Should the Practice of ESC Be Restricted to Professional Engineers?
A long-time practitioner looks at differences in training and experience
"Should the practice of erosion and sediment control be restricted to professional engineers?" To the casual reader, that question may seem a little pointless, considering that the overwhelming majority of erosion and sediment control (ESC) plans have been, are, and will continue to be prepared by engineers. Another element that clouds the question for the layman is the similarity in appearance between erosion and sediment control plans and engineering plans. The common conclusion is, "If it walks like a duck and squawks like a duck, it must be an engineering practice."
Actually, engineers as a group are latecomers to the practice of erosion and sediment control. They were largely absent from the practice during the first 70-odd developmental years of erosion and sediment control activities in this country.
With the exception of regions where water quality had a long history of commercial value—the Pacific Northwest, for example, and the Chesapeake Bay area—erosion and sediment control was not a common part of the American vocabulary. That changed radically during the Dust Bowl of the 1930s. The magnitude of the national disaster brought to light the need to safeguard natural resources that had previously been taken for granted.
The initial emphasis of the concern, and the resulting laws, were on soil. That emphasis gave birth to the US Department of Agriculture's Soil Conservation Service (SCS). At the state level, it spawned the Soil Conservation Districts. Because the disaster originated with the rural agricultural practices of the day, the combined corrective efforts of the federal service and the state districts focused there. Experts from a wide array of disciplines (geologists, soil scientists, climatologists, conservationists, geomorphologists, and other experts in the earth sciences) became involved in researching the roots of the problem of soil conservation and devising control practices.
Not too far into the effort, it was discovered that, while wind erosion was the prime mover of the Dust Bowl disaster itself, stormwater runoff had an equal and often greater overall adverse impact on soil loss. Hydrologists and specialists in hydraulics, stream flow, and stream morphology came onboard to add their skill to the task. A whole new category of control practices was developed and added to the growing mix while expertise in erosion control evolved.
With the involvement of stormwater specialists came another revelation. Soil was not the only resource placed at risk by erosion. Eroded soils ended up primarily in the waters of the nation. Sediment was found to be a great detractor from water quality as well as an extremely and increasingly expensive maintenance problem. In recognition of this new area of concern, the Soil Conservation Districts became Soil and Water Conservation Districts, and ultimately the venerable SCS renamed itself the Natural Resources Conservation Service. Sediment control was added to erosion control as another crucial environmental practice, and the experts in erosion control embraced the art of sediment control to complete the package.
As experts in the field of erosion and sediment control, along with their partners in the agricultural industry, began to succeed in their rural efforts, they observed that water quality was not improving at the same rate as rural erosion and sediment control was succeeding. Looking beyond the rural boundaries, studies by the EPA and others brought to light the fact that there was also an urban component. The runoff from urban construction sites was generating from 100 to 10,000 times the sediment yield as equivalent agricultural areas. Agriculture, even with well-designed control practices in place, continues to generate the largest annual volume of sediment simply because of the vast amount of land under cultivation. Construction, on the other hand, because it is a more violent and invasive form of disturbance, is equally damaging.
Public opinion and the advice of experts in the field of erosion and sediment control convinced Congress that remedial steps were necessary in urban areas. The technology and expertise developed in well over a half-century by specialists working in the field was readily adaptable to the urban landscape. The natural forces causing erosion are the same in urban locations as they are in rural settings. The practices that successfully limit erosion in farm country work equally well in the city. The sediment generated by urban erosion is the same as that generated by the rural counterpart. Sediment-trapping techniques work equally well on either side of the city limits. Where the mesh is not perfect, someone with the requisite expertise can adapt an existing practice or devise a new one to fit the situation. Urban erosion and sediment control, especially on construction sites, was deemed necessary, and this in part led to the EPA's promulgation of Phase I of the National Pollutant Discharge Elimination System (NPDES), which moved erosion and sediment control into cities and urbanizing areas in 1992.
This action on the part of the political leadership of the nation created a tremendous logistical problem. Requiring erosion and sediment control for every construction site disturbing 5 or more acres brought literally thousands of projects into the program simultaneously. The overwhelming number of construction projects—existing, pending, and planned—covered by the mandate for erosion and sediment control was far beyond what the number of experts in the field could deal with. Most of the experts in erosion and sediment control at that time were in government service, and compliance with the NPDES regulations is a task for the private sector. Until the regulations became a reality, there was little incentive within the private sector to invest in the necessary education and training. Because expertise in the field is something that requires years to develop, waiting for the mandate to be in place allowed too little time to significantly expand the numbers of qualified individuals.
When writing technical regulations, agencies at the federal and state levels generally know, based on the topic, what community of qualified professionals will be made responsible for their implementation. In the case of erosion and sediment control, the clear choice, certified professionals in erosion and sediment control (CPESCs), simply did not and do not exist in sufficient numbers to satisfy the demand. There was perhaps one CPESC available for every 50 or so projects. The agencies found themselves in the unusual position of having to inventory the available options. There were not many.
The CPESC program draws heavily on a wide variety of disciplines, such as geology, soil science, natural resource science, natural resource management, and geomorphology, along with agricultural, environmental, and civil engineering. But no single field provides all the information necessary. A degree in geology, for example, indicates expertise in geology—which is just one element of ESC. Expertise in one field does not automatically confer expertise in another. There is no undergraduate degree in erosion and sediment control. ESC is unique in that it is a professional field that must be actively pursued by the individual without conventional institutional aid. Expertise must be earned in erosion and sediment control because there is no formal mechanism to grant it.
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The agencies were faced with the dilemma of having a very large number of people with some of the necessary skills but very few with all of them. They took the only course that was available to them: They left the field virtually wide open. The Ohio NPDES general construction permit, for example, states that the erosion and sediment control plans must be prepared "by a professional experienced in the design and implementation of standard erosion and sediment controls and stormwater management practices." The Commonwealth of Virginia, a leading state in the development of erosion and sediment control, states, "The owner or lessee may designate someone (e.g., an engineer, architect, contractor, etc.) to prepare the [ESC] plan . . ." (Virginia Erosion and Sediment Control Handbook 1994). In addition to CPESCs, other regulations open the practice to landscape architects and conservationists. Literally anyone accustomed to working with and reshaping topography and the underlying soil was welcome to try his or her hand at the erosion and sediment control tasks required by NPDES.
As a matter of expediency, the bulk of the work fell to the engineering community. By law, there is at least one, often several, and occasionally many, engineers involved in every single land development project. Most developers had never heard of a CPESC, but every owner of land development projects had an engineer or two on staff or maintained a working relationship with one or more engineering firms to satisfy project needs. It was a simple matter, when erosion and sediment control came along, to add that to the cost of engineering services. It did not really matter that erosion and sediment control is not engineering. On paper, it looks like engineering and the engineers, quite naturally as businessmen, were more than happy to undertake the additional work.
This windfall to the community was not an unmixed blessing. Not for all, but certainly for the vast majority of the design community, the promulgation of NPDES in 1992 was the first exposure of urban civil engineers to the subject of erosion and sediment control. The inclusion of erosion and sediment control as a mandatory element of construction projects did not take the design community by surprise (obviously—since the subject had been looming on the horizon for nearly a decade before it arrived on the scene) but it did catch the community technically unprepared.
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March-April 2005
Should the Practice of ESC Be Restricted to Professional Engineers?
A long-time practitioner looks at differences in training and experience
"Should the practice of erosion and sediment control be restricted to professional engineers?" To the casual reader, that question may seem a little pointless, considering that the overwhelming majority of erosion and sediment control (ESC) plans have been, are, and will continue to be prepared by engineers. Another element that clouds the question for the layman is the similarity in appearance between erosion and sediment control plans and engineering plans. The common conclusion is, "If it walks like a duck and squawks like a duck, it must be an engineering practice."Actually, engineers as a group are latecomers to the practice of erosion and sediment control. They were largely absent from the practice during the first 70-odd developmental years of erosion and sediment control activities in this country.
With the exception of regions where water quality had a long history of commercial value—the Pacific Northwest, for example, and the Chesapeake Bay area—erosion and sediment control was not a common part of the American vocabulary. That changed radically during the Dust Bowl of the 1930s. The magnitude of the national disaster brought to light the need to safeguard natural resources that had previously been taken for granted.
The initial emphasis of the concern, and the resulting laws, were on soil. That emphasis gave birth to the US Department of Agriculture's Soil Conservation Service (SCS). At the state level, it spawned the Soil Conservation Districts. Because the disaster originated with the rural agricultural practices of the day, the combined corrective efforts of the federal service and the state districts focused there. Experts from a wide array of disciplines (geologists, soil scientists, climatologists, conservationists, geomorphologists, and other experts in the earth sciences) became involved in researching the roots of the problem of soil conservation and devising control practices.
Not too far into the effort, it was discovered that, while wind erosion was the prime mover of the Dust Bowl disaster itself, stormwater runoff had an equal and often greater overall adverse impact on soil loss. Hydrologists and specialists in hydraulics, stream flow, and stream morphology came onboard to add their skill to the task. A whole new category of control practices was developed and added to the growing mix while expertise in erosion control evolved.
With the involvement of stormwater specialists came another revelation. Soil was not the only resource placed at risk by erosion. Eroded soils ended up primarily in the waters of the nation. Sediment was found to be a great detractor from water quality as well as an extremely and increasingly expensive maintenance problem. In recognition of this new area of concern, the Soil Conservation Districts became Soil and Water Conservation Districts, and ultimately the venerable SCS renamed itself the Natural Resources Conservation Service. Sediment control was added to erosion control as another crucial environmental practice, and the experts in erosion control embraced the art of sediment control to complete the package.
As experts in the field of erosion and sediment control, along with their partners in the agricultural industry, began to succeed in their rural efforts, they observed that water quality was not improving at the same rate as rural erosion and sediment control was succeeding. Looking beyond the rural boundaries, studies by the EPA and others brought to light the fact that there was also an urban component. The runoff from urban construction sites was generating from 100 to 10,000 times the sediment yield as equivalent agricultural areas. Agriculture, even with well-designed control practices in place, continues to generate the largest annual volume of sediment simply because of the vast amount of land under cultivation. Construction, on the other hand, because it is a more violent and invasive form of disturbance, is equally damaging.
Public opinion and the advice of experts in the field of erosion and sediment control convinced Congress that remedial steps were necessary in urban areas. The technology and expertise developed in well over a half-century by specialists working in the field was readily adaptable to the urban landscape. The natural forces causing erosion are the same in urban locations as they are in rural settings. The practices that successfully limit erosion in farm country work equally well in the city. The sediment generated by urban erosion is the same as that generated by the rural counterpart. Sediment-trapping techniques work equally well on either side of the city limits. Where the mesh is not perfect, someone with the requisite expertise can adapt an existing practice or devise a new one to fit the situation. Urban erosion and sediment control, especially on construction sites, was deemed necessary, and this in part led to the EPA's promulgation of Phase I of the National Pollutant Discharge Elimination System (NPDES), which moved erosion and sediment control into cities and urbanizing areas in 1992.
This action on the part of the political leadership of the nation created a tremendous logistical problem. Requiring erosion and sediment control for every construction site disturbing 5 or more acres brought literally thousands of projects into the program simultaneously. The overwhelming number of construction projects—existing, pending, and planned—covered by the mandate for erosion and sediment control was far beyond what the number of experts in the field could deal with. Most of the experts in erosion and sediment control at that time were in government service, and compliance with the NPDES regulations is a task for the private sector. Until the regulations became a reality, there was little incentive within the private sector to invest in the necessary education and training. Because expertise in the field is something that requires years to develop, waiting for the mandate to be in place allowed too little time to significantly expand the numbers of qualified individuals.
When writing technical regulations, agencies at the federal and state levels generally know, based on the topic, what community of qualified professionals will be made responsible for their implementation. In the case of erosion and sediment control, the clear choice, certified professionals in erosion and sediment control (CPESCs), simply did not and do not exist in sufficient numbers to satisfy the demand. There was perhaps one CPESC available for every 50 or so projects. The agencies found themselves in the unusual position of having to inventory the available options. There were not many.
The CPESC program draws heavily on a wide variety of disciplines, such as geology, soil science, natural resource science, natural resource management, and geomorphology, along with agricultural, environmental, and civil engineering. But no single field provides all the information necessary. A degree in geology, for example, indicates expertise in geology—which is just one element of ESC. Expertise in one field does not automatically confer expertise in another. There is no undergraduate degree in erosion and sediment control. ESC is unique in that it is a professional field that must be actively pursued by the individual without conventional institutional aid. Expertise must be earned in erosion and sediment control because there is no formal mechanism to grant it.
The agencies were faced with the dilemma of having a very large number of people with some of the necessary skills but very few with all of them. They took the only course that was available to them: They left the field virtually wide open. The Ohio NPDES general construction permit, for example, states that the erosion and sediment control plans must be prepared "by a professional experienced in the design and implementation of standard erosion and sediment controls and stormwater management practices." The Commonwealth of Virginia, a leading state in the development of erosion and sediment control, states, "The owner or lessee may designate someone (e.g., an engineer, architect, contractor, etc.) to prepare the [ESC] plan . . ." (Virginia Erosion and Sediment Control Handbook 1994). In addition to CPESCs, other regulations open the practice to landscape architects and conservationists. Literally anyone accustomed to working with and reshaping topography and the underlying soil was welcome to try his or her hand at the erosion and sediment control tasks required by NPDES.
As a matter of expediency, the bulk of the work fell to the engineering community. By law, there is at least one, often several, and occasionally many, engineers involved in every single land development project. Most developers had never heard of a CPESC, but every owner of land development projects had an engineer or two on staff or maintained a working relationship with one or more engineering firms to satisfy project needs. It was a simple matter, when erosion and sediment control came along, to add that to the cost of engineering services. It did not really matter that erosion and sediment control is not engineering. On paper, it looks like engineering and the engineers, quite naturally as businessmen, were more than happy to undertake the additional work.
This windfall to the community was not an unmixed blessing. Not for all, but certainly for the vast majority of the design community, the promulgation of NPDES in 1992 was the first exposure of urban civil engineers to the subject of erosion and sediment control. The inclusion of erosion and sediment control as a mandatory element of construction projects did not take the design community by surprise (obviously—since the subject had been looming on the horizon for nearly a decade before it arrived on the scene) but it did catch the community technically unprepared.
The truth is that the majority of engineering schools, as recently as only five years ago, exposed their students to little if any discussion of this specific field of earth science. An excellent college-level textbook in erosion and sediment control (Erosion and Sediment Control Handbook by Steven J. Goldman, Katherine Jackson, and Taras A. Bursztynsky, McGraw-Hill) was published in 1986 and was already out of print by 1992, due to a lack of interest within engineering education circles. Six years later, Jerald S. Fifield, Ph.D., CPESC, and principal of Hydro-Dynamics Inc. in Parker, CO, said in an interview in the June 1999 issue of Erosion Control, "Perhaps making sediment and erosion control part of the general curriculum—a one-semester (at least) course for all civil engineers—would be a good idea." To date, I am not aware of that happening.
Since then, Fifield himself has authored two state-of-the-art books on the subject: Designing for Effective Sediment and Erosion Control on Construction Sites (ForesterPress 2004) and Field Manual on Sediment and Erosion Control: Best Management Practices for Contractors and Inspectors (ForesterPress 2002). Well-worn copies of both are on my desk, but to the best of my knowledge, engineering education has yet to include the subject as a part of its agenda. It can be safely said that the typical engineer is not prepared in erosion and sediment control by virtue of his or her formal education.
During more than four decades in the civil field, I have known a large number of excellent engineers, who have graduated, earned their professional licenses, worked through their careers, and retired without ever uttering the phrase "erosion and sediment control." Of the hundreds of urban construction project designs that I have been involved with or observed over the years, not one (prior to NPDES in 1992) was designed with any consideration being given to the subject. So, it is also fairly safe to say that engineers are not typically prepared in erosion and sediment control by virtue of practical experience.
This is not to say that engineers cannot become proficient in the field of erosion and sediment control. They can and a number have, some even having achieved the CPESC designation. As a community, however, they are still not fully educated or trained in erosion and sediment control. Their focus—their vocation—is engineering, not erosion and sediment control. Engineering is a demanding field in its own right and its practitioners are under constant pressure to keep current with technological and philosophical advances. Most states require continuing education as a requisite to sustaining an engineering license or registration. As Dan Strawser, president of Jobsite Outfitters Inc., a sediment and erosion control contractor in Columbus, OH, says, "They [engineers] must continue to devote the time and resources necessary to stay current in the stuff they've already learned." Expertise in erosion and sediment control is something that must be actively pursued by the individual. Strawser goes on to say that they have little left with which to become "qualified in a field that takes the same amount of energy to master, such as E&SC."
Should the practice of erosion and sediment control become a practice restricted to professional engineers? With all due respect, the answer must be no.
The casual reader that I first mentioned must understand that even though many engineers practice erosion and sediment control, erosion and sediment control is not an engineering practice. The engineering community plays a dominant role in erosion and sediment control because it has the numbers and the logistical position to do so. At the same time, there are a significant number of other professional disciplines whose expertise in ESC is equal to and in some cases superior to that of the engineering profession. In the interview I mentioned earlier, Fifield also commented, "You know, there's nothing sacred that says that erosion and sediment control is the domain of the engineering community. In fact, engineering is just one aspect of it."
Expertise in erosion and sediment control draws upon a wide range of backgrounds and scientific fields, including the engineering field. No single one of those fields provides a complete erosion and sediment control package, and no one field should be given proprietary rights over it. Doing so would deprive a necessary undertaking, already wanting in expertise, of the full range of what the other professional fields have to offer. As a specialized field of technology, urban erosion and sediment control is still developing. It is too crucial to the public welfare to have that development curtailed by what amounts to a "territorial" claim.
For those of us who are involved in the practice of erosion and sediment control, regardless of our professional allegiances, our time would be better spent in the continuing development of the field. There remain many obstacles to effective and economical approaches to ESC. Most are technical and consist of things that even the most expert of us still need to learn. Perhaps the greatest single obstacle is convention. We resist giving up familiar practices and policies even in the face of their failure to satisfy the demands of the 21st century. Examples of these are clearly represented in the way we continue to design land development projects.
Martha S. Mitchell, CPESC, natural resource planner and principal of Clearwater West in Portland, OR, wrote in her feature article "CPESCs Take It to the Top" in the January/February 2002 issue of Erosion Control magazine, "Because of my training in geomorphology, I frequently gasp at the problems that arise because of decisions people made about siting roads, facilities, parks, and large developments." We know that, like water-quality issues, erosion and sediment control can be made simpler, less costly, and more effective if it is considered early in the planning stage of a land development project. If included early on, areas of minimal disturbance can be located where the soils are the most sensitive. By minimizing the potential for erosion within the overall design of the project, the intensity of both erosion control and sediment control practices required during construction can be reduced. Critically sensitive areas can be incorporated into the plan and worked around, protected as much by the overall design as by specific practices.
Currently, in many regions of the country, erosion and sediment control is not treated as an integral part of the project (which, in fact, it is). ESC concerns are not a factor in site layout and design. In too many instances, erosion and sediment control is treated as an afterthought in the design process. Rather than being an integral part of the project, ESC is dealt with as an overlay to the finished design. When the engineering plans are virtually complete, a sometimes cosmetic coating of ESC practices is applied. Silt fences are sketched on the plan, inlet protection is added, a sediment trap (or two) is positioned in obscure locations, and the erosion and sediment control is considered "done." We know better.
Even in the detailed plans for the site, ESC is seldom a design consideration. We know that in the design of slopes—for example, the geometric shape and orientation of the constructed slopes—have a significant influence on the potential for erosion. Yet the standard slope design has not changed from what it was before ESC became an issue. The result is that erosion control and its cost are maximized. Sediment control and its cost are maximized. We know that open-channel geometry and alignment govern the erosion potential when the channel is subjected to flows. A parabolic channel is less susceptible to erosion than a trapezoidal channel, yet it is the trapezoidal section that is routinely specified on improvement plans. Even a slightly sinuous flow path is less erosive than a straight channel, yet improvement plans consistently present straight lines. In some cases—roadway projects, for example—it is the nature of the improvement that mandates straight lines. In virtually any other type of project involving open channels, the designer has the choice. Too often, traditional standards outweigh contemporary principles. Too often, a project is designed more to conform than to perform.
Erosion and sediment control is a practice that is crucial to the conservation of two of our most necessary natural resources: soil and water. Its effective and economical implementation relies totally upon the expertise of those engaged in the practice. Restricting the practice to any one profession—even one as capable as the engineering profession—reduces the size and depth of the pool of available expertise. Such an action is not in the best interest of the erosion and sediment control field, not in the best interest of the erosion and sediment control programs across the country, and ultimately, not in the best interest of the future.