Services: Comprehensive and Individual
QSP/QSD Training Classes
The Keish Environmental team lead, Rachael Keish, is one of only 121 CASQA Trainers of Record in the state of California. Based on her expertise in construction stormwater, she can offer the state mandated 2-3 day training sessions to qualify others as Qualified SWPPP Practitioners/Developers.
Keish Environmental offers complete SWPPP training either formally for Qualified SWPPP Practitioners/Developers or informally with brown bag and tailgate type presentations. Contact us to learn more about our training sessions - available offsite or at client facilities - as well as discounted rates for groups.
Construction Management: Permit Compliance Oversight and Inspection
Few issues are more critical than ensuring that a project is constructed in accordance with contract plans, specifications, permits and environmental document commitments. Our team has extensive experience in coordination between diverse stakeholders and in handling noise, vibration, dust, migratory nesting birds, sensitive status animal/plant, and cultural resources issues - including coordination with Native American Most Likely Descendants. When unexpected discoveries of human bones trigger sensitive handling of earthwork on a construction site or a raptor nests near a work area, it takes an experienced and sensitive team to draw together the regulators, biologists, planners, archaeologists, engineers and contractor to ensure a productive and quick resolution to field issues and move the project forward.
Understanding the areas of overlapping jurisdiction and knowing the right agencies to approach with specific project needs are critical to ensuring that environmental concerns are addressed and capital projects are kept on schedule. Our on-the-ground field experience and familiarity with typical CM requirements for daily diaries, measurement of field quantities, and attention to detail required in the plans, specifications, and project permits make us the ideal choice for construction management, inspection and permit oversight needs. Keish Environmental is sensitive to the lines of communication requirements for construction contracts, and is careful not to direct the contractor or dictate their means and methods when conducting oversight inspections or making recommendations.
Regulatory agency permit conditions will often apply for projects in sensitive habitats or with work near creeks. Typically permits must be obtained from the CA Department of Fish and Wildlife (Lake and Streambed Alteration Agreement), Regional Water Quality Control Board (401 Water Quality Certification), U.S. Army Corps of Engineers (Section 404 Permit, with associated NOAA Fisheries and US Fish and Wildlife Service Biological Opinions/Letters of Concurrence) for any work in a riparian corridor or wetland. Our personnel have assisted with permit compliance monitoring on more than 15 creek diversions in the Bay Area’s most sensitive habitat streams, keeping projects in full compliance with permit conditions and reporting requirements.
By leveraging Keish Environmental relationships and reputation for excellence in construction inspection and environmental compliance oversight, our staff helps keep projects moving forward and on budget.
Regulatory Liaison: Permitting, Monitoring, and Reporting
The permitting environment is only getting more complex and stringent. For construction projects, it is more critical than ever to provide clients with knowledgeable technical staff to train and assist in compliance with the many NPDES permits, such as the Construction General Permit for Storm Water, Phase 1 and Phase 2 Municipal Storm Water permits, Dewatering permits for Structures and VOC impacted groundwater - the list goes on and on! With one of 121 CASQA Trainers of Record under the CGP on staff, Keish Environmental can guide agencies and assist contractors in getting training needed to keep clients in full compliance with current and newly-phased-in regulations.
Our staff has also assisted clients when they are affected by new NPDES permits, such as the 2013 Small Phase 2 MS4 permit which took effect in July 2013. Keish Environmental drafted the Storm Water Program Guidance Document for the VTA when they were regulated and assisted them with the organizational structure to implement the new permit. Our staff has also applied for and obtained authorization to discharge groundwater under the RWQCB Structural Dewatering Permit and are aware of the stringent monitoring required for that as well as the VOC impacted groundwater discharge permit. With 14 years of experience overseeing complex public infrastructure projects, Keish Environmental can assist our clients in navigating the complex permitting environment and serve as a regulatory liaison to keep projects on schedule and in full compliance with the laws and regulations that protect the environment.
Keish Environmental also has an excellent track record of working with the regulatory agencies to implement creative workarounds when unexpected field issues arise and there is very little time to modify the permits. Our personnel have diverse experience in design, program, and construction management and know the regulatory framework related to NEPA/CEQA, NPDES permits, and jurisdictional agency (RWQCB, Corps, CDFW, USFWS, NOAA Fisheries) permits, agreements and biological opinions. When a new issue arises, staff can draw on this practical experience and relationships with regulatory staff to quickly determine the stakeholder and project needs, research the technical issues in question with the agencies and the contractor, and reach timely issue resolution.
Design Integration and Construction Document Preparation
Environmental documents and reports are not written in contractor's terms; they are written to be understood by the layperson, agencies and regulators. Achieving SWPPP, permit and environmental compliance in the field starts with excellent plans, specifications, and estimate (PS&E) packages. A Contractor needs to be informed succinctly in these documents of the relevant issues, what handling requirements and protections are needed, and what quantities to include in their bid - along with how they will be paid. It is also critical that the quantities provided are accurate. It takes someone experienced with construction management and implementation who has overseen public, low-bid projects on behalf of the client to ensure that environmental requirements are correctly written into project plans, specifications and estimate packages for public works. The design documents must include temporary water pollution control BMPs, permanent erosion control measures, and permanent water quality treatment facilities to ensure compliance is readily achieved by contractors.
On a typical project, contractors are much more willing to implement SWPPP BMPs and environmental mitigation measures with a unit price wherever a quantity is physically measurable, such as: linear feet of fiber rolls/silt fence, individual construction entrance/exits, and linear feet of wildlife exclusion fence. Omission of separate pay items can leave owners exposed and contractors searching for ways to efficiently construct the project. Keish Environmental ensures that adequate quantities of BMPs are included in PS&E packages so that the contractor will be equitably paid for compliance work to fully implement the NPDES requirements.
In addition, Keish Environmental staff focuses on customizing specifications to require the preferred format for the SWPPP when it is generated by the contractor. Our specifications outline in detail the requirements to ensure a quality submittal is received the first time. This in turn speeds the SWPPP review process and enables faster coverage under the CGP.
Keish Environmental staff capabilities in this area are extensive, and we understand how agency staff, designers, planners, regulators, and the contractor need to communicate to be effective on a project. Previous experience includes drafting boilerplate Environmental Coordination and Cooperation specifications for the VTA, in addition to Technical Specifications for several Caltrans Highway Projects in the cities of San Jose, Milpitas, and Fremont and for the Blackberry Farm Restoration Project Phase 1 in the city of Cupertino. Our skills were key in developing the Environmental Requirements specification for the VTA's BART Silicon Valley Berryessa Extension (SVBX) $700M Design-Build RFP, and we assisted with preparation of the hazardous materials specifications for that RFP. These projects illustrate communication of critical issues during the procurement process, so that change is managed from bid time through construction. Our services have been invaluable in keeping public projects on time and on budget.
Envision Institute for Sustainable Infrastructure (ISI) Project Certifications
Envision is a sustainability rating system comparable to LEED, but with 60 sustainability criteria geared toward public/infrastructure projects. It provides a holistic framework for evaluating and rating the community, environmental, and economic benefits of all types and sizes of infrastructure projects. It evaluates, grades, and gives recognition to infrastructure projects that use transformational, collaborative approaches to assess the sustainability indicators over the course of the project's life cycle.
Envision can be used by infrastructure owners, design teams, community groups, environmental organizations, constructors, regulators, and policy makers to:
- Meet sustainability goals.
- Be publicly recognized for high levels of achievement in sustainability.
- Help communities and project teams to collaborate and discuss, "Are we doing the right project?" and, "Are we doing the project right?".
- Make decisions about the investment of scarce resources.
- Include community priorities in civil infrastructure projects.
The Envision tools help the project design team:
- Assess costs and benefits over the project lifecycle.
- Evaluate environmental benefits.
- Use outcome-based objectives.
- Reach higher levels of sustainability achievement.
The Keish Environmental team lead, Rachael Keish, is an ISI credentialed Envision Sustainability Professional (ENV SP). Ms. Keish can assist clients and project teams in achieving higher levels of sustainability, documenting project sustainability accomplishments, and submitting the projects for ISI Envision recognition and awards.
Storm Water Pollution Prevention Plans (SWPPPs)
One critical area for a successful project is water quality, and correct implementation of a stormwater pollution prevention plan (SWPPP) is key. The water quality regulatory environment is complex, with overlapping jurisdictions including the statewide Construction General Permit for Storm Water (NPDES Order #2009-0009-DWQ), the Municipal Regional Permit (NPDES Order# R2-2009-0074) for work within Bay Area city/county right-of-way, the Small Phase 2 Municipal Regional Permit (NPDES Order# 2013-0001-DWQ ) for work on special district facilities (e.g. BART, VTA), and the Caltrans NPDES permit for any projects that affect state highway facilities (Order No. 2012-0011-DWQ). In addition there are separate statewide Industrial Stormwater Permit requirements that may affect certain clients, and there may be site specific dewatering permits required for some situations. Our team has prepared SWPPPs and other NPDES permit applications using city, CASQA and Caltrans standard formats and strives for a 'No Exceptions Taken' disposition on the first review so work can start more quickly.
The Keish Environmental team specializes in implementing requirements of the Construction General Permit (CGP) and offers complete SWPPP support, including writing SWPPPs, performing reviews of contractor’s SWPPPs, performing field stormwater compliance inspections, and pH and turbidity sampling.
Keish Environmental experts can assist with compliance inspections for correct best management practice (BMP) implementation as required by the CGP. This includes inspections weekly, before storm, each day during rain, and after storms. We also provide non-stormwater inspection and required pH and turbidity sampling. Most construction projects will be classified as traditional, Risk Level 1 or Risk Level 2 depending on local watersheds and soil types. As such, pH and turbidity sampling must be performed by a Qualified SWPPP Practitioner (QSP) or trained person at every point where stormwater discharges from a project - and this can be very time consuming.
Once collected, all data must then be individually entered into the State Water Resources Control Board's Stormwater Multiple Application and Report Tracking System (SMARTS) and summarized in an Annual Report. Keish Environmental can support data management in SMARTS, assisting the Contractor, Authorized Signatory, or Legally Responsible Person with project compliance under the CGP.
