ACWA supports the Environmental Protection Agency (EPA) periodically updating and modernizing the federal NPDES regulations to eliminate application form inconsistencies, improve transparency, and remove outdated provisions. States also support EPA’s efforts to provide NPDES permit writers with improved tools and to provide the public with opportunities for public participation in permitting actions. States acknowledge that some of the proposed provisions will accomplish the above goals. However, ACWA also believes several of the provisions articulated in this proposal would undermine historical flexibilities and create new challenges for states, including increasing state administrative burden.
ACWA Proposed NPDES Updates Rule Letter 8-1-2016
