Widespread failure to comply with US storm water regulations for industry - Part II: Facility-level evaluations to estimate number of regulated facilities

This research evaluated compliance with U.S. pollution prevention regulatio ns from storm water discharges associated with industrial activities, focus ing on facilities that had failed to complete first-stage compliance requir ements ("filed") approximately 5 years after the regulations took effect. T he number of facilities is not readily estimated because the regulatory str ucture requires facility-specific determination of requirement to comply ba sed on factors not included in publicly available data. The research estima ted the proportion of identifiable facilities actually subject to regulatio ns using the universe of potentially covered California facilities develope d in Part I of this research. Researchers mailed information to about 3,600 nonfiling facility operators to request they determine whether their facil ities were included. Researchers then independently assessed inclusion for several samples of about 200 facilities in the Los Angeles region. Results suggested about half of the identified mandatory-compliance manufacturing f acilities probably should comply, and at most half of those had filed throu gh the first 5 years of the permit. The ability or willingness of facility operators to correctly assess inclusion was limited; about one-fourth of fa cility operators claiming nonapplicability were incorrect, and over one-thi rd of contacted facilities failed to respond to mailings. Telephone intervi ew techniques reliably assessed inclusion for many facilities but left unde termined a large proportion of identified facilities. Field verification su ggested over one-fourth of nonresponding facilities conducted industrial ac tivities outdoors where pollutants were exposed to storm water, and were pr obably subject to regulations, including a significant portion of facilitie s whose coverage was undetermined by telephone methods.