A Strategic Plan FY 2001 AND BEYOND

WAWAWAWAWATER PERMITS DIVISIONTER PERMITS DIVISIONTER PERMITS DIVISIONTER PERMITS DIVISIONTER PERMITS DIVISION

OFFICE OF WATERU.S. EPA

WASHINGTON, DC 20460

United StatesEnvironmentalProtection Agency

Protecting the Nation’s WatersThrough Effective NPDES Permits

EPA-833-R-01-001June 2001

Office of WaterWashington DC 20460

STRATEGIC OUTLOOK

Since the creation of the Clean Water Act in 1972, the National Pollutant Discharge EliminationSystems (NPDES) program has been a major force in the nation�s efforts to protect and restorethe quality of our rivers, lakes, and coastal waters. Thirty years ago, only one-third of ourwaters were considered healthy. Today, approximately two-thirds are healthy. This progress hasbrought a wide range of environmental, recreational, and economic benefits to millions ofAmericans.

The NPDES program faces at least two significant challenges in the near future. First, we mustsafeguard our gains in water quality and strive to improve those waters still impaired bypollution. Increases in population and development will stress infrastructure, threatening theprogress the nation has made. This will make future improvements to water quality moredifficult 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 andcomplex problems that continue to threaten the quality of the nation�s waters. This strategicplan 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 activepartners in the NPDES program and, more broadly, in protecting and restoring the nation�swatersheds.

Because this strategic plan is intended to be a living document, Readers are encouraged to readand comment on it. Readers can find this document and much more information on ourprograms at our new website: www.epa.gov/npdes. Comments may be sent to the address onthe next page.

WATER PERMITS DIVISION STRATEGIC PLAN

Introduction to the Water Permits Division Strategic Plan

Background .................................................................................................................................. 1

Water Permits Division Organization and Resources ..................................................................... 4

Current 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

Overview ....................................................................................................................................... 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

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Contents

For more information:visit our website at www.epa.gov/npdes.

Write us at:U.S. Environmental Protection Agency

Office of Wastewater ManagementICC Building

1200 Pennsylvania Ave., N.W.7th Floor, Mail Code: 4201M

Washington, DC 20460

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BACKGROUND

In 1972, Congress created the Clean Water Act(CWA) to address serious pollution problemsaffecting the nation�s rivers, lakes, and coastalwaters. The central objective of the Act is to �restoreand maintain the chemical, physical and biologicalintegrity of the nation�s waters.�

The Clean Water Act is a comprehensive set ofprograms and requirements designed to address thecomplex problems caused by a wide variety ofpollution sources. One of the cornerstones of the Actis the National Pollutant Discharge EliminationSystem (NPDES), which regulates the discharge ofpollutants 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 oran authorized state.

NPDES Permit Program Accomplishments

Over the past 30 years, the NPDES program hasplayed a key role in restoring the quality of thenation�s waters. In 1972, only one third of our rivers,lakes, and coastal waters were considered fishable

and swimmable. Today, approximately two thirds ofour waters are healthy. More than 50 categories ofindustry (including several hundred thousand busi-nesses) and the nation�s network of more than 16,000municipal sewage treatment systems comply withstandards implemented in NPDES permits. Thesepermits have resulted in the removal of billions ofpounds of conventional pollutants and millions ofpounds of toxic pollutants annually.

Scope of the NPDES Permit Program

Since the inception of the NPDES program, the numberof facilities required to have NPDES permits hasquadrupled. This growth is the result of a number ofchanges to the program, including reauthorization ofthe CWA in 1987, which significantly expanded thescope of the NPDES program. Figure 1 shows thegrowth in the number of sources required to haveNPDES permits. Today, more than 400,000 facilities arerequired to have NPDES permits. EPA expects that thisuniverse will continue to grow, particularly with theimplementation of new storm water requirements in2003. Figure 2 describes the types of facilities coveredby the NPDES program.

Introduction

“RESTORE AND MAINTAIN THE PHYSICAL, CHEMICAL AND BIOLOGICAL

INTEGRITY OF THE NATION’S WATERS.”

— The Clean Water Act

Figure 1. Growth of the NPDES Program(number of facilities or sources)

The Clean Water Act requires anyone discharging pollutants from anypoint source into waters of the U.S. to obtain an NPDES permit fromEPA or an authorized state. Typical point sources regulated under theNPDES program include:

� Municipal wastewater systems

� Municipal and industrial storm water systems

� Industries and commercial facilities

� Concentrated Animal Feeding Operations

Figure 2. Who Must Have an NPDES Permit?

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A Strong Partnership with the States

Today, 44 states and one territory are authorized toimplement the NPDES program. State implementa-tion is a fundamental concept that runs throughoutthe Clean Water Act and is also a cornerstone of theNPDES program. A state�s authorization to imple-ment this program allows state managers to setpriorities and tailor the program to meet the chal-lenges facing the waters in that state and to satisfythe desires of its citizens. EPA works closely with thestates to ensure a level of national consistency andassist states in meeting their environmental goals andobjectives. As �co-regulators,� the authorized statesplay a unique role by helping to shape and developthe national program. This year EPA will implementseveral ideas to strengthen this partnership (seeStrategic Issues and Key Actions).

Our Stakeholders

Stakeholders play a critical part in the implementa-tion and development of the NPDES program. EPAplans to take several steps this year to improvecommunication and coordination with our stakehold-ers. Our stakeholders include:

� States, tribes, and territories

� Regulated community (e.g., industry,agriculture, and municipalities)

� Citizens

� Interest groups

� Congress

� Other federal agencies

State NPDES Program Authority

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Relationship to EPA�s Strategic Plan

EPA�s 2000 Strategic Plan provides an overallframework for achieving the Agency�s mission �toprotect human health and safeguard the naturalenvironment.� This NPDES Program Strategic Planis intended to support that overall mission. Specifi-cally, the NPDES program directly supports Goal 2of the overall EPA Strategic Plan, which is entitled�Clean and Safe Water.� There are two specificobjectives related to the NPDES program.

Objective

�By 2005, increase by 175 the number of water-sheds where 80 percent or more of assessedwaters meet water quality standards.�

Result

�By 2005, 5,000 additional miles of water willattain water quality standards and specific interimmilestones will be achieved in 50,000 impairedmiles.�

Objective

�By 2005, reduce pollutant loadings from key pointand nonpoint sources by at least 11 percent from1992 levels.�

Result

�By 2005, using both pollution control andprevention approaches, reduce at least 3 billionpounds of pollutant source loadings from keysources including a combined 11 percent reductionfrom industrial sources, POTWs, and combinedsewer overflows (CSOs).�

For more information on EPA�s Strategic Plan, see

wwwwwwwwwwwwwww.epa.gov/ocfopage/plan/plan.htm.epa.gov/ocfopage/plan/plan.htm.epa.gov/ocfopage/plan/plan.htm.epa.gov/ocfopage/plan/plan.htm.epa.gov/ocfopage/plan/plan.htm.

Measuring and reporting environmental results is asignificant element in EPA�s strategic planningefforts and, in fact, is mandated under the Govern-ment Performance and Results Act (GPRA). EPAhas developed a set of measures to help documentthe success of the NPDES program and willcontinue to refine them to reflect program accom-plishments (see Strategic Issues and Key Actions).

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Figure 3. Structure of the Water Permits Division

Figure 4. Trend of Available Resources

Organization

EPA�s Water Permits Division is proud of its contribu-tions to the development of and ongoing leadershiprole in the NPDES permit program. Recently, theWater Permits Division implemented a new organiza-

WATER PERMITS DIVISION ORGANIZATION AND RESOURCES

Resources

The Water Permits Division has three primarycategories of resources available to accomplishits mission:

� Skilled employees

� Funds for contractor support

� Funds for grants to states, municipalitiesand others

Figure 4 compares the growth in the numberof facilities covered by the NPDES program tothe relatively stable level of the program�sresources. Over the last decade the number offacilities included in the NPDES program hasrisen dramatically while the Water PermitsDivision�s resources have remained essentiallyconstant. Resource levels in the Regions andStates have remained constant as well.

tional structure to foster improved implementation ofthe NPDES permit program and to better addressstakeholder needs. Figure 3 shows the Division�sstructure and general areas of responsibility.

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CURRENT PROGRAM IMPLEMENTATIONACTIVITIES

This strategic plan focuses on new and cross-cuttingactivities. The following section is intended to providea brief overview of the ongoing activities in eachmajor program area.

NPDES Program Implementation

� Support state NPDES programs, including

- Assessment of state program health,including recognition of vulnerability trendsand innovations within the program, withpotential regulation revisions

- Electronic reporting, including automatedNPDES permit applications and dischargemonitoring reports

- Assistance to tribal governments onNPDES issues and programs, includingauthorization

- Coordination with other federal agencies,particularly on the Endangered Species Actand National Historic Preservation Act

� Ensure quality and consistency in state NPDESpermit programs, including state programauthorizations, modifications, and review ofpetitions for state program withdrawal.

� Develop and implement strategies to ensuretimely NPDES permit issuance.

� Develop and provide training programs,including:

- NPDES Permit Writer�s Course

- NPDES Permit Applicant�s Course

- Pretreatment Courses

- Storm Water Implementation Course

� Implement water quality permitting require-ments and policies, which include:

- Supporting development and refinement ofsound water quality standards

- Implementing policies to ensure NPDESpermits reflect Total Maximum Daily Loads

- Implementing Whole Effluent Toxicity testingpolicies

- Developing water quality permittingguidance

Storm Water Program

� Ensure effective implementation of the StormWater Program, including Phase I, Phase II,and reissuance of the Multi-Sector GeneralPermit.

Sewer System Overflows

� Develop and implement a program to addresssanitary sewer overflows (SSOs), including aproposed rulemaking to address systemmanagement and overflows from over 16,000municipal sewer systems nationwide.

� Fully implement the Combined Sewer Over-flow (CSO) Control Policy, including develop-ment of a CSO water quality standardsguidance, an implementation tracking system,performance measures, and requirements ofthe Wet Weather Water Quality Act of 2000.

Pretreatment Program

� Continue implementation of the NationalPretreatment Program, including finalizing thepretreatment streamlining rule and the Pre-treatment Program Project XL rule.

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Rural Program

� Implement the USDA-EPA Animal FeedingOperations Strategy, including

- Work with states to increase permitting ofexisting Concentrated Animal FeedingOperations (CAFOs)

- Issue revised regulations for ConcentratedAnimal Feeding Operations (CAFO)

- Conduct outreach and support training forstates, the agriculture industry and thepublic

- Work with USDA to implement voluntaryprograms for animal feeding operations

Administrative Systems

� Improve training and development programsfor staff

� Upgrade accounting, strategic planning, andadministrative support systems.

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CHALLENGES ON THE HORIZON

A wide variety of factors influence how we work toprotect watersheds. The following issues have helpedto shape our strategic plan and will continue toinfluence implementation of the NPDES program. Incoming years, we will continue to update and refinethis list of issues and this plan.

Watershed Driven Solutions to Address RemainingWater Quality Challenges

Over the last 30 years, we have made great progressnationally in addressing large-scale water pollutionproblems from a relatively limited universe ofmunicipal sewage treatment systems and majorindustrial sources. Indeed, our efforts have substan-tially improved the quality of the nation�s rivers, lakesand coastal waters. Nevertheless, there are stillsignificant water quality challenges ahead.

The nature of these remaining water quality prob-lems is very different from those faced in the earlyyears of this program. Remaining sources tend to bemuch smaller, more numerous and more widelydistributed, and less amenable to traditional end-of-pipe controls. For instance, effectively addressingseveral hundred thousand storm water sources andthousands of concentrated animal feeding operationsaround the country requires innovative approaches.

Further complicating this picture is the fact that eachwatershed has unique physical and hydrologicalcharacteristics and may be stressed by a uniquecombination of pollution sources, including both

OUR MISSION:

EPA, in partnership with authorized states, willdevelop, support, and manage the NPDES permitprogram to protect and restore the nation�s waters.

EPA�s Water Program:

Shapes National Program Direction by identify-ing issues of national or regional concern anddeveloping and implementing realistic strategies toaddress these issues.

Produces Policy and Regulation to addressproblems affecting the nation�s waters, whilepreventing transfer of environmental problems to theair and land.

Develops Technical and Administrative Toolsto help state and EPA permit writers and programmanagers implement solutions through NPDESpermits.

Tracks and Manages Information on permitissuance, permit quality, and point source pollutionabatement to measure the effectiveness of theNPDES program and refine its management.

Communicates with Stakeholders by informingthem of program goals and providing them withpolicies and information to foster more effectiveparticipation in the NPDES program.

OUR VISION: EVERY WATERSHED IN THE U.S. IS FREE FROM IMPAIRMENTS

CAUSED BY INDUSTRIAL, MUNICIPAL, AND OTHER POINT SOURCE DISCHARGES.

NPDES Program Vision and Mission

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point and nonpoint (runoff). As a result, a significantchallenge will be to reorient the NPDES program tobetter address the specific needs of individualwatersheds.

New Watershed Science

EPA conducts research on the impacts of pollutantson watersheds. Our knowledge of watersheds andthe complex interaction of pollutants within differenttypes of watersheds has increased in recent years. Asa result we are now able to begin establishing waterquality standards to address remaining problems,such as nutrient and pathogen pollution. Becausethese pollutants impact ecosystems in a variety ofways, they present special challenges for the NPDESprogram. A detailed understanding of the hydrologi-cal and biological characteristics of each affectedwatershed is needed to develop and implementpermit limits and other controls.

Total Maximum Daily Loads

Total Maximum Daily Loads (TMDLs) are essentiallypollution budgets for specific river segments or otherwaterbodies. EPA and the states are scheduled todevelop as many as 40,000 TMDLs over the next 15years. The development of TMDLs is scientifically,legally and politically challenging. In addition, theworkload associated with implementing 40,000TMDLs will present significant management chal-lenges to EPA and the states.

Program Expansion and Evolution

The scope of the NPDES program has continued toexpand since its inception. As we move toward fullerimplementation of the watershed approach, theNPDES program will need to better address remain-ing sources of pollution (including storm water andconcentrated animal feeding operations). New effortswill include innovations and partnerships such ascomprehensive environmental management systemsand �best management practices� for non-traditionalsources in lieu of end-of-pipe controls. Workingclosely with the states and other federal partners willbe crucial to ensure that new approaches achievereal environmental results.

The Information Age

The information age has ushered in a new andimportant role for EPA. With the advent of theInternet and major advances in geographic informa-tion technology, we are now able to provide thepublic with a wealth of information about thecharacteristics of the watersheds in which they live.The NPDES program has much to contribute to thegrowing body of watershed information. We mustalso improve our data collection efforts to includenewer categories such as storm water, concentratedanimal feeding operations, and sewer systemoverflows. Web technology also offers new andinnovative ways to collect and disseminate informa-tion.

New Initiatives

The NPDES program must always be ready toaddress new developments. Congress, the Adminis-tration, court decisions, and developments aroundthe country can have a significant impact on thedirection and focus of the NPDES program. Ourstrategic plan must be flexible enough to accommo-date changes; therefore, we will update it regularly.

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Strategic Issues and Key Actions -2001 through 2006

OVERVIEW

A strategic issue is a fundamental policy question orchallenge related directly to an organization�smission. To formulate our strategic issues, wecarefully considered a wide range of factors,including environmental priorities and trends, futurechallenges, mandates, the needs of our partners andstakeholders, and resources.

This process led to the identification of eight strategicissues. The next step was to identify the actionsnecessary to begin addressing each issue. This planhighlights major courses of action designed to helpaddress each strategic issue. These strategic issuesand key actions create the framework for thisstrategic plan and will, in turn, define and shapeactions, programs, policies and resource allocationsfor the coming years.

SUMMARY OF STRATEGIC ISSUES ANDKEY STRATEGIC GOALS AND KEY ACTIONS2001-2006

ENVIRONMENTAL ISSUES

1. Support Watershed Planning

Description of the Issue

In order to continue improving the quality of thenation�s waters, we must tailor our strategies andprograms to the specific needs of individual water-sheds. Past efforts have focused largely on national,�one-size-fits-all� programs rather than more flexiblewatershed-oriented approaches. The nature anddiversity of the water quality challenges aheadrequire us to reinvent the concept of permitting and,perhaps, the entire NPDES program. Working inclose collaboration with a broad array of stakehold-ers is imperative to successful implementation ofwatershed strategies. Further, taking a broader, moreflexible view of our program in a watershed contextwill be required to move forward with solutions thatwill improve water quality. Our challenge is to findways in which the NPDES program can adapt tothese challenges and actively promotewatershed-based strategies.

Strategic Goal: Restructure the permits programand seek changes in the water quality standards,TMDL, and enforcement programs to promoteplanning, development, and implementation ofenvironmental programs on a watershed basis.

AN EFFECTIVE STRATEGIC PLAN MUST IDENTIFY AND OFFER A CLEAR PLAN TO

ADDRESS KEY ISSUES.

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Priority setting is the key to the watershed approachand must be considered at two levels. First, prioritiesmust be set among watersheds�for those that aremost impaired and those that are most in need ofprotection. Second, within high-priority watersheds,potential restoration and preservation actions mustbe evaluated and prioritized. For the NPDES pro-gram, such priority setting will help determinewhere, when, and how we will reissue NPDESpermits and implement new standards and TMDLs.

Much of the decision making in a watershed frameworkoccurs at the state and local level. Nationally-ledprograms, such as the NPDES program, must con-stantly work to develop management tools and otheropportunities for flexibility that enhance state and localleadership. The NPDES program has begun exploringthe potential for municipal �integrated watershed�permits to further this kind of local decision making andflexibility.

Key Actions

By December 2002, sponsor the development ofpilot integrated watershed NPDES permits that bringtogether the full range of municipal programs (e.g.pretreatment, CSOs, SSOs, storm water) on awatershed basis.

By December 2003, develop guidance on prioritizingpermit issuance according to the status and conditionof watersheds.

2. Permit and Program Quality, Consistency, andInnovation

Description of the Issue

The issuance of an NPDES permit represents theculmination of much effort by many programs underthe umbrella of the Clean Water Act. Water qualitystandards, technology-based requirements, and TMDLsall find their final expression in the text of NPDESpermits. Because NPDES permits are fundamental tothe Clean Water Act, the quality and completeness ofeach permit is critical. As mentioned earlier, EPA andthe authorized states share responsibility for implement-ing the NPDES program. State administered programspromote day-to-day decision making at a level moreattuned to the situation in individual watersheds. One ofthe primary challenges inherent in any delegatedprogram is maintaining the appropriate balancebetween these objectives. EPA�s challenge is to providemanagement tools, technical assistance, and guidanceto support the states in their efforts to implement theNPDES program and, at the same time, ensure areasonable level of consistency across the country.

Strategic Goal: Improve the integrity, consistency, andeffectiveness of the NPDES program by providingbetter management tools to the states.

In 1999, the EPA Inspector General reported that thenumber of permits exceeding their five-year lifetime

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had grown substantially and that this situationwarranted significantly increased attention by thestates and EPA. This problem continues to beidentified and managed as a �material weakness� inthe Federal Managers Financial Integrity Act (FMFIA)report. A related issue facing the program is theincreasing number of lawsuits and petitions challeng-ing states on their implementation of the NPDESprogram. These legal actions seek to have EPAwithdraw the NPDES program (or portions of it).

In order to address these issues, EPA and the stateshave initiated efforts on several fronts to help usmeet the goal of improved integrity, consistency, andeffectiveness of the NPDES program. EPA and thestates have adopted a detailed strategy to addressthe timely issuance of permits. In addition, EPA andthe states are working to build a comprehensive setof tools to assist states in their management of theprogram and to improve the quality of the permitsthey issue. Additionally, EPA and the states will beworking together on a longer-term project toimprove the information and management systemsthat support the NPDES program.

Another management tool, known as environmentalmanagement systems (EMS), could be effective inmeeting this goal and the broader goal of cleanwater. Environmental management systems arecomprehensive and proactive systems that helporganizations manage their facilities and programs inways that promote long-term compliance withenvironmental requirements. Such systems helppromote corporate and organizational responsibilityand frequently minimize the need for governmentinspections and enforcement actions. Our challengewill be to find opportunities to build these conceptsinto our new initiatives and existing programs.

Key Actions

By December 2001, complete the assessment of permitquality and provide tools and assistance to states toassist them in making any needed improvements.

By December 2001, Water Permits Division willcontinue to emphasize the goal of reducing thebacklog of major permits to 10% or less and willwork closely with Regions and states towards itsachievement.

During 2002, develop a package of managementtools, guidance, and assistance to support states inmaintaining and improving the overall health of theNPDES programs in preparation for piloting inseveral states.

During 2001, look for opportunities to extend theenvironmental management systems concept withinthe NPDES program. Document opportunities andset priorities by December 2001.

By December 2004, Water Permits Division willcontinue to emphasize the goal of reducing the backlogof all permits to 10% or less and will work closely withRegions and States towards its achievement.

3. Standards to Permits

Description of the Issue

Incorporating water quality standards into permitscan be a complex process. The water quality stan-dards being developed today are scientifically morecomplex and often require specialized implementa-tion in different ecological regions. TMDLs addanother layer of complexity in that a given facilitymust be considered within the context of the water-shed and the other sources of pollution in thatwatershed. Further complicating this picture areseveral factors including: the need to consider

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By September 2003, complete initial reviews of thehealth of state water quality permitting programsand document and distribute state innovations in thestandards-to-permits process.

PROGRAM ADMINISTRATION ISSUES

4. Modernizing the Permit Management System

Description of the Issue

Information technology has radically changed theway data and information can be collected, man-aged, and made available. The information systemsthat support the NPDES program are now obsolete.The latest advances in information technology affordus many opportunities including: development ofmore effective management systems, streamlineddata collection, geographic referencing and integra-tion with other water-related information, and onlineaccess for the public.

Many states have made significant progress indeveloping and using online data systems. Using newtechnologies, the NPDES program needs to besupported by a new information system that con-nects with and enhances these efforts. Our challengeis to develop technology that will streamline thepermitting process, provide for easier and moremeaningful access to information, and integrate withexisting state systems.

Strategic Goal: Develop an efficient and effectiveNPDES information management system (that auto-mates and streamlines the permit application, issuanceand administration process) utilizing state-of-the-arttechnology and building upon existing state innovations.

One of the most important aspects of this effort willbe 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.

Key Actions

By September 2001, begin pilot implementation ofelectronic NPDES permit application and reportingforms.

Continue to support EPA�s efforts to develop andimplement all aspects of this new NPDES informationsystem.

varying hydrological conditions (wet and dryweather), some outdated water quality standards,inappropriate classification of waterbodies, inconsis-tent availability of water quality data, and lack ofstandardized water-quality-to-standards translationmethodologies.

Strategic Goal: Guide the consistent and effectivetranslation of water quality goals and standards intopermit limits and conditions.

In the near future, the workload associated withimplementing the NPDES program is expected toincrease dramatically. The authorized states will needsubstantial assistance from EPA to remain successful.Our challenge will be to provide the technicalassistance, training, and guidance to ensure thatstates have clear policies for translating standards topermits and that NPDES permits reflect the latestwater quality and technology-based standards, andTMDLs in a timely manner. The NPDES program willalso need to be more actively engaged with the waterquality standards, effluent guidelines (technology-based requirements) and TMDL programs to ensurethat the needs of permit writers are considered asthese programs evolve.

Key Actions

By October 2001, establish regular communicationswith EPA regional and state permit writers onemerging standards-to-permits issues and problems.

By November 2002, complete updates and finalrevisions to EPA�s basic guidance on developingwater quality-based limits in permits.

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5. Measuring Environmental Results

Description of the Issue

Measuring and reporting of environmental progressand results are critical aspects of managing anyenvironmental program and serve as the basis forcommunicating progress and for public accountability.In 1993, Congress passed the Government Perfor-mance and Results Act (GPRA) to focus and improvethe federal government�s efforts in this area. Duringthe last seven years, the NPDES program has devel-oped and implemented a set of measures, but we stillhave much work to do. Presently, the program collectsinformation and data necessary to support programimplementation, but our ability to describe environ-mental results is limited. Our challenge is to work withstates, municipalities, and industry to develop aframework for expressing environmental results andan agreement on the information that will be gatheredto support it.

Strategic Goal: Improve the measurement andreporting of environmental results for the NPDESpermit program.

The most important step in creating measures ofenvironmental results is to identify the questions wewant to answer about the effect of the NPDESprogram on water quality. Then we can determinewhat additional information we need and incorporateit into our existing information management systems.

Key Actions

By December 2002, work with our stakeholders todevelop a revised framework for environmental resultsmeasurement for all facets of the NPDES program.

6. Better Communication and Participation ofStakeholders

Description of the Issue

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 mustmaintain close lines of communication. We areincreasingly aware that successful implementation ofthe NPDES program is contingent upon constantcommunication between EPA and the states in everyaspect of the program, from policy development toimplementation to enforcement.

Success of the NPDES program also depends on theinformed and active involvement of key externalstakeholders including the regulated community,interests groups and the public. We recognize the needto work more closely with the full range of groupsinterested in and affected by the NPDES program.

Finally, EPA and the states share responsibility formaking information available to the public. Newtechnologies, such as the Internet, provide enhancedopportunities to disseminate information. Ourchallenge will be to use both new and traditionalmethods to provide high quality, understandableinformation to the public.

Strategic Goal: Improve communication with andincrease the involvement of stakeholders in theimplementation of the NPDES program.

A good starting point for better communication withthe states is to establish a core group of representa-tives to voice the perspectives and concerns of theirjurisdictions. For our external stakeholders, we willensure our web site meets their diverse needs�providing a range of information from trainingcourses to guidance documents�and provides themwith the opportunity to participate in our efforts.

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Key Actions

By June 2001, EPA will launch a new NPDES website at www.epa.gov/npdes to provide greatlyexpanded access to information and services.

By December,2001, EPA will initiate an ExecutiveCouncil to help guide the development and imple-mentation of the NPDES program. The Council willinclude state and EPA representatives and will adviseEPA management on a full range of issues facing theNPDES program.

By December 2001, EPA headquarters will develop arefined and expanded communications plan for theNPDES program.

7. Planning and Administration

Description of the Issue

Given the limitations on the resources available toimplement the NPDES program (see figure 4), thereis an increased need to engage in meaningfulplanning to set priorities and utilize resourcesefficiently. With an increasing workload, resourcesare often drawn from base program activities that, inthe longterm, are critical to this program�s success(for more on this topic see Strategic Issue 2). Thisstrategic plan is a first step toward managingavailable resources, and setting and communicatingpriorities to both internal and external stakeholders.

Training of EPA and state employees is essential toensuring that the NPDES program is implementedconsistently and effectively. EPA also provides some

training to stakeholders on a variety of issues andprograms, providing them with important regulatoryand policy information and facilitating compliancewith environmental requirements.

Finally, EPA must address a variety of administrativeand management issues related to the operation ofour programs, including recordkeeping, manage-ment and support systems, and rulemaking proce-dures. EPA is working on a number of fronts toutilize new information management technology tostreamline some of these processes and to improvequality control where appropriate.

Strategic Goal: Institutionalize a strategic planningprocess for the NPDES program, address the trainingneeds of both internal and external stakeholders, andimprove our administrative systems and procedures.

Achievement of this goal will be crucial to thesuccessful implementation of the NPDES programover the longterm. EPA will need to find efficientsolutions to these issues and to implement themconsistently over time.

Key Actions:

By October 2001, establish a permanent process forstrategic planning for the NPDES program.

By October 2001, establish a training program andschedule for internal and external stakeholders.

By October 2001, refine management and adminis-trative systems and distribute guidelines for manag-ers and staff.

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CONCLUSIONS

The NPDES program is a cornerstone of the CleanWater Act. This program is directly responsible forpreventing the discharge of billions of pounds ofpollutants to the nation�s rivers, lakes and coastalwaters each year. We hope this strategic plan helpsto demonstrate some of the important accomplish-ments of this successful program.

This Strategic Plan also describes the context inwhich the NPDES program currently operates and

frames the issues that we believe will influence ourfuture activities. We are committed to working withour state partners and other stakeholders to furtherrefine this Plan and the programs that it representsto achieve the goal of clean and safe water.

More information is available at www.epa.gov/npdes.Readers may provide comments and suggestions tothe address on the Contents page.