This standard may be ambitious in comparison to current practice, but improving water quality demands it. The EPA and the Davis Administration should assess the validity of these issues and provide adequate resources for enforcing the permit system. The problem is often compounded by industries who take advantage of resource-strapped bureaucrats, or who intentionally delay the process of permit renewal by submitting late or inordinately complex permit renewal applications. Facilities should be required to submit renewal applications no less than nine months prior to an expiration deadline. Higher fees should be imposed for late applications.
Current rules allow for submissions up to the expiration date.
Polluters with a history of late, incomplete or particularly complex permits should be required to submit their applications earlier than the nine-month time frame. Permits should not be continued just because the polluter has applied for a new permit. This analysis is based on data from the U.S. EPA Envirofacts database. These sorts of data errors are a serious problem. Envirofacts is the central repository for state-collected environmental information, and the Pollution Control System database represents the only assemblage of each state's data into one collection.