We do this work.
So we built this.

What we do

We work on the compliance side of water and wastewater: technical document review, regulatory interpretation, permit and enrollment work, root cause evaluation, and quality assurance on other people’s engineering. Most of it is the unglamorous part. Reading the order properly. Working out which board actually holds a facility. Noticing that two agency documents say different things before somebody files against the wrong one.

The winery work is a large part of that at the moment, because the statewide Winery Order brought at least 1,481 California wineries from no permit at all into a permitting program with real reporting duties. That figure is built from the Order’s own findings, both on printed page 1. Finding 2 records the Wine Institute’s estimate that 2,070 of California’s 3,612 bonded wineries will be subject to the Order. Finding 3 records that, on a 2020 estimate, 589 were already permitted by a regional board, under general waste discharge requirements, individual requirements or a conditional waiver.

Those 589 are counted against all 3,612, not against the 2,070, so the difference is a floor rather than an answer: at least 1,481 wineries were brought in holding nothing, and the real figure is that or higher. It is worth being exact about which, because the looser version of this sentence was on this page until an outside reviewer caught it. The rest are working out what it means without help.

Why this site is free, and staying free

Because the alternative is worse for everybody, including us.

Most of what a winery needs to know about the Winery Order is not secret. It is public, and it is scattered across a 119 page order, a 25 page attachment, nine regional board websites, a county program or two, and a set of documents that do not entirely agree with each other. The work is not access. The work is reading it and being honest about the parts that are unclear.

So the reading is free. Every page, every document, the calculator, the alerts and the conflict ledger. Nothing here is gated behind an email address, and the alert list exists to tell people when rules change rather than to build a sales pipeline.

What we sell is the part a page cannot do: looking at your file, your volumes, your permit of record, and telling you where you actually stand.

What we will not do here

This site has some rules it holds itself to, and they are worth stating plainly because they are the reason to trust anything on it.

• We show our sources. Page numbers, order numbers, adopted text. If a claim rests on a staff report or a trade bulletin rather than adopted text, the page says so, because those are not the same thing.
• We do not resolve conflicts by picking one. Where two authoritative sources disagree, both appear, with the document and page on each side, in the conflict ledger, which counts itself rather than trusting a number typed into this sentence.
• We publish our corrections. Every change to this site is logged with the date and, where it is not obvious, the reason. Including the times we were wrong. The log is here.
• We mark what was only reported to us. Now and then somebody working in a region tells us something a board has not published, and leaving it out would mislead more than including it. Those appear marked as reported, saying what we do and do not know and who has published nothing about it, and they never sit in the same visual register as adopted text. If you can only act on what you are able to check yourself, treat those blocks as a prompt to go and ask, not as an answer.
• We say when we do not know. Some questions on this site are marked unanswered because nobody has published an answer. Guessing at those would be the most expensive thing we could do to a reader.

If you find something here that is wrong, we would genuinely rather hear it than not. That is not a courtesy line: external review passes have found real errors on this site, and the corrections are logged with their dates.

Who you are actually dealing with

Ashley Boudet, Principal Consultant. This site is her work: the reading, the document checks, the calls to regional boards, and the corrections when it turned out to be wrong. If something here is right, that is why. If something here is wrong, there is a person to tell.

BCG Water LLC trades as Boudet Consulting Group and is a Pivora Collective company, based at 4225 Solano Ave, Napa, California. You can check the firm independently of this site: bcgwater.com.

Where a page stops being enough

Everything on this site is general. Your position depends on your permit of record, your reported volumes, and whether anything at your facility has changed since it was issued. Those are facts about you that no public page can know.

Two ways forward, depending on where you are.

Contact

BCG Water LLC, 4225 Solano Ave, Napa, CA 94558.
compliance@bcgwater.com · 707 582 8592

BCG Water LLC is a Pivora Collective company. This site is published as general regulatory information and is not engineering advice, legal advice, or a compliance determination for any specific facility. Why this site exists →