EPA’s Water Permits Division, as part of renewing the information collection request (ICR) for the National Pollution Discharge Elimination System (NPDES) program, is considering making minor revisions to the forms and instructions of permit applications.

EPA is proposing these revisions as a means to improve clarity and resolve areas of potential confusion. For example, some of the proposed revisions include clarifying text to assist in application completion and eliminating a “yes/no” format in certain forms where a “no” answer may default to an incomplete application.

There are eight forms EPA is proposing modifications to, including:

• EPA Form 3510-1, Application Form 1: General Information
• EPA Form 3510-2A, Application Form 2A: New and Existing Publicly Owned Treatment Works
• EPA Form 3510-2B, Application Form 2B: Concentrated Animal Feeding Operations and Concentrated Aquatic Animal Production Facilities
• EPA Form 3510-2C, Application Form 2C: Existing Manufacturing, Commercial, Mining, and Silvicultural Operations
• EPA Form 3510-2D, Application Form 2D: New Manufacturing, Commercial, Mining, and Silvicultural Operations That Have Not Yet Commenced
• EPA Form 3510-2F, Application Form 2F: Stormwater Discharges Associated with Industrial Activity
• EPA Form 3510-2E, Application Form 2E: Manufacturing, Commercial, Mining, and Silvicultural Facilities Which Discharge Only Nonprocess Water
• EPA 3510-2S, Application Form 2S: New and Existing Treatment Works Treating Domestic Sewage

The above forms and instructions include the redline revisions EPA proposes making. EPA’s Water Permits Division is seeking feedback on the potential revisions, but it is also looking for additional input on how to improve the NPDES permit application forms and the instructions.

NACWA is reviewing the proposed minor changes for the application forms that directly relate to our members’ interests. If members have input on these proposed modifications or how EPA can improve upon the permit application forms and instructions, please connect with Emily Remmel, NACWA’s Regulatory Affairs Director, with comments before September 20^th.