United States
Environmental
Protection Agency
Office of Water
Washington DC 20460
EPA-833-R-01-001
June 2001
Protecting the Nation's Waters
Through Effective NPDES Permits
A Strategic Plan FY2001 AND BEYOND
WATER PERMITS DIVISION
OFFICE OF WATER
U.S. EPA
WASHINGTON, DC 20460
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STRATEGIC OUTLOOK
Since the creation of the Clean Water Act in 1972, the National Pollutant Discharge Elimination
Systems (NPDES) program has been a major force in the nation's efforts to protect and restore
the quality of our rivers, lakes, and coastal waters. Thirty years ago, only one-third of our
waters were considered healthy. Today, approximately two-thirds are healthy. This progress has
brought a wide range of environmental, recreational, and economic benefits to millions of
Americans.
The NPDES program faces at least two significant challenges in the near future. First, we must
safeguard our gains in water quality and strive to improve those waters still impaired by
pollution. Increases in population and development will stress infrastructure, threatening the
progress the nation has made. This will make future improvements to water quality more
difficult to achieve. Second, the NPDES program must extend its influence beyond the tradi-
tional boundaries of the program to promote comprehensive solutions to the diverse and
complex problems that continue to threaten the quality of the nation's waters. This strategic
plan provides guidance and direction for making progress on both of these fronts.
Water quality protection is becoming increasingly complex—scientifically and socially. This plan,
and succeeding iterations, must address this complexity by adapting to new information,
emerging science and technology, and the evolving needs of stakeholders. States, tribes,
municipalities, industry, agriculture, and citizens can use this plan as a guide to become active
partners in the NPDES program and, more broadly, in protecting and restoring the nation's
watersheds.
Because this strategic plan is intended to be a living document, Readers are encouraged to read
and comment on it. Readers can find this document and much more information on our
programs at our new website: www.epa.gov/npdes. Comments may be sent to the address on
the next page.
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Contents
WATER PERMITS DIVISION STRATEGIC PLAN
Introduction to the Water Permits Division Strategic Plan
Backgroun d 1
Water Permits Division Organization and Resources 4
Current 1 implementation Activities 5
Water Permits Division Vision and Mission
Vision & Mission 7
Challenges on the Horizon 7
Strategic Issues and Key Actions—2001 through 2006
Overvi ew 9
Summary of Strategic Issues and Key Strategic Goals and Key Actions—2001 through 2006 9
Environmental Issues 9
Program Administration Issues 12
Conclusions... .15
Write us at:
U.S. Environmental Protection Agency
Office of Wastewater Management
ICC Building
1200 Pennsylvania Ave.. N.W.
7th Floor. Mail Code: 4201 M
Washington. DC 20460
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Introduction
"RESTORE AND MAINTAIN THE PHYSICAL, CHEMICAL AND BIOLOGICAL
INTEGRITY OF THE NATION'S WATERS."
The Clean Water Act
BACKGROUND
In 1972, Congress created the Clean Water Act
;CWA) to address serious pollution problems
affecting the nation's rivers, lakes, and coastal
waters. The central objective of the Act is to "restore
and maintain the chemical, physical and biological
integrity of the nation's waters."
The Clean Water Act is a comprehensive set of
programs and requirements designed to address the
complex problems caused by a wide variety of
pollution sources. One of the cornerstones of the Act
is the National Pollutant Discharge Elimination
System (NPDES), which regulates the discharge of
pollutants into the waters of the U.S. Under the CWA,
NPDES permits are issued to industrial, municipal,
and other point source dischargers by either EPA or
an authorized state.
NPDES Permit Program Accomplishments
Over the past 30 years, the NPDES program has
played a key role in restoring the quality of the
nation's waters. In 1972, only one third of our rivers,
lakes, and coastal waters were considered fishable
and swimmable. Today, approximately two thirds of
our waters are healthy. More than 50 categories of
industry (including several hundred thousand busi-
nesses) and the nation's network of more than 16,000
municipal sewage treatment systems comply with
standards implemented in NPDES permits. These
permits have resulted in the removal of billions of
pounds of conventional pollutants and millions of
pounds of toxic pollutants annually.
Scope of the NPDES Permit Program
Since the inception of the NPDES program, the number
of facilities required to have NPDES permits has
quadrupled. This growth is the result of a number of
changes to the program, including reauthorization of
the CWA in 1987, which significantly expanded the
scope of the NPDES program. Figure 1 shows the
growth in the number of sources required to have
NPDES permits. Today, more than 400,000 facilities are
required to have NPDES permits. EPA expects that this
universe will continue to grow, particularly with the
implementation of new storm water requirements in
2003. Figure 2 describes the types of facilities covered
by the NPDES program.
Figure 1. Growth of the NPDES Program
(number of facilities or sources)
BUUUUU
500000
400000
300000
200000
100000
n
500,000 +
r~
400,000
370,000
100,000
Figure 2. Who Must Have an NPDES Permit?
The Clean Water Act requires anyone discharging pollutants from any
point source into waters of the U.S. to obtain an NPDES permit from
EPA or an authorized state. Typical point sources regulated under the
NPDES program include:
• Municipal wastewater systems
• Municipal and industrial storm water systems
• Industries and commercial facilities
• Concentrated Animal Feeding Operations
1972
1992
2001 Future
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State NPDES Program Authority
No authority
NPDES authority
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A Strong Partnership with the States
Today, 44 states and one territory are authorized to
implement the NPDES program. State implementa-
tion is a fundamental concept that runs throughout
the Clean Water Act and is also a cornerstone of the
NPDES program. A state's authorization to imple-
ment this program allows state managers to set
priorities and tailor the program to meet the chal-
lenges facing the waters in that state and to satisfy
the desires of its citizens. EPA works closely with the
states to ensure a level of national consistency and
assist states in meeting their environmental goals and
objectives. As "co-regulators," the authorized states
play a unique role by helping to shape and develop
the national program. This year EPA will implement
several ideas to strengthen this partnership (see
Strategic Issues and Key Actions).
Our Stakeholders
Stakeholders play a critical part in the implementa-
tion and development of the NPDES program. EPA
plans to take several steps this year to improve
communication and coordination with our stakehold-
ers. Our stakeholders include:
us
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Relationship to EPA's Strategic Plan
EPA's 2000 Strategic Plan provides an overall
framework for achieving the Agency's mission "to
protect human health and safeguard the natural
environment." This NPDES Program Strategic Plan
is intended to support that overall mission. Specifi-
cally, the NPDES program directly supports Goal 2
of the overall EPA Strategic Plan, which is entitled
"Clean and Safe Water." There are two specific
objectives related to the NPDES program.
"By 200S, 5,000 additional miles of water will
attain water quality standards and specific interim
milestones will be achieved in 50,000 impaired
miles."
"By 2005, using both pollution control and
prevention approaches, reduce at least 3 billion
pounds of pollutant source loadings from key
sources including a combined 11 percent reduction
from industrial sources, POTWs, and combined
sewer overflows (CSOs)."
For more information on EPA's Strategic Plan, see
www.epa.gov/ocfopage/plan/plan.htm.
Measuring and reporting environmental results is a
significant element in EPA's strategic planning
efforts and, in fact, is mandated under the Govern-
ment Performance and Results Act (GPRA). EPA
has developed a set of measures to help document
the success of the NPDES program and will
continue to refine them to reflect program accom-
plishments (see Strategic Issues and Key Actions).
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WATER PERMITS DIVISION ORGANIZATION AND RESOURCES
Organization
EPA's Water Permits Division is proud of its contribu-
tions to the development of and ongoing leadership
role in the NPDES permit program. Recently, the
Water Permits Division implemented a new organiza-
tional structure to foster improved implementation of
the NPDES permit program and to better address
stakeholder needs. Figure 3 shows the Division's
structure and general areas of responsibility.
Figure 3. Structure of the Water Permits Division
Water Permits I
Division
StatefRegional 1
Branch
Municipal
Branch
h
Industrial _ _
Branch
i
_ Rural
Branch
• State/Tribal Authorization
• Permit Issuance Process
• Legal and Policy
Interpretation
• Water Quality Permitting
• Municipal Permitting
• Pretreatment
• Sewer System Overflows
• Storm Water (Municipal)
• Biosolids
• Septic Systems
' Industrial Permitting
' Stormwater (Industrial and
Construction)
' Pretreatment
' Oil and Gas
' Mining
'Cooling Water Intakes [316(b)]
1 Animal Feeding
Operations
1 Forestry
1 Pesticides
> Aquaculture
> Water Transfers
Resources
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Figure 4 compares the growth in the number
of facilities covered by the NPDES program to
the relatively stable level of the program's
resources. Over the last decade the number of
facilities included in the NPDES program has
risen dramatically while the Water Permits
Division's resources have remained essentially
constant. Resource levels in the Regions and
States have remained constant as well.
Figure 4. Trend of Available Resources
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CURRENT PROGRAM IMPLEMENTATION
ACTIVITIES
major program area.
NPDES Program Implementation
Assessment of state program health,
including recognition of vulnerability trends
and innovations within the program, with
potential regulation revisions
Electronic reporting, including automated
NPDES permit applications and discharge
monitoring reports
Assistance to tribal governments on
NPDES issues and programs, including
authorization
Ensure quality and consistency in state NPDEE
permit programs, including state program
authorizations, modifications, and review of
petitions for state program withdrawal.
- NPDES Permit Writer's Course
- NPDES Permit Applicant's Course
- Pretreatment Courses
- Storm Water Implementation Course
- Supporting development and refinement of
sound water quality standards
- Implementing policies to ensure NPDES
permits reflect Total Maximum Daily Loads
- Implementing Whole Effluent Toxicity testing
policies
- Developing water quality permitting
guidance
Storm Water Program
• Ensure effective implementation of the Storm
Water Program, including Phase I, Phase 11,
and reissuance of the Multi-Sector General
Permit.
Sewer System Overflows
• Develop and implement a program to address
sanitary sewer overflows (SSOs), including a
proposed rulemaking to address system
management and overflows from over 16,000
municipal sewer systems nationwide.
• Fully implement the Combined Sewer Over-
flow (CSO) Control Policy, including develop-
ment of a CSO water quality standards
guidance, an implementation tracking system,
performance measures, and requirements of
the Wet Weather Water Quality Act of 2000.
Pretreatment Program
• Continue implementation of the National
Pretreatment Program, including finalizing the
pretreatment streamlining rule and the Pre-
treatment Program Project XL rule.
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Rural Program
- Work with states to increase permitting of
existing Concentrated Animal Feeding
Operations (CAFOs)
- Issue revised regulations for Concentrated
Animal Feeding Operations (CAFO)
- Conduct outreach and support training for
states, the agriculture industry and the
public
- Work with USDA to implement voluntary
programs for animal feeding operations
Administrative Systems
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OUR VISION: EVERY WATERSHED IN THE U.S. IS FREE FROM IMPAIRMENTS
CAUSED BY INDUSTRIAL, MUNICIPAL, AND OTHER POINT SOURCE DISCHARGES.
OUR MISSION:
EPA's Water Program:
Shapes National Program Direction by identify
ing issues of national or regional concern and
developing and implementing realistic strategies to
address these issues.
Produces Policy and Regulation to address
problems affecting the nation's waters, while
preventing transfer of environmental problems to the
air and land.
Develops Technical and Administrative Tools
to help state and EPA permit writers and program
managers implement solutions through NPDES
permits.
Tracks and Manages Information on permit
issuance, permit quality, and point source pollution
abatement to measure the effectiveness of the
NPDES program and refine its management.
Communicates with Stakeholders by informing
them of program goals and providing them with
policies and information to foster more effective
participation in the NPDES program.
CHALLENGES ON THE HORIZON
A wide variety of factors influence how we work to
protect watersheds. The following issues have helped
to shape our strategic plan and will continue to
influence implementation of the NPDES program. In
coming years, we will continue to update and refine
this list of issues and this plan.
Watershed Driven Solutions to Address Remaining
Water Quality Challenges
Over the last 30 years, we have made great progress
nationally in addressing large-scale water pollution
problems from a relatively limited universe of
municipal sewage treatment systems and major
industrial sources. Indeed, our efforts have substan-
tially improved the quality of the nation's rivers, lakes
and coastal waters. Nevertheless, there are still
significant water quality challenges ahead.
The nature of these remaining water quality prob-
lems is very different from those faced in the early
years of this program. Remaining sources tend to be
much smaller, more numerous and more widely
distributed, and less amenable to traditional end-of-
pipe controls. For instance, effectively addressing
several hundred thousand storm water sources and
thousands of concentrated animal feeding operations
around the country requires innovative approaches.
Further complicating this picture is the fact that each
watershed has unique physical and hydrological
characteristics and may be stressed by a unique
combination of pollution sources, including both
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point and nonpoint (runoff). As a result, a significant
challenge will be to reorient the NPDES program to
better address the specific needs of individual
watersheds.
New Watershed Science
EPA conducts research on the impacts of pollutants
on watersheds. Our knowledge of watersheds and
the complex interaction of pollutants within different
types of watersheds has increased in recent years. As
a result we are now able to begin establishing water
quality standards to address remaining problems,
such as nutrient and pathogen pollution. Because
these pollutants impact ecosystems in a variety of
ways, they present special challenges for the NPDES
program. A detailed understanding of the hydrologi-
cal and biological characteristics of each affected
watershed is needed to develop and implement
permit limits and other controls.
Total Maximum Daily Loads
Total Maximum Daily Loads (TMDLs) are essentially
pollution budgets for specific river segments or other
waterbodies. EPA and the states are scheduled to
develop as many as 40,000 TMDLs over the next 15
years. The development of TMDLs is scientifically,
legally and politically challenging. In addition, the
workload associated with implementing 40,000
TMDLs will present significant management chal-
lenges to EPA and the states.
Program Expansion and Evolution
The scope of the NPDES program has continued to
expand since its inception. As we move toward fuller
implementation of the watershed approach, the
NPDES program will need to better address remain-
ing sources of pollution (including storm water and
concentrated animal feeding operations). New efforts
will include innovations and partnerships such as
comprehensive environmental management systems
and "best management practices" for non-traditional
sources in lieu of end-of-pipe controls. Working
closely with the states and other federal partners will
be crucial to ensure that new approaches achieve
real environmental results.
The Information Age
The information age has ushered in a new and
important role for EPA. With the advent of the
Internet and major advances in geographic informa-
tion technology, we are now able to provide the
public with a wealth of information about the
characteristics of the watersheds in which they live.
The NPDES program has much to contribute to the
growing body of watershed information. We must
also improve our data collection efforts to include
newer categories such as storm water, concentrated
animal feeding operations, and sewer system
overflows. Web technology also offers new and
innovative ways to collect and disseminate informa-
tion.
New Initiatives
The NPDES program must always be ready to
address new developments. Congress, the Adminis-
tration, court decisions, and developments around
the country can have a significant impact on the
direction and focus of the NPDES program. Our
strategic plan must be flexible enough to accommo-
date changes; therefore, we will update it regularly.
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AN EFFECTIVE STRATEGIC PLAN MUST IDENTIFY AND OFFER A CLEAR PLAN TO
ADDRESS KEY ISSUES.
OVERVIEW
A strategic issue is a fundamental policy question or
challenge related directly to an organization's
mission. To formulate our strategic issues, we
carefully considered a wide range of factors,
including environmental priorities and trends, future
challenges, mandates, the needs of our partners and
stakeholders, and resources.
This process led to the identification of eight strategic
issues. The next step was to identify the actions
necessary to begin addressing each issue. This plan
highlights major courses of action designed to help
address each strategic issue. These strategic issues
and key actions create the framework for this
strategic plan and will, in turn, define and shape
actions, programs, policies and resource allocations
for the coming years.
SUMMARY OF STRATEGIC ISSUES AND
KEY STRATEGIC GOALS AND KEY ACTIONS
2001-2006
ENVIRONMENTAL ISSUES
1. Support Watershed Planning
In order to continue improving the quality of the
nation's waters, we must tailor our strategies and
programs to the specific needs of individual water-
sheds. Past efforts have focused largely on national,
"one-size-fits-all" programs rather than more flexible
watershed-oriented approaches. The nature and
diversity of the water quality challenges ahead
require us to reinvent the concept of permitting and,
perhaps, the entire NPDES program. Working in
close collaboration with a broad array of stakehold-
ers is imperative to successful implementation of
watershed strategies. Further, taking a broader, more
flexible view of our program in a watershed context
will be required to move forward with solutions that
will improve water quality. Our challenge is to find
ways in which the NPDES program can adapt to
these challenges and actively promote
watershed-based strategies.
Strategic Goal: Restructure the permits program
and seek changes in the water quality standards,
TMDL, and enforcement programs to promote
planning, development, and implementation of
environmental programs on a watershed basis.
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Priority setting is the key to the watershed approach
and must be considered at two levels. First, priorities
must be set among watersheds—for those that are
most impaired and those that are most in need of
protection. Second, within high-priority watersheds,
potential restoration and preservation actions must
be evaluated and prioritized. For the NPDES pro-
gram, such priority setting will help determine
where, when, and how we will reissue NPDES
permits and implement new standards and TMDLs.
Much of the decision making in a watershed framework
occurs at the state and local level. Nationally-led
programs, such as the NPDES program, must con-
stantly work to develop management tools and other
opportunities for flexibility that enhance state and local
leadership. The NPDES program has begun exploring
the potential for municipal "integrated watershed"
permits to further this kind of local decision making and
flexibility.
2. Permit and Program Quality, Consistency, and
Innovation
By December 2002, sponsor the development of
pilot integrated watershed NPDES permits that bring
together the full range of municipal programs (e.g.
pretreatment, CSOs, SSOs, storm water) on a
watershed basis.
The issuance of an NPDES permit represents the
culmination of much effort by many programs under
the umbrella of the Clean Water Act. Water quality
standards, technology-based requirements, and TMDLs
all find their final expression in the text of NPDES
permits. Because NPDES permits are fundamental to
the Clean Water Act, the quality and completeness of
each permit is critical. As mentioned earlier, EPA and
the authorized states share responsibility for implement-
ing the NPDES program. State administered programs
promote day-to-day decision making at a level more
attuned to the situation in individual watersheds. One of
the primary challenges inherent in any delegated
program is maintaining the appropriate balance
between these objectives. EPA's challenge is to provide
management tools, technical assistance, and guidance
to support the states in their efforts to implement the
NPDES program and, at the same time, ensure a
reasonable level of consistency across the country.
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had grown substantially and that this situation
warranted significantly increased attention by the
states and EPA. This problem continues to be
identified and managed as a "material weakness" in
the Federal Managers Financial Integrity Act (FMF1A)
report. A related issue facing the program is the
increasing number of lawsuits and petitions challeng-
ing states on their implementation of the NPDES
program. These legal actions seek to have EPA
withdraw the NPDES program (or portions of it).
In order to address these issues, EPA and the states
have initiated efforts on several fronts to help us
meet the goal of improved integrity, consistency, and
effectiveness of the NPDES program. EPA and the
states have adopted a detailed strategy to address
the timely issuance of permits. In addition, EPA and
the states are working to build a comprehensive set
of tools to assist states in their management of the
program and to improve the quality of the permits
they issue. Additionally, EPA and the states will be
working together on a longer-term project to
improve the information and management systems
that support the NPDES program.
Another management tool, known as environmental
management systems (EMS), could be effective in
meeting this goal and the broader goal of clean
water. Environmental management systems are
comprehensive and proactive systems that help
organizations manage their facilities and programs in
ways that promote long-term compliance with
environmental requirements. Such systems help
promote corporate and organizational responsibility
and frequently minimize the need for government
inspections and enforcement actions. Our challenge
will be to find opportunities to build these concepts
into our new initiatives and existing programs.
By December 2001, Water Permits Division will
continue to emphasize the goal of reducing the
backlog of major permits to 10% or less and will
work closely with Regions and states towards its
achievement.
During 2002, develop a package of management
tools, guidance, and assistance to support states in
maintaining and improving the overall health of the
NPDES programs in preparation for piloting in
several states.
During 2001, look for opportunities to extend the
environmental management systems concept within
the NPDES program. Document opportunities and
set priorities by December 2001.
By December 2004, Water Permits Division will
continue to emphasize the goal of reducing the backlog
of all permits to 10% or less and will work closely with
Regions and States towards its achievement.
3. Standards to Permits
Incorporating water quality standards into permits
can be a complex process. The water quality stan-
dards being developed today are scientifically more
complex and often require specialized implementa-
tion in different ecological regions. TMDLs add
another layer of complexity in that a given facility
must be considered within the context of the water-
shed and the other sources of pollution in that
watershed. Further complicating this picture are
several factors including: the need to consider
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varying hydrological conditions (wet and dry
weather), some outdated water quality standards,
inappropriate classification of waterbodies, inconsis-
tent availability of water quality data, and lack of
standardized water-quality-to-standards translation
methodologies.
Strategic Goal: Guide the consistent and effective
translation of water quality goals and standards into
permit limits and conditions.
In the near future, the workload associated with
implementing the NPDES program is expected to
increase dramatically. The authorized states will need
substantial assistance from EPA to remain successful.
Our challenge will be to provide the technical
assistance, training, and guidance to ensure that
states have clear policies for translating standards to
permits and that NPDES permits reflect the latest
water quality and technology-based standards, and
TMDLs in a timely manner. The NPDES program will
also need to be more actively engaged with the water
quality standards, effluent guidelines (technology-
based requirements) and TMDL programs to ensure
that the needs of permit writers are considered as
these programs evolve.
By September 2003, complete initial reviews of the
health of state water quality permitting programs
and document and distribute state innovations in the
standards-to-permits process.
PROGRAM ADMINISTRATION ISSUES
4. Modernizing the Permit Management System
Information technology has radically changed the
way data and information can be collected, man-
aged, and made available. The information systems
that support the NPDES program are now obsolete.
The latest advances in information technology afford
us many opportunities including: development of
more effective management systems, streamlined
data collection, geographic referencing and integra-
tion with other water-related information, and online
access for the public.
Many states have made significant progress in
developing and using online data systems. Using new
technologies, the NPDES program needs to be
supported by a new information system that con-
nects with and enhances these efforts. Our challenge
is to develop technology that will streamline the
permitting process, provide for easier and more
meaningful access to information, and integrate with
existing state systems.
Strategic Goal: Develop an efficient and effective
NPDES information management system (that auto-
mates and streamlines the permit application, issuance
and administration process) utilizing state-of-the-art
technology and building upon existing state innovations.
One of the most important aspects of this effort will
be the move from paper-based to highly efficient,
online applications and reporting forms. Coordina-
tion with the Agency's other information manage-
ment programs will also be essential.
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5. Measuring Environmental Results
Measuring and reporting of environmental progress
and results are critical aspects of managing any
environmental program and serve as the basis for
communicating progress and for public accountability.
In 1993, Congress passed the Government Perfor-
mance and Results Act (GPRA) to focus and improve
the federal government's efforts in this area. During
the last seven years, the NPDES program has devel-
oped and implemented a set of measures, but we still
have much work to do. Presently, the program collects
information and data necessary to support program
implementation, but our ability to describe environ-
mental results is limited. Our challenge is to work with
states, municipalities, and industry to develop a
framework for expressing environmental results and
an agreement on the information that will be gathered
to support it.
Strategic Goal: Improve the measurement and
reporting of environmental results for the NPDES
permit program.
The most important step in creating measures of
environmental results is to identify the questions we
want to answer about the effect of the NPDES
program on water quality. Then we can determine
what additional information we need and incorporate
it into our existing information management systems.
6. Better Communication and Participation of
Stakeholders
EPA and the states are involved in a unique partner-
ship for the implementation of the NPDES program.
In order for this partnership to succeed, we must
maintain close lines of communication. We are
increasingly aware that successful implementation of
the NPDES program is contingent upon constant
communication between EPA and the states in every
aspect of the program, from policy development to
implementation to enforcement.
Success of the NPDES program also depends on the
informed and active involvement of key external
stakeholders including the regulated community,
interests groups and the public. We recognize the need
to work more closely with the full range of groups
interested in and affected by the NPDES program.
Finally, EPA and the states share responsibility for
making information available to the public. New
technologies, such as the Internet, provide enhanced
opportunities to disseminate information. Our
challenge will be to use both new and traditional
methods to provide high quality, understandable
information to the public.
Strategic Goal: Improve communication with and
increase the involvement of stakeholders in the
implementation of the NPDES program.
A good starting point for better communication with
the states is to establish a core group of representa-
tives to voice the perspectives and concerns of their
jurisdictions. For our external stakeholders, we will
ensure our web site meets their diverse needs—
providing a range of information from training
courses to guidance documents—and provides them
with the opportunity to participate in our efforts.
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By December,2001, EPA will initiate an Executive
Council to help guide the development and imple-
mentation of the NPDES program. The Council will
include state and EPA representatives and will advise
EPA management on a full range of issues facing the
NPDES program.
7. Planning and Administration
Given the limitations on the resources available to
implement the NPDES program (see figure 4), there
is an increased need to engage in meaningful
planning to set priorities and utilize resources
efficiently. With an increasing workload, resources
are often drawn from base program activities that, in
the longterm, are critical to this program's success
(for more on this topic see Strategic Issue 2). This
strategic plan is a first step toward managing
available resources, and setting and communicating
priorities to both internal and external stakeholders.
training to stakeholders on a variety of issues and
programs, providing them with important regulatory
and policy information and facilitating compliance
with environmental requirements.
Finally, EPA must address a variety of administrative
and management issues related to the operation of
our programs, including recordkeeping, manage-
ment and support systems, and rulemaking proce-
dures. EPA is working on a number of fronts to
utilize new information management technology to
streamline some of these processes and to improve
quality control where appropriate.
Strategic Goal: Institutionalize a strategic planning
process for the NPDES program, address the training
needs of both internal and external stakeholders, and
improve our administrative systems and procedures.
Achievement of this goal will be crucial to the
successful implementation of the NPDES program
over the longterm. EPA will need to find efficient
solutions to these issues and to implement them
consistently over time.
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CONCLUSIONS
The NPDES program is a cornerstone of the Clean
Water Act. This program is directly responsible for
preventing the discharge of billions of pounds of
pollutants to the nation's rivers, lakes and coastal
waters each year. We hope this strategic plan helps
to demonstrate some of the important accomplish-
ments of this successful program.
frames the issues that we believe will influence our
future activities. We are committed to working with
our state partners and other stakeholders to further
refine this Plan and the programs that it represents
to achieve the goal of clean and safe water.
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