Pre-FY 2018 NPDES Oversight Initiatives
- Permitting for Environmental Results (PER)
- Priority Permits
- Pre-FY 2018 NPDES Backlog Reduction Efforts
The Permitting for Environmental Results (PER) initiative was a multi-year effort by EPA and the states to improve the overall integrity and performance of the NPDES program. EPA collaborated with the Association of Clean Water Administrators (ACWA) to develop and implement the PER strategy and to coordinate with state NPDES programs.
EPA designated a baseline assessment to gauge the effectiveness of each program and to identify strengths and opportunities for improvement. The Program and Permit Quality Review (PQR) program was one result of this process.
On March 4, 2004, EPA established the priority permits initiative under the PER program. The priority permits initiative’s purpose was to select priority permits from a pool of eligible expired permits and commit to finalizing (reissuing or terminating) a certain percentage of them.
The priority permits initiative served a few important roles:
- It was a measure for NPDES program performance reported as a budget measure to the Office of Management and Budget (OMB).
- It was reported as a measurement under the Government Performance and Results Act (GPRA).
- It ensured that states and regions were evaluating the most environmentally or programmatically significant of the “older” administratively continued permits and taking action on these permits.
The Agency has shifted focus with the current efforts focused on making all permitting decisions within six months, with initial efforts focused on reducing the backlog of new EPA-issued permits. The priority permits measures were also focused on backlog reduction, but only for permits expired for two years or more that were deemed high priority. This limited focus is no longer enough to meet Agency goals as described in the EPA FY 2018-2022 Strategic Plan. As a result, data collection efforts and work planning have also shifted and now examine all causes for delay in issuing permits and EPA Regions have developed backlog elimination strategies for all EPA-issued permits.
Under EPA’s current measures, permits are considered backlogged as soon as they expire. For new permits, applications are considered backlogged after six months if they are not issued. (See current Permit Backlog Reduction Efforts for more information.) Before FY 2018, under the Government Performance and Results Act (GPRA) measures, permits administratively continued beyond their expiration date for 180 days or more were considered "backlogged," and new permits were considered backlogged after 365 days from when the application was submitted.
Percent Current Goals
Under the GPRA measures before FY 2018, EPA tracked the number and percent of facilities covered by NPDES permits that are considered current (i.e., not “backlogged”) and set goals with states and EPA Regions to achieve the national goal of 90 percent current. All major facilities and non-stormwater minor facilities and general permit covered facilities were included in this goal. EPA no longer tracks these measures.