Agencies responsible for enforcing regulations on storm water discharges as
sociated with industrial activities widely suspect that many facilities obl
igated to comply have failed to complete the first stage of requirements, s
elf-identification to regulatory agencies. This research attempted to estim
ate the number of facilities, and the proportion of facilities that may be
identified through publicly-available business lists, that should comply wi
th Clean Water Act storm water requirements but have not yet recognized the
ir duty to comply. Mail communication to more than 3,500 California facilit
ies resulted in 9% of contacted facilities signifying their intent to compl
y. Direct first-hand telephone surveys of 149 facilities suggested as many
as 25% of the remaining facilities-those that failed to respond to the mail
ing, and those that claimed nonapplicability-apparently should comply with
the regulations. Field verification site visits to another 159 facilities s
uggested as many as half of the same facilities (non-respondents and those
claiming non-applicability) apparently should comply. These included many o
f the facilities whose phone responses did not suggest a need to comply. Fa
cilities claiming non-applicability by mail were comparable to non-respondi
ng facilities in several observed characteristics relevant to pollutant dis
charges, such as types of industrial activities.