PWNA - BMPs: What they are and what they are not. A letter from Mike Hilborn, E.D.

[PWNA HQ 14]

This letter is written by Mike Hilborn, PWNA Executive Director. It was reviewed and commented on by the PWNA Board of Directors. This letter has been approved for distribution by the PWNA Board of Directors (BOD from this point).

This letter is intended to explain the BOD intentions behind the Environmental Best Management Practices (from this point BMPs) and why they are important for members of PWNA and the industry at large. My goal is to explain what the BMPs are and what they are not.

Let me begin that neither the BOD nor I saw that the voting on the BMPs would create such a response.The response was surprising, disappointing, and encouraging all at the same time. Let me address each of these:

· Surprising - we post things almost everyday with little or no notice. The BMPs that were voted on was part of the process to make the BMPs official so that we could use those

BMPs as part of an Environmental Certification course currently being developed. Education is one of the "pillars" of the PWNA and is one of the ways we bring real value to our

members. Also, these BMPs have been around the PWNA for many years. These BMPs are not new, just reformatted to be easier trained and understood. Nothing new.

· Disappointing - the things that were said about people who volunteer their time and talents to make our industry better is always disturbing to read and reflects poorly on our

industry.

· Encouraging - it is positive to see such interest in this topic. The BMPs are a work in progress and the more help we can get the better. Typically, these sorts of things are worked

on by only 1 or 2 dedicated people and then approved by a group. The BOD welcomes and appreciates the input and comments from everyone to make these BMPs the best they

can be for all involved.

Let me explain what the BMPs are:

· An educational tool - to be used as part of an Environmental Certification course. For me personally, I have spent all of my time on residential services like wood restoration, roof

cleaning and house washing. I recently began commercial exterior cleaning and fleet washing and I had no idea where to begin as it relates to the Clean Water Act (CWA from this

point). I found the current PWNA BMPs difficult to understand and they left me with many questions. However, I didn't know where to begin without them. The PWNA is leading this

important topic.

· A resource for your employees - we wanted to have a document that could be part of every members operation, if they chose. Take these BMPs and use them as they are or use

them to start developing your own company BMPs based on the services you provide and the geography you serve. They are a living and open document that can be modified and

applied by anyone that wants them.

· Protection - having BMPs and being Water Reclaimer Certified can be used to demonstrate to local regulators and municipalities that you are a trained professional. They will know

that you are doing what you can to protect our lakes, rivers, streams and oceans. The PWNA is here to protect our members and help them to be more profitable. You may not

agree, and that's fine, but that is what the BOD believes.

· Helping keep our waters clean - Some cities have not developed their own BMPs, others have. Part of phase 2 of the EPA (as I understand it) requires cities to develop their own

BMPs. If all of us can do the work for them by writing or at least influencing the writing of their BMPs, better for your city, better for you the contractor and better for the

environment. The services each of us as contractors perform is to keep things clean and to protect the health and safety of our customers. No one is more interested in protecting

the environment than those of us in the power washing industry.

Let me tell you what the BMPs are not (based on some of the points I read on the bulletin boards):

· The PWNA is not going to bring, or shop, the BMPs to municipalities, city leaders or roll them out across the country. That was never mentioned as our plan and I don't know where

that came from. Second, we don't have the money or resources for such an undertaking.

· These BMPs aren't designed to be the answer for every power washer, in every part of the country, for every possible cleaning situation or challenge. They are a guide. They are a

resource to develop BMPs specific to your operation.

· They will not solve the Houston problem. These BMPs are written to comply with the CWA. What is happening in Houston is not about the CWA. As you can read toward the

beginning of the BMP document "If your discharge does not reach the waters of the United States, then there are no requirements under the Clean Water Act."

· The BMPs are not applicable to residential services such as house washing, roof cleaning or deck cleaning unless wash water will reach a storm drain. If the water doesn't hit the

storm drain, these BMPs do not apply.

· The BMPs are not about enriching anyone. To be on the BOD, 50% or more of your revenue must come from contract cleaning. Michael Hinderliter had to leave the Board when he

bought Delux from Robert and the new bylaws were passed. Although Robert Hinderliter is the Environmental Chairman, he is not one of the Board of Directors. The BMPs are about

education and guidance. We aren't suggesting anyone buy a particular type of equipment or to buy any equipment at all. It is up to the individual contractor as to how he or she

will meet the requirements of the CWA.

· We are not submitting these BMPs to the EPA on April 15th or any other date. We are not submitting these BMPs to any government authority. They will be available on the PWNA

website to anyone who wants to read them. We are asking for member comments to be returned by April 15th to keep the process moving.

· The BMPs don't suggest that we are polluters. If I'm mistaken, please email which line or lines of the draft you are referring to and the correction or corrections will be made.

It is the position of the BOD that our industry support the Clean Water Act and the PWNA will support rules that are practical, reasonable and economically feasible to protect our lakes, rivers, streams and oceans. If we find municipalities that are overreaching or are unreasonable, we will do what we can to address those cities (this is where we need everyone to be a member, my only plug). Power washing contractors are parents, sportsmen and sportswomen who want to leave our world better than we inherited it. I would like to believe that few of us would disagree.

The BOD would like to get member comments as described in a previous post. Please submit by email, fax or USPS your comments by April 15th. If you have any questions, please call me directly at 612-868-7312. My email address is mike.hilborn@pwna.org. If I did not explain our intentions to your satisfaction or I need to answer questions not answered here, I would appreciate the opportunity to speak to you directly. Thank you.

Sincerely,

Mike Hilborn and the Board of Directors of the PWNA

Edited April 4, 2011 by PWNA HQ

[Guy B 70]

I would like to publicly apologize to the PWNA. I posted on TGS, that the PWNA was going to submit this BMP to the EPA April 15, I have been assured by Mr. Hilborn that this is not true and I take him at his word. Although the information came from a good source, seems it is incorrect. Again my apologizes.

[Ron Musgraves 240]

http://www.youtube.com/watch?v=Y2TH6myI7Fs

My final and Last comments about this!! Its not worth My time Right NOW

[Guy B 70]

When I first read the Ft. Worth BMP, I read the Ordinances along with the BMP. I thought they were 2 in the same. By separating the BMP from the Ordinances, its a totally different picture. This BMP mirrors that of many states, and is close to CWA Minimum Standards. I still disagree with the reasons that they should want or even need to do this at all. Call it whatever you want, just don't call it a BMP.

Mr. Hilborn and I talked today, he brought up a really good point. He said "Why As An Industry Can't We Come Together??", I have thought this many times myself. We are an unusual and very interesting group of people. So my answer to Mike's question would be "Give Us A Reason".

If you want to "Come Together" or raise the level of awareness to the Industry, start with the "Perception Of Our Industry". If you read different BMP's we are classified as "Cosmetic Washers", that pressure washing is an inefficient use of water, that we are perceived as a "Major Source Of Pollution", All Untrue!!! Houston Will Put Contractors out of Business, that is true.

Give Us a Reason To Come Together.

Ron is right though, there are more important issues than this BMP thing. Hope you guys will listen.

[tonyshelton 112]

Any thoughts about going ahead and spending money on testing runoff before publicizing any BMP's? Wouldn't that be a better use of PWNA funds if the PWNA wants to be involved in a contractor oriented way?

[John T 744]

Mr. Hilborn and I talked today, he brought up a really good point. He said "Why As An Industry Can't We Come Together??", I have thought this many times myself. We are an unusual and very interesting group of people. So my answer to Mike's question would be "Give Us A Reason".

This has always puzzle me also. I can see difference of Opinions always happening and since we are all business owners most of us have strong Personalities. This has made me wonder over the years if this is the biggest reason somewhere sometime as to why we lock horns with each other. Either way the goal should always try to get this industry at the most part to unite in one way shape or form. This would be exluding all hacks and Lowballers and I'm not talking about people who charge a little less then others but the ones who charge so low its a joke and then you see those people are gone the next year.

Years ago I proposed that there should be a Roundtable that was geared to the whole Industry with orgs being invited but more importantly to get as many from each Bulletin board to go. This would be like a massive Roundtable so we all could meet and talk shop and maybe find some common grounds that we all could support.

Man did I almost get my head shot off for that proposal. I was asked to remove that thread by a few which I did and I regretted doing that but it looked like at that time there was to much angst for this to succeed.

Today it is a little better but its still oh so slow to get this industry to unite in some aspects because we all know you can't get everyone to ever agree on everything.

Maybe Ron M. this time really does have a way to make this happened. He's the one traveling the most, Planning the most and pretty much doing more then many can do combine.

So seeing the light a little better today after a rough few weeks.... I am supportive of Ron and the Coalition along with the PWNA for something to come out positive from this Houston Fiasco.

Determination can make this happened and if there is anyone that is so determined right now to do this..... its Ron.

[tonyshelton 112]

What do you guys think about the PWNA having their own certifications with some other nomenclature that avoids the "BMP" reference? Seems like BMP's are a "buzz word" for municipalities.

[C&S Property Services 24]

Tony,

Certifications, I think, can be a good thing.

LOok at it this way. I just start or want to start a PW business. I know NOTHING. How would I get out from being a hack? Easy solution...Certification. If you work for someone or do the free labor stuff then thats fine too.

Certifications can make your business look better as well. You can send your employees to the classes and raise the bar a little bit for your company.

Now, let me play devils advocate. Who says any one group or company can certify for powerwashing. Let me make this clear. If I put something out that we offer wood certifications and only show you how to redwoods how does that help the guy that really only gets to see Pine decks? Same thing with the environmental. When Scott Stone and I talked about putting stuff together I had no idea about dry wells. You guys may have them out west but we dont see them here. Or at least I havent. But if I was to offer an environmental cert how would it benefit the guy in Arizona with dry wells? It wouldnt. When I took the Environmental Cert from the PWNA it showed alot of different and cheap methods to be able to comply. But I dont remember talk about dry wells. But then that was back 5 or 6 years ago.

So, IMO I think certifications are what you want them to be. They have benefits and downsides.

[tonyshelton 112]

Rob what you described above is exactly why no one is ready to "certify" any pressure washer in a "one size fits all" BMP.

[Guy B 70]

Rob what you described above is exactly why no one is ready to "certify" any pressure washer in a "one size fits all" BMP.

That's why it should be called a "CWA Certification". The CWA is a "One Size That Fits All" rule that has to be followed....But anyone that takes this should be told to get a copy of their local or State BMP's and make sure they follow their guidelines also.

[John T 744]

That's why it should be called a "CWA Certification". The CWA is a "One Size That Fits All" rule that has to be followed....But anyone that takes this should be told to get a copy of their local or State BMP's and make sure they follow their guidelines also.

Hey Guy how would one go about getting a "CWA Certification" and do they even give those out?? I say if that can be done its a great idea to go that route. I wonder if that can be done legitimately. It kind of rings like the famous and unauthorized term of "Its EPA Compliant". I don't thing the EPA gives any company there blessing. Once again I could be wrong on these points here but if like Guy says that you can call a certification a 'CWA Certification" thats golden. Good point Guy.:idea:

[Ron Musgraves 240]

How about we contain water and never deal with the CWA as a first Choice. WOW what a concept

[tonyshelton 112]

If the PWNA or anybody is going to certify anyone they need to make darn sure they know where the reach of the CWA ENDS.

John, you should understand this: In other words, If I was going to give a certification on "how to legally drive in America" I could take the easy way out and cover my a$$ and say "You may not travel on the highway at speeds greater than 65 mph". That would be a lie but it would "certify" the listeners to guarantee that they would be covered nationwide. OR WOULD IT? What about construction zones? What about night restrictions? What about trying to dry 65 on a Vegas freeway and somebody running of you off the road for impeding traffic?

All this type of stuff takes research.

"Nothing down the drain but rain" is a falsehood taught because it's easy and simple and doesn't require any research.

Everytime someone says that phrase I will make it my life's goal to make fun of them mercilessly. :)

There is nothing wrong with playing within our legal rights. In other words, if you can keep the runoff OUT of the "waters of the US" as Ron is talking about then you don't even fall under the jurisdiction of the CWA. The CWA restricts POLLUTANTS. If we can remove pollutants before they reach the drain we've already complied.

If we don't learn the law, we can't certify. It's that simple. We can certify "environmental cleaners" or some other such generic nomenclature, but we can't certify compliance with an Act that we don't understand and can't put in a box with it's limitations.

IF ANY entity attempts to certify anything official sounding like "BMP's" or CWA using lies about the CWA I will use every minute of my spare time making them look like fools via every forum I can get high rankings on Google with. I might even provide the text and just ask Ron' SEO guys to place it wherever it has the most bang.

That goes not only for the PWNA, but the ***** and any other group that thinks they can provide certification on something so region specific by just throwing a 2 hr blanket course demanding that they give up their legal rights just to be able to get jobs.

That's where this is going. Mike Hilborn tells me that is not his goal and I have no reason not to believe him. But that's like running towards the edge of a cliff full blast all the while claiming it's not your goal to fall off. Eventually any 'certification' that even remotely sounds "official" will become the government "standard" that we will have to "comply" with in order to do business. We are not working with things that can kill people like restaurant fires. We are simply CLEANING things that need to be cleaned. We don't need any certification to be required by any government entity just to make a living for our families.

Who wins in these situations? Not the contractor. As important as it is to make sure kitchen exhausts are cleaned go ahead and ask all the KEC guys how much their income has gone up since "certification". Go ahead, ask. If they are being honest they will tell you zero and they are STILL complaining about hacks and lowballers and will continue to do so forever because the government does not make things better, they just make them more expensive.

Who wins? The only winner is the entity charging for the certification.

How about we ask the PWNA to make this certification free of charge permanently to all members and non members if it's "contractors" and the "environment" that is on the top of their goals. Let's see how far that goes.

LEARN the law first. Teach the law to the contractors. Don't invite the government into our industry. When they come in - fight them WITH the LAW. You can't do that unless you KNOW THE LAW.

[Ron Musgraves 240]

Same Day , same Story

[tonyshelton 112]

Almost a year later and they are aready sending representatives from Texas and California and elsewhere to Arizona trying to make the Arizona officials "enforce" the law as THEY interpret it.

Who can believe anything they say anymore.

[bigchaz 157]

· The PWNA is not going to bring, or shop, the BMPs to municipalities, city leaders or roll them out across the country. That was never mentioned as our plan and I don't know where

that came from. Second, we don't have the money or resources for such an undertaking.

Always a good quote