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MEMORANDUM

TO: Public Record for the NPDES Electronic Reporting Rule

EPA Docket Number EPA-HQ-OECA-2009-0274 (www.regulations.gov)

FROM: Carey A. Johnston, P.E.

USEPA/OECA/OC

ph: (202) 566 1014

johnston.carey@epa.gov

DATE: 17 November 2011

SUBJECT: Description of the PCS and ICIS-NPDES [DCN 0008]

A. The Permit Compliance System (PCS)

EPA uses the Permit Compliance System (PCS), a national data system developed in 

1982, to support the NPDES program. PCS, which is managed by the Office of Enforcement and 

Compliance Assurance (OECA), is a critical information system for EPA’s Office of Water and 

OECA. PCS tracks NPDES permit issuance, permit limits, self-monitoring data, enforcement 

and inspection activity for NPDES facilities regulated under the CWA. PCS currently tracks data 

for 16 states. The data from 34 other states, 19 territories, 2 tribes and 10 EPA Regional offices 

that had previously been in PCS were migrated to ICIS-NPDES, the modernized system1. PCS, 

identified as a mission critical system for the Agency, is one of the Agency’s largest and most 

complex systems, given the large number of transactions and the variety of information sources 

for hundreds of thousands of NPDES permittees. The NPDES Discharge Monitoring Reports 

(DMRs) that the permitting authorities collect and process constitute the second largest data 

collection effort within the federal government, accounting for close to 30 million records. 

The PCS Policy Statement (as amended) identified the data elements that were expected 

to be entered or otherwise provided by the states to EPA through PCS. This policy statement and 

accompanying data requirements allowed PCS to function for many years as a useful 

management tool for the NPDES program, providing EPA with a nationally consistent set of 

facility-specific NPDES information, particularly for major facilities.

B. The NPDES component of the Integrated Compliance Information System (ICISNPDES) 

The Integrated Compliance Information System (ICIS) serves as the repository for multimedia compliance and enforcement data at the federal level. The development of ICIS was 

divided into three phases. The first phase focused on developing a system to integrate federal 

enforcement and compliance activities. The second phase focused on the incorporation of the 

NPDES program specific requirements, thus creating the ICIS-NPDES component which is 

 

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See EPA’s website (http://www.epa-echo.gov/echo/compliance_report_water.html) for a current listing of states, 

tribes, and territories that report to PCS or ICIS-NPDES.
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intended as a replacement national NPDES data system for PCS. The third phase, under 

discussion, may add air-related program-specific requirements. 

C. Why the Change from PCS to ICIS-NPDES?

When EPA and the NPDES-authorized states developed the Water Enforcement National 

Data Base (WENDB) list of data elements for PCS, NPDES agencies were focused on the 

control and reduction of pollutant discharges from the identified point sources of pollution that 

were priorities for national attention at the time, specifically, major dischargers. The NPDES 

program has evolved considerably since then. EPA now recognizes the need to better quantify

and address the environmental impacts from nonmajor point sources (including wet weather 

sources) as well. The changes in the focus of the NPDES program implementation necessitate 

change in the data to be tracked and in the areas in which program oversight is conducted.

Given the significant advances in computer technology in the past twenty years, the 

underlying database technology supporting the PCS data system has grown increasingly outdated 

and unsupported, making it impractical to upgrade and difficult for EPA and NPDES-authorized 

states to maintain. The PCS data system is also not capable of handling the increase in the 

expanded NPDES universe. EPA and states modified their NPDES data systems to address new 

program requirements, but not necessarily in a nationally consistent or methodical manner. 

Without a systematic approach, difficulty obtaining the necessary data to make strategic program 

decisions from each state and EPA Region, including data needed to respond to requests received 

by EPA, hampers EPA’s ability to provide timely responses to both Congress and the public on 

pollutant discharges and trends of national or regional significance. This lack of timely access to 

nationally consistent NPDES information from the states has undermined the Agency’s capacity 

to conduct program oversight and to make the best-informed program management decisions.

EPA has worked closely with its state partners in an effort to modernize PCS and 

eventually replace it with ICIS-NPDES. ICIS-NPDES was designed to improve EPA’s and 

states’ ability to track and manage information related to all NPDES sources. The new ICISNPDES ensures that the more traditional NPDES information remains available, accessible, and 

useful, and also provides means to track and access other NPDES information that was not 

historically available in PCS.

There are substantial benefits derived from a more modern NPDES data system. Through 

this rule’s requirement for electronic reporting of NPDES information, ICIS-NPDES will capture 

information for all permitted NPDES sources, improve NPDES agencies’ capacity to evaluate 

compliance, perform watershed analysis, evaluate trends in NPDES program implementation, 

and report to Congress. ICIS-NPDES would continue to support the public’s access to 

information through Agency web sites providing a more complete picture of the NPDES 

program for EPA, its state partners, Congress and the public.