The project team is seeking clarification as to whether an enhanced Stormwater Pollution Prevention Plan (SWPPP) would qualify as an Innovation Credit. The General Contractor, Hensel Phelps Construction Company, has developed and implemented a program to monitor construction pollution prevention and ensure soil erosion and sediment controls during construction. Hensel Phelps developed a trial program in 2007 to assess their effectiveness in assuring compliance with specified pollution prevention strategies. Results of the trial indicated dramatic performance improvements in the implementation of pollution prevention practices during construction. Consequently, the company has adopted this program as standard practice for all of its projects. The Prerequisite for Sustainable Sites requires prevention of: 1. Loss of soil during construction by stormwater runoff and/or wind erosion, including protecting topsoil by stockpiling for reuse, 2. Prevent sedimentation of storm sewer or receiving streams, and 3. Prevent polluting the air with dust and particulate matter. While all construction sites attempt to fulfill this prerequisite by putting in place controls, these precautions are rarely monitored and thus not repaired when necessary. Hensel Phelps Construction actively evades this negligence by implementing a much more thorough Stormwater Pollution Prevention Plan. The program contains a comprehensive plan for ensuring compliance through extensive training, routine audits, documentation, and maintenance. An HPCC employee not on the project team is employed to audit the site\'s SWPPP Program. Three to seven days after the initial assessment, a follow-up inspection is conducted. Throughout the lifetime of the project, at least one HPCC employee that is part of the construction crew is assigned to oversee the upkeep of the soil erosion and sediment control measures on a monthly basis. This surveyor will walk the site to ensure that the control measures are in good shape. Documentation guidelines and performance metrics are also included to allow for thorough monitoring and assessment of the plan\'s effectiveness. Reports from the third party inspections of the SWPPP are forwarded to the Vice President, General Superintendent, Project Superintendent(s) and the Area Superintendent(s) to ensure that it receives the appropriate attention. Then the monthly inspections are recorded in detailed reports called "Stormwater Risk Management- Construction SWPPP Field Inspection Report." The report includes general information and summarizes the number of findings, the severity of these findings, calculations of how the findings are scored, and the percentage of the corrections made due to the findings. The summary is followed by maps of the construction site with markings of problem areas. The report then progresses into further detail with documentation of each finding including a deadline for correction. The follow-up inspection section indicates if any correction was attempted, any necessary explanation, and the follow up finding severity rating in a similar format. Photos of the site are also present from both initial and follow- up inspections. Continuous implementation of this program will provide substantial contributions to maintaining water quality. In addition, the success of this program provides a model for other project teams seeking to improve stormwater pollution controls and minimize damage to waterways resulting from construction practices. Hensel Phelps received an Environmental Achievement Award in 2008 in recognition of these ongoing benefits from the Mid-Atlantic Environmental Protection Agency. According to the EPA\'s website: "This award recognizes and rewards projects that have significant sustained, measurable, and replicable environmental results for a clearly defined environmental issue in Delaware, the District of Columbia, Maryland, Pennsylvania, Virginia, or West Virginia; must have reduced pollution and/or protected public health and the environment; has innovative ideas, approaches, techniques, and/or technologies; and demonstrated leadership and outreach to others."