LEED CI 2009 SS p1 – Construction Activity Pollution Prevention

General Standard Practice

In general, complying with this prerequisite is standard practice in most urban and suburban areas, where most or
all of the US Environment Protection Agency (EPA) Construction General Permit (CGP) requirements have
been adopted and implemented at the state or county level. Regulators at those levels often threaten heavy fines
for not complying with CGP requirements, so most projects do so without the added incentive of the LEED
prerequisite.

Early on in project planning, compare your local code requirements to the CGP to determine which is more
stringent. If your local code is more stringent, then you will meet the prerequisite just by following that. If it is less
stringent, follow the CGP to achieve the prerequisite.

Create an ESC plan

The CGP extends compliance with the National Pollutant Discharge Elimination System (NPDES) stormwater
regulations to construction activities. It has three main categories that need to be addressed as you create an
Erosion and Sedimentation Control (ESC) plan:
 Prevent the loss of topsoil during construction.
o Proper staging of earth-moving activities and the preservation of mature vegetation can aid in
preventing topsoil loss and controlling stormwater pollutant discharge.
o Stabilization methods such as seeding, mulching, and the use of geo-textiles should also be included in
your plan.
 Prevent the sedimentation of receiving streams.
o Your plan should outline the placement of planned structural control measures such as silt fences,
drainage swales, and storm drain inlet protection.
 Prevent air pollution by particulate matter.
o Your plan should describe measures to prevent the tracking of soil onto paved surfaces off-site and the
generation of dust from construction vehicles—for example, gravel skirts at drive entries and exits,
transit ways for heavy vehicles, and wash stations for trucks.

Simply put, your ESC plan implements good housekeeping on a site-wide basis, minimizing the impact of
construction on local environmental resources and surrounding properties.

As written, the CGP applies to sites of one acre or larger. However, all projects pursuing LEED certification must
meet the requirements of the CGP, regardless of size.

Often the civil engineer is responsible for creating the ESC plan, which is then implemented by the general
contractor. Smaller projects may find the contractor is the one providing the plan, often one that is standard for
their company.

Documenting your plan

The ESC plan may be submitted as documentation, in the form of a site plan or a narrative report.
To demonstrate that your ESC plan was implemented, your projects will also be required to provide one of the
following:
 An inspection check list―signed, and dated periodically;
 Date-stamped photos of the following:
o measures to prevent topsoil loss including staging of earth-moving activities and stabilization
techniques;
o measures to prevent sedimentation of nearby streams including structural controls and inlet protection;
o measures to prevent air pollution including tracking control at entrances and exits.
 Description of corrective actions taken in response to problems with the performance of ESC measures.

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NC 2009 SSp1: Construction Activity Pollution Prevention

Pre-Design Phase

1. Review pages B-1 through B-4 of the EPA Construction General Permit (CGP) to determine the
applicable CGP requirements for all projects.

2. In regions where the EPA CGP is not standard practice, compare the local code with the CGP and make
adjustments, if necessary, to include all the CGP requirements.

3. Meeting the requirements of this prerequisite is standard practice in the U.S. and, therefore, no- or low-
cost for LEED.

4. The materials cost to implement these measures is minimal and can potentially save money by
preserving the vegetation and topsoil on-site.

5. Conduct a site evaluation to assess opportunities for minimizing the alteration of the natural stormwater
runoff patterns of your site and the disruption of mature vegetation, especially trees. This will save money and
time in terms of earth-moving and replanting vegetation.
6. Ask your civil engineer about soil types and what type of drainage you will have once the topsoil and
vegetation are disturbed.

Early Design Phase

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1. Establish who will create your ESC and stormwater pollution prevention plans. Usually, the civil
engineer creates them, and the contractor is responsible for their onsite implementation.

2. It is best to include your ESC plan in both project drawings and project specifications so that the
intention of the plan is clearly communicated to the project team, especially contractors and subcontractors.

3. Determine whether the 2003 EPA CGP or local erosion and sedimentation control standards are more
stringent―and follow the more stringent standards. Often the state department of environmental protection or
equivalent will have a written ruling on the comparison of the CGP standards and the local standards.

4. A good first step to determine which is more stringent is to review your local code to be sure it contains
at minimum the general categories contained in the CGP. If not, you’ll know that you need to follow the CGP.
If so, you’ll need to review your local code in detail to be sure that all of the requirements are included. The
general categories are as follows:
 allowable stormwater discharges
 allowable non-stormwater discharges
 limitations on coverage
 a stormwater pollution prevention plan
 releases in excess of reportable quantities
 treatment of spills

5. If local standards are equal to or more stringent than the CGP, you'll need to provide a narrative report
detailing this. Write the narrative when you do the comparison, so that it's fresh in your mind.

Design Development Phase

1. Create a draft ESC plan drawing or a narrative report that outlines how your project will comply with the
requirements of the CGP or the local standard.

2. Make sure that you use the same LEED project boundary as all other LEED credits your project is
attempting (this is particularly relevant with other Sustainable Sites credits).

3. A project drawing should include anticipated stormwater flows and indicate the location and type of any
planned ESC measures.

4. All written ESC plans must include the following:

 an introduction describing the standard being followed, existing site conditions, and responsible parties
 a list of the temporary and permanent control measures that will prevent loss of topsoil, sedimentation of
receiving streams and storm sewers, and air pollution by particulate matter
 details of the plan for implementation and ongoing maintenance to prove implementation, including one of
the following measures:
 A checklist or inspection report demonstrating implementation of your ESC plan and providing sample
dates, inspection frequency, at least three equally spaced inspections over the project timeline, and a
description of any corrective actions taken. (For LEED documentation, you need to upload this document
and have the builder or general contractor sign the LEED Online credit form.)

5. Date-stamped photos of implementation and corrective actions, as applicable, including at least three
photos from three different monthly inspections equally spaced over your project site's work timeline.
(For LEED documentation, you need to upload these images, but there is no specific required signatory for
this option.)
6. A narrative outlining the implementation and corrective action taken to effectively implement your ESC
plan. (For LEED documentation, you provide the narrative itself; there is no required signatory for this option.)

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7. Determine which path your project will follow to demonstrate implementation compliance: inspection
report, photos, or narrative report.

8. Photos are likely the easiest way to demonstrate compliance, unless an inspection report has already
been completed.

9. Develop a site-wide, earth-moving schedule to minimize the impact on established vegetation and to
stockpile topsoil and protect it from erosion. This can also complement your strategy to achieve SSc5.1: Site
Development—Protect or Restore Habitat, by limiting site disturbance and maintaining native vegetation.

10. Proper scheduling and staging of earth-moving activities can lower the costs associated with sediment
and erosion controls.

11. Retain as much of the existing vegetation as possible, not only to lower costs for replacements, but also
to decrease the cost of structural controls.

12. Careful implementation of the stormwater pollution prevention plan (SWPPP) by the contractor should
inform the design and installation of stormwater management systems onsite. This will enable those systems
to be integrated to the greatest extent possible during construction, preventing unexpected stormwater
discharges into receiving waterways.

13. If attempting one or both of the stormwater management credits SSc6.1 and SSc6.2 confirm with the
contractor that the SWPPP accurately represents the hydrologic characteristics of the site and is performing
as anticipated. Check on assumed infiltration rates, suspected rate and quantity of run-off to receiving
streams, and discuss potential storage options. Make changes to the stormwater management system
accordingly to improve its effectiveness and ensure that the credit calculations are accurate.

Construction Phase

1. Review all ESC project drawings and construction specifications prior to construction activities.

2. Verify that all ESC measures are in place before any construction activities begin.

3. The general contractor implements the ESC plan until construction is completed and all disturbed
areas have been stabilized.

4. Have a representative from the general contractor’s office onsite daily to monitor and implement
necessary measures laid out in your ESC plan.

5. The civil engineer, contractor, or a third party should inspect your ESC plan measures on a weekly
basis (bi-weekly if inspections are also conducted after any weather event involving more than 0.5 inches of
rain) to include the following:
 submit status reports on ESC plan implementation - these reports should include labeled and
dated photographs
 Weekly inspection log
 A narrative report describing the performance of the measures implemented

6. Provide corrective actions immediately after any rain event.

7. Corrective actions can range from adjusting the placement of silt fencing and removing debris from
stormwater catchment basins to replanting areas of temporary seeding and adding material to gravel skirts at
entrances and exits.
8. Preserve existing vegetation, especially mature trees, whenever possible. This will decrease costs for
temporary stabilization measures and erosion controls. In addition, the vegetation may also be used as part of
your landscaping plan.

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9. After completion of all construction activities, document credit compliance in LEED Online by uploading
these documents:
 A narrative that declares the standard followed (2003 EPA CGP or local). If you used a local standard,
write a narrative report detailing how it is equal to or more stringent than the CPG (Phases I and II,
NPDES program).
 A written ESC plan or project drawings showing the control measures used.
 Proof of implementation with the following:
 an inspection report with the required signature
 nine photos
 a narrative report

Updated: November 30, 2011

LEED NC 2009 SSp1 Const Activity Pollution Prevention

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