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Recommendations

Clean Water Report Card for California: Recommendations

March 1, 2000

A number of excuses are commonly given for the backlog of permits – lack of money, regulatory changes, an agency-wide attitude that permits are not a priority. 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. To ensure that polluters cooperate and do their fair share:

  • The state and regional water boards must fine facilities that submit incomplete applications and assess higher fees on applications that require time-consuming re-review of materials.
  • 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 back-door "administrative" permitting process does not allow for adequate public input, and it should not be used to mask serious problems with permitting delays.