to the environment when “green building” is an important consideration for the awarding of work. The greatest challenge in implementing an EMS is that tremendous resources and a great deal of time and effort can be spent creating them before organizations receive recognition or commercial advantage.

The CSEP utilizes a methodology that could potentially revolutionize the way EMS programs are implemented. By design, the EMS-based CSEP takes much of the burden off of those participating by pre-packaging its required elements and making them relatively simple and cost-effective for any organization to implement. By inserting the accountability aspect of third-party verification through an outside construction reviewer, along with performance scores and the other CSEP standard systems and tools, immediate results can be documented and proven to the regulatory community and environmentally conscious owners.

CSEP Standardized Tools
  1. Pre-construction Project Planning Systems
  2. Independent third-party initial inspection
  3. Independent third-party follow-up inspection
  4. Photo-driven inspection reporting
  5. Standardized E-impact™ scoring system
  6. 24-hour database, Internet access, storage & retrieval
  7. Regulation database (State, Watershed & MS4)
  8. Standardized performance reports
  9. CSEP-Pilot participation agreements
  10. CSEP- Pilot administration
  11. Standardized management system plan
  12. Standardized training & education
On behalf of the Division, the CSEP Administrator provides the principles, systems & tools to participants and helps facilitate and monitor their successful implementation.

There are 12 standardized tools within the CSEP that support the five guiding principles fundamental to the program. With assistance from a knowledgeable CSEP administrator or construction reviewer, participants can adopt each of the elements of the program, usually within 90 days or less, and begin experiencing the kind of results that may take others years to realize in a traditional EMS environment. By applying the standardized principles and tools of the EMS-based CSEP, an organization will be well on its way to creating a fully self-directed EMS.

CSEP-Pilot Stage I yielded extremely positive results for those companies adopting its standards and, as a result, proved to the regulatory community the effectiveness of a pre-packaged, industry sector standardized EMS-based program.

Proof Positive of CSEP Results

Six categories of performance were measured during the first stage of the Pilot Program using an objective-scoring matrix approved by the Division. The E-Impact ™ scoring matrix measurement tool is a five-point system applied to each finding discovered in the field during an initial monthly inspection of a project. A finding can be any item within a project’s stormwater management plan that does not conform to the requirements of the CDPS or presiding MS4 permit. Each finding is then assessed a score from one through five, depending upon its potential environmental impact, and is categorized by BMP type. A follow-up inspection occurs five days following the initial monthly inspection whereby the same items that were noted on the original report are checked to ensure corrective measures took place. If not corrected, the item is then re-scored using the same measurement matrix. It is the objective of a participant to reduce the initial score to a 0 (zero) on the follow-up report.

Due to the positive results of voluntarily self-policing, a credible scoring system and ancillary tools rooted soundly in a compliance-focused program, the regulatory community is able to get behind the CSEP model and provide its participants with tangible benefits, even when perfect performance is not always achieved. With compliance improvements in the CSEP-Pilot Stage I exceeding 50% in most measured categories, the program provides great promise and additional leadership opportunities for companies who desire to participate in the CSEP-Pilot Stage II.

Combined Total Results
(All Participants – Stage I & Stage II)
Category Measured
(Considers average for all jobsites)
Baseline After Two Years % Improvement
Average number of initial findings 9.05 4.66 48.51%
Average number of initial “more severe” findings 0.72 0.15 79.17%
Average number of uncorrected items found on follow-up 2.14 1.14 46.73%
Average number of “no attempt to correct” items found on follow-up 1.77 0.5 71.75%
Average initial E-Impact™ performance score 13.23 4.09 69.09%
Average follow-up E-Impact™ performance score 2.71 0.91 66.42%
The totals in each of the six measured categories reflect the efforts of twelve prominent General Contractors and one Property Developer. The data consists of over 800 individual jobsite inspections on 150 separate projects varying in size and complexity collected over a two-year period.