UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460 


MAY 11 2011 


Dear State Water Pollution Control Administrators, State Commissioners and EPA 

Regional Administrators: 

EPA's Office of Enforcement and Compliance Assurance (OECA) and the Office of 

Water (OW) are pleased to provide you with the final set of new approaches we are 

implementing under the Clean Water Act Action Plan to usher in a 21 st century National 

Pollutant Discharge Elimination System (NPDES) program for cleaner water. We have 

all witnessed the significant progress that the United States has made in the last three 

decades in protecting our environment from water pollution. But we know that the 

challenges we still face in doing this work are real, growing, and require our ingenuity, 

adaptability and collaboration to solve. We believe that the suite of actions described in 

the enclosed "CWA Action Plan Implementation Priorities" will lead the way in these 

efforts. 

First, we extend our thanks and appreciation to you and your staff for the hard work and 

dedication over the last year in collaborating with our offices to discuss and evaluate the 

critical challenges facing our programs and the practical steps we can all take to 

address them. States, EPA Regions, OW and OECA worked together on the CWA 

Action Plan Steering Committee and six teams to analyze and identify potential 

solutions to the water quality problems involving sources regulated under the CWA's 

NPDES program. Together, we were able to develop a suite of actions to chart our best 

course of action over the next several years to strengthen our ability to provide the 

American public with cleaner water. This demonstration of teamwork and commitment 

to a common cause is reason for believing that our nation's waters can be protected 

from pollution and provide our communities with a resource to value and enjoy well into 

the Mure. 

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Internet Address (URL) • http://www.epa.gov 


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The enclosed document, "CWA Action Plan Implementation Priorities," summarizes the 

four key changes that will modernize and revamp the NPDES program and describes 

the new features of the retooled system, including the specific actions, tools, policies 

and regulations that EPA believes are most important for implementing the new system 

starting in FY2011. The four critical changes are: 

1. 	Switch existing paper reporting to electronic reporting with automated compliance 

evaluations and improved transparency. 

2. 	 Create a new paradigm in which our regulations and permits compel compliance 

via public accountability, self-monitoring, electronic reporting and other methods. 

3. 	 Address the most serious water pollution problems by fundamentally re-tooling 

key NPDES permitting and enforcement practices, while continuing to vigorously 

enforce against serious violators. 

4. 	 Conduct comprehensive and coordinated permitting, compliance and enforcement 

programs to improve state and EPA performance in improving water quality. 

Our efforts as co-regulators in driving better CWA compliance and reducing pollution 

through the enhanced power of public accountability is one of the principal components 

of our work under this Plan. Promulgating the NPDES Electronic Reporting Rule is a 

fundamental deliverable in FY11 and FY12. Many of the new approaches in the Action 

Plan will rely on the foundation set by the NPDES Electronic Reporting rule and will 

require EPA and states to launch fundamental overhauls to some of the tools, policies, 

and regulations by which we implement the NPDES permitting and enforcement 

program. Some of these changes can begin now and will require close collaboration to 

deliver: thus, EPA and states will be at work for several years to realize the vision and 

complete these changes. 

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We will continue to seek state input and assistance through the EPA State CWA Action 

Plan Steering Committee. We hope the four existing state members of the Steering 

Committee will continue to work with us, and we would like to expand the state 

membership to include two additional states. We are working with ASIWPCA and 

ECOS to fill these positions. We look forward to our continued work together in these 

areas to deliver clean water to our citizens. 

Sin 

OECA K~ 

Acting Assistant Administrator 

OW 

Enclosure: CWA Action Plan Implementation Priorities and One Pager 

CC: with enclosures 

EPA State Steering Committee Members 

ASIWPCA Executive Director and Deputy Director 

ECOS Executive Director 

OW Office and Deputy Office Directors 

EPA Regional Water Division Directors 

EPA Enforcement Division Directors 

Regional Water Enforcement Branch Chiefs 

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