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Introduction
The recent actions by California State EPA, through the 2022 Construction General Permit (CGP), reducing qualifications for SWPPP Inspectors and Designers, have generated a series of important questions. Moreover, EnviroCert International (ECI) has recognized a broad platform of misunderstandings, ranging from why ECI opposes lowered qualifications to why ECI does not act as a training provider, that are addressed in this letter.
The State Water Resources Control Board is composed of highly capable professionals and regulators who, historically, have set the national standard through innovative permits and policies. The 2022 CGP is, in many respects, another strong example of this leadership. However, due to the influence of special interest groups and individuals, California has eliminated long-standing professional requirements for stormwater inspectors and SWPPP designers. In ECI’s view, this decision has set the practice of stormwater management and water quality protection back more than 30 years.
After repeated but unsuccessful discussions with the State Water Board:
ECI Letter, dated 7 October 2024
State Water Board Letter, dated 31 December 2024
State Water Board Letter, dated 13 June 2025
ECI has formally communicated its concerns to the Office of the Governor for the State of California (ECI Letter, dated 10 August 2025) in hopes that leadership and direction will be provided. Should no corrective action be taken, ECI and allied stakeholders are prepared to pursue other available options to protect the public and the profession.
This article has been assembled to begin addressing these questions and misconceptions, and to provide ECI professionals with accurate, transparent information. It also outlines key distinctions between Professional Certifications, Certificates of Training, and Membership Organizations, in order to clarify misunderstandings that continue to affect the industry.
ECI believes this moment provides a cautionary tale for regulators and practitioners alike: when professional standards are diluted, the risks to water quality, public safety, and environmental protection rise sharply.
Our goal is to foster dialogue, build awareness, and reaffirm the importance of competence and professional integrity in stormwater practice.
SECTION 1 – DIFFERENCES BETWEEN CERTIFICATION TYPES
Question 1.1: ECI is not teaching me how to write a better SWPPP or how to perform the tasks required for my certification.
ECI Response 1.1:
This is one of the bigger misconceptions. It is essential to understand what a Certification Body (CB) is, and how it differs from membership groups or training providers.
Fact Sheet - Key Elements of a Certification Body
A CB has clearly defined responsibilities under international standards (ISO/IEC 17024, ISO/IEC 17021, ISO/IEC 17065, etc.), as well as ethical and legal obligations to the public, regulators, and certificate holders. Responsibilities include impartiality, scheme development, certification process management, renewal requirements, data protection, accountability, and public trust. Please read the Fact Sheet in the link above for a more detailed breakout of the role of a CB. This has been a constant area of confusion for many certified professionals and the industry as a whole.
In contrast, education and training should be undertaken by industry membership groups, not the certification body. ECI only offers a general review course to help candidates prepare for exams—not to provide technical training.
Fact Sheet - Key Elements of a Membership Organization
Question 1.2: Why doesn’t ECI teach us how to pass the exam like some other organizations?
ECI Response 1.2:
Because certification bodies must remain independent of training. Teaching the exam would violate our impartiality obligations and could even revoke our accreditation.
The distinction is simple:
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Certification: independent, competency-based credential requiring prerequisites, exams, ethics, and ongoing continuing education.
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Certificate of Training: proof of course attendance, with no independent verification of long-term competency.
Fact Sheet - Key Elements of a Certificate of Training
Certifications carry weight in regulatory and legal contexts. Certificates of training supplement learning but do not replace certification. Two examples are California's QSP/QSD and the State of Washington's CESCL program
Question 1.3: What are membership groups, and which one should I reach out to?
ECI Response 1.3:
Membership groups are industry associations that provide training, advocacy, networking, research, legal support, and technical resources. They help professionals grow and stay informed. Examples include state erosion control associations (e.g. CASQA) or national groups national stormwater groups such as National Municipal Stormwater Alliance (NMSA). You will note that these groups may have their own education content and associated certificate of training but that are not Licensures or Professional Certifications.
ECI always recommends professionals in the industry to join appropriate membership groups, but we always recommend researching each group carefully to ensure they align with your professional goals and provide meaningful resources, not just marketing claims.
SECTION 2 – ECI VIEWS ON REDUCED REQUIREMENTS/COMPETENCY
Question 2.1: Why is ECI opposing reduced technical requirements in California’s CGP?
ECI Response 2.1:
Because reducing qualifications undermines the standards and integrity of the stormwater field. Credentials like CPESC and CESSWI exist to ensure practitioners are competent to manage erosion, sediment, and stormwater risks. Allowing unverified individuals to practice increases environmental and public health risks.
Question 2.2: What are the potential consequences of less experienced individuals holding certifications?
ECI Response 2.2:
- Improper stormwater management
- Increased erosion, sedimentation, and water pollution
- Costly compliance failures and litigation
- Loss of public and industry trust in regulatory frameworks
Question 2.3: Why are professional certifications important?
ECI Response 2.3:
They validate expertise, demonstrate accountability, and ensure consistency in compliance across jurisdictions. Certifications also promote ongoing professional development.
Question 2.4: How can municipalities balance qualifications with workforce demand?
ECI Response 2.4:
By supporting education, apprenticeships, and professional development—not by lowering standards.
Question 2.5: How is ECI engaging municipalities?
ECI Response 2.5:
Through advocacy, letters, and collaboration with industry groups to raise awareness of the risks of lowering standards and to promote policies that protect certification integrity.
SECTION 3 – ECI RESPONSE TO CLAIMS OF EXCLUSIVITY
Question 3.1: Why is ECI accused of exclusivity?
ECI Response 3.1:
ECI promotes certifications grounded in years of education, training, exams, and experience, not quick classes. This is not about restricting opportunity, but about ensuring competence and protecting public safety.
Question 3.2: Why object to “alternate” standards in California’s CGP?
ECI Response 3.2:
Because “alternate” must mean equivalent in rigor. Redefining it as reduced or no qualifications is legally invalid and constitutes an underground regulation under California Gov. Code §11340.5.
Question 3.3: What are the consequences if this decision stands?
ECI Response 3.3:
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Loss of leadership – California risks its reputation as a regulatory leader.
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Economic impacts – Wages and credentials devalued; market flooded with unqualified practitioners.
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Public safety risks – Increased slope failures, flooding, and habitat destruction.
Question 3.4: Why is the Water Board and CASQA promoting these changes?
ECI Response 3.4:
We believe their intent was genuine, but messaging was hijacked by special interests. The resulting logic is flawed and unsound.
Question 3.5: Is this about money for ECI?
ECI Response 3.5:
No. As a nonprofit, ECI reinvests revenues into technical development and oversight. Renewal fees are modest (<0.002% of median salary) and far less than comparable professional licenses. If revenue were the goal, ECI could offer low barrier “certificate of training” programs. Instead, ECI chooses to uphold rigorous, competency-based certification.
SECTION 4 – LEGAL & REGULATORY IMPLICATIONS
Question 4.1: How does reducing standards create legal risks?
ECI Response 4.1:
It undermines permit enforceability under the Clean Water Act and Porter-Cologne. Regulators issuing permits based on unqualified practitioners’ risk legal challenge and noncompliance findings. Municipalities and contractors then face greater liability for environmental harm.
SECTION 5 – RISK MANAGEMENT & LIABILITY
Question 5.1: Why are certifications a risk management tool?
ECI Response 5.1:
Certified professionals provide a defensible assurance of competence in audits and court. Certificates of training do not. Employing underqualified staff increases liability for municipalities and contractors. Certifications reduce risk by ensuring decisions are made by verified experts.
SECTION 6 – WORKFORCE DEVELOPMENT & PIPELINE
Question 6.1: If there are labor shortages, why not reduce standards?
ECI Response 6.1:
Because short-term fixes create long-term risk. Instead, build a pipeline of qualified professionals through partnerships, apprenticeships, and education programs. Workforce demand can be met without sacrificing certification integrity.
SECTION 7 – PUBLIC SAFETY & ENVIRONMENTAL STEWARDSHIP
Question 7.1: Why compare stormwater certifications to aviation or healthcare?
ECI Response 7.1:
Because the stakes are equally high. Poor stormwater management can cause deaths, flooding, property loss, and ecological destruction. Just as pilots and doctors must be credentialed, stormwater professionals must demonstrate proven competence.
SECTION 8 – TRANSPARENCY & ACCOUNTABILITY
Question 8.1: How does ECI ensure fairness and impartiality?
ECI Response 8.1:
Through an Impartiality Committee, published standards, appeals processes, and nonprofit reinvestment into certification oversight. ECI does not profit from training, which preserves independence and credibility.
SECTION 9 – GLOBAL COMPARISONS
Question 9.1: How does California compare globally?
ECI Response 9.1:
Other U.S. states and countries (EU, Canada, Malaysia, Japan, Australia, Ibero-America, etc.) are strengthening standards, not weakening them. California’s reduction risks setting the state behind its peers and undermining decades of progress.
SECTION 10 – FINANCIAL MOTIVATION
Question 10.1: Is maintaining standards financially motivated?
ECI Response 10.1:
No. ECI is a nonprofit organization. Certification fees are modest, reinvested into exam development, technical standards, and oversight functions. The organization could generate more revenue by offering quick, low-barrier training programs but has deliberately chosen the harder path of maintaining rigor.
This model protects the value of certifications, safeguards public trust, and prevents hidden costs from falling on the public in the form of environmental damage, litigation, and loss of life or property.
SECTION 11 – FINANCIAL MOTIVATIONS AND IMPLICATIONS
Question 11.1: Is ECI certification costs driving up or adversely impacting the costs of the QSP/QSD programs?
ECI Response 11.1
EnviroCert (ECI) is not driving up the cost of QSP/QSD programs. In fact, the higher costs and barriers in California are almost entirely the product of third-party training and implementation decisions by the State Water Board and its selected trainers. Here’s the breakdown:
1. ECI’s Role vs. Training Providers
- ECI’s role is limited to credentialing and certification (CPESC, CESSWI, CPSWQ, etc.), which are nationally and internationally recognized professional standards.
- QSP/QSD training in California is not provided by ECI, it is administered under the Construction General Permit (CGP) through programs run by groups like CASQA and other Board-approved trainers. These groups set their own course fees, application fees, and trainer fees.
This means that ECI does not control the cost of QSP/QSD classes, nor does it financially benefit from them.
2. Actual Certification Costs
ECI Fees:
- ECI costs for a Professional Certification that can be used in all 50 states and internationally is approximately $1,000.
- ECI certification renewal fees (for CPESC, CESSWI, etc.) are modest compared to salaries and consulting revenues, typically around $150–200 per year, less than 0.002% of an average certified professional’s income.
CASQA QSP/QSD Program
- The “alternative training programs are on the order of $500 per person for the 16 hours.
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By comparison, CASQA’s QSP/QSD training courses can run $1,200–$2,000 per candidate, plus trainer application and annual fees and PDH’s will be required.
- This Certificate of Training is only valid in California
This demonstrates that the training market in California, not ECI, is the driver of the higher program expenses.
Question 11.2: Why does the Misconception Exists
ECI Response 11.2
There are several reasons, but ECI will only address a few in this article.
..a.....SHORTAGE OF QSP/QSD
A recent survey of industry advertisements on all job boards (e.g. ZipRecruiter, etc) only revealed four (4) advertisements for QSP/QSD. Surveys of the marketplace do not support this fallacy.
..b.....CGPTT PROGRAM INHERENT CONFLICTS OF INTEREST
The CASQA based advisory group that has been the source of the California issues is composed of some excellent professions and practitioners.
However, the composition of the Construction General Permit Training Team (CGPTT) raises serious governance and integrity concerns. Members were not appointed on the basis of professional experience, demonstrated accomplishments, or recognized credentials in erosion, sediment, or stormwater management. Instead, appointments were made without transparent criteria, undermining both the credibility of the team and the legitimacy of its outputs.
Equally troubling, no conflict-of-interest disclosures were required or undertaken. In professional and regulatory practice, such disclosures are a basic safeguard to ensure impartiality and protect the public interest. The absence of this safeguard allows undisclosed financial, organizational, or personal interests to influence decision-making, creating a reasonable perception of bias and undermining public confidence.
By failing to require both merit-based appointments and conflict-of-interest transparency, the CGPTT process does not align with the standards of impartiality and integrity expected of regulatory programs. This deficiency calls into question the validity of the team’s recommendations and their compliance with California’s obligations under the Clean Water Act and Porter-Cologne Water Quality Control Act to ensure competent, unbiased implementation of water quality protections.
..c.....MONOPOLY
Some parties have asserted there is a monopoly by requiring CPESC. This has created confusion by some and improper accusations by others.
EnviroCert International (ECI) is a 501(c)(6) nonprofit professional certification body. Its mission is to protect public health, safety, and the environment by upholding competency-based certification standards. ECI’s certifications (CPESC, CESSWI, CPSWQ) are one of the most recognized pathways to demonstrate competence based on over 40 years of experience, leadership, and standards.
Some critics confuse ECI’s role in credentialing professionals with control over the California QSP/QSD training system. In reality:
- ECI earns only from certification and renewal fees, not from QSP/QSD course registrations.
- CASQA and private trainers derive revenue from the QSP/QSD classes, not ECI.
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If anything, ECI has reduced its potential market size by holding to rigorous prerequisites rather than lowering standards to attract more candidates.
..d.....FINANCIAL GAIN
As discussed in Section 10, ECI does not distribute profits or operate for private financial gain. Some critics assume that because ECI advocates for maintaining certifications (like CPESC/CESSWI) as prerequisites for QSP/QSD roles, that position is financially motivated. In reality:
If ECI wanted revenue, it could have created a “CPESC-light” or “CESSWI-light” short course program that would attract far more participants at lower cost.
Instead, ECI deliberately chose to maintain rigorous, competency-based standards, even though this limits the number of candidates and, by extension, ECI’s revenue.
SUMMARY
The cost burden for QSP/QSD candidates in California comes from CASQA-run training and trainer fee structures, not from ECI’s credentialing model.
EnviroCert as a Benchmark of Professional Standards
A. National and International Recognition
EnviroCert International (ECI) administers certifications such as CPESC, CESSWI, and CPSWQ, which are recognized across the United States and in many other countries as the benchmark credentials for erosion, sediment, and stormwater professionals. These credentials are accredited to ISO/IEC 17024 (Conformity assessment, General requirements for bodies operating certification of persons), the international standard for personnel certification programs.
B. Competency-Based, Not Training-Based
Unlike short training classes or certificates of attendance, ECI’s certifications are competency-based. They require:
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Formal education or equivalent professional experience.
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Documented field experience under responsible charge.
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Rigorous written examination testing applied knowledge.
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Adherence to a code of ethics and continuing education requirements.
This structure ensures that certified individuals have both the theoretical and practical expertise necessary to protect water quality and public safety.
C. Benchmark for Regulatory Programs
Because of these qualities, regulators across the country, including the California State Water Resources Control Board, various state DOTs, and local agencies, have adopted ECI certifications as benchmarks of competency for stormwater professionals. The credentials provide regulators, the regulated community, and the public with confidence in the qualifications of those entrusted with stormwater compliance.
D. Safeguard Against Dilution of Standards
By serving as the professional standard, ECI certifications prevent dilution of qualifications. Substituting them with short courses or unaccredited training undermines both the legal framework of the Clean Water Act and Porter-Cologne, and the public trust that stormwater programs are being managed by qualified professionals.
EnviroCert does not compete as a training provider, it functions as the benchmark-setting professional certification body, ensuring that erosion, sediment, and stormwater practice remains a recognized profession rather than reduced to minimal training.
California, however, has effectively created a system where no meaningful baseline of education or experience is required. Under the current framework, an individual who has not graduated from high school or completed any math- or science-based coursework may simply sit through a 16-hour class with no examination. They then attend an additional 16–21-hour course where, in many cases, the answers to the exam are provided during instruction. The final step is an online, open-book, open-note exam. Upon completion, this individual is permitted to act as a QSP/QSD, preparing erosion and sediment control plans (E&SC) and Stormwater Pollution Prevention Plans (SWPPPs).
The State Water Board, CASQA, and the CGPTT appear to operate under the belief that their approved trainers can, within this framework, effectively teach the practice of erosion and sediment control and water quality management. In contrast, Professional Engineers (PEs) and Certified Professionals in Erosion and Sediment Control (CPESCs) typically undergo the equivalent of 7 to 10 years of education, field training, examination, and mentorship before being qualified to undertake such work. Even then, additional training and continuing education are required to ensure competence.
Link to WGR Article, dated August 2025
ECI Response Letter, dated 27 August 2025
The disparity is clear: California’s current system substitutes expediency for expertise, undermining the credibility of the program and the protection of public health and safety.
EnviroCert’s mission has always been, and remains, to uphold competency, professional integrity, and the public interest. It does not profit from training fees and has consistently resisted creating low-barrier, revenue-driven programs that would erode professional standards.
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