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Methodology & References

Clean Water Report Card for California: Methodology & References

March 1, 2000

Methodology

This analysis is based on data from the U.S. EPA Envirofacts database. The Permit Compliance System or PCS database of Envirofacts contains information submitted by the states (or EPA regional offices). EWG’s and FOE’s analysis only considered permits that are categorized by the states and regions as "major," a designation based on toxic pollution potential, pollution volume, public heath impacts, and proximity to coastal water.

It is possible that a few permits listed as "expired" in our national analysis have, in fact, been renewed, since states may be very slow in providing updated information to EPA headquarters. In addition, a few facilities may have ceased operations but remain listed as "active" facilities in the 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. It is readily accessible to anyone who has access to the Internet on a computer in his or her home, school, business or local library. It is a vital source of information to local citizens concerned with water quality – but only if it is kept up-to-date.

Friends of the Earth and the Environmental Working Group have graded the EPA regions and the states. States and Regions with more than 10 percent of the NPDES permits expired received a failing grade under our grading system. This grade is based upon EPA’s stated goal of reducing the expired permits to 10 percent.

Based on this scale, both the State of California and U.S. EPA Region 9, based in San Francisco, receive failing grades. The website related to this report – http://www.foe.org/cleanwater/grades – provides both the grades and detailed information on expired permits for individual states.

References

FNS 1997. Prepared Statement of Lois J. Schiffer, Assistant Attorney General Environment and Natural Resources Division Before the Senate Committee on Environment and Public Works: Subject - Enforcement of Environmental Laws." Federal News Service, June 10.