Robert, if you are willing to take a serious look at the direction we are taking our industry in this regard I am more than willing to bring up examples of other industries.
I have quite a few of them, but we an address them individually starting with the construction industry.
I know the little catch-phrase "nothing down the drain but r@in" sounds great. But that is not, in fact, how it works in reality. If "nothing" was allowed down the drain but r@in, then there would be no need for NPDES permits because nothing would be permitted.
The first industry we can discuss is the
construction industry.
How many construction sites have you seen with vacuum systems and large filter systems set up to treat runoff prior to the storm drain? That's right, they don't exist. A construction site is a TEMPORARY and potentially HIGH IMPACT zone, yet they are ALLOWED to let gravity filtered runoff enter the storm drain, whether that runoff is the result of a storm or if it is incidental to the work, i.e. dust control, vehicle wash without soap, etc. They are allowed this because the law states that contaminants be reduced to the GREATEST EXTENT PRACTICABLE. That means if is isn't cost effective or if it doesn't make sense to build gigantic filtering systems onsite, then it is not to be required.
Mobile contract cleaners are also TEMPORARY in their time onsite. But we are a LOW IMPACT industry using the power of pressure to clean rather than high volumes of water with the exception of your colleague and fellow PWNA chair, Mr. Gamble who likes to GAMBLE with the fire equipment and use a fire hose for rinsing to make more profit.
If the construction orgs could come up with something reasonable, simple, inexpensive and sensible for their members, then why haven't you done the same for us?
Here is the BMP for the California Stormwater Quality Association.
http://www.cabmphandbooks.com/Documents/Construction/SE-10.pdf
And also, if the authorities themselves are using gravity filtration to deal with all contaminants during the massive flow of a storm, then why in the world have we not been working on convincing them for the past 15 years that we, too, can deal with runoff using the same layers of filtration to deal with a measly 5-11 gallons per minute while cleaning?????
http://www.cabmphandbooks.com/Documents/Development/TC-40.pdf
Thank you.