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Permit Renewal Data & Communication Needs Issues Matrix
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Topic/Subtopic Description of ProblemDesired OutcomePolicies & GuidanceRelated Workgroup EffortsPrior Workgroup EffortsExample PermitsPotential Tools
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1Chemical EvaluationsWebsite/FAQCWWUC Subgroup – topic focused on renewal processClean Water Webinars
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1.1Clarity about what data will be needed at renewal. (WET test data, effluent data, dosing data, SDS, proprietary chemical process)Update Guidance documents
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1.2When and how will Chem Eval forms be requested (esp. application prior to the creation of the Chemical evaluation form)Change in process to have permit writers to provide early notification to applicants that the chem eval forms has not been provided
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1.3Form only allows single chemicals how about multiple chemicals for evaluation?Modify form for multple chemicals.
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1.4Is there a pre-approved list of chemicals that have been evaluatedFormulate an easily accessible resource for these pre-approved chemicals.Reference list link
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2Antidegradation CalculationsProcedural Guidance (2001 & 2002), Implicit NILs Clarification Guidance (2022)Clean Water Webinars
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2.1Clarity needed on what data and effluent Data are neededUpdate Guidance documents
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2.2How many data points are needed prior to calculating implicit NILs to be significant enough to be used to determin NILsUpdate Guidance documents
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2.3List of Parameters of which antdeg limits will be appliedAppendix List of applicable parameters for Anti Deg.
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2.4Clarity on Antideg limits in cases for 303(d) listed parameters (Assumed they do not apply)Update Guidance documents
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2.5Data needs communicated to renewal applicants early (2 years worth of data and a heads up)Change Permiting Application review process to allow 2 year data collection prior to picking up a permit (Especially on those administratively extended permits) &/or allow flexibility in permit renewal to adequately collect the needed data
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2.6Allow consideration and justification from facilities for implicit NILS when current instream concentration is representative of baseline concentration when a facility doesn't have data during a baseline period (pre 9/30/2000).Update Guidance documents
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3New ParametersBaseline Monitoring Frequency, WQP-20 (2022)
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3.1Uncertainty about what pollutants of concern are evaluated for a facility (e.g. newer certs and individual permits are including nitrite, Reg 31 parameters, etc). It is helpful for facilities to know what new parameters will be considered so that data can be collected and used in the permit developmentUnderstanding of how the division determines POCs for WWTPs and industrial facilities; understand the basis for including additional parameters from Reg 31, etcGuidance document/website information
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3.2Facilities are not provided the opportunity to collect data to potentially establish an implicit NIL or to conduct a quantitative reasonable potential analysisIncreased communication during permit drafting between permittee and permit writer regarding POCs and the need to collect data prior to a reasonable potential analysis being conducted
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3.3Uncertainty about when the division determines monitoring versus permit limits for:
-New parameter
-Parameter with no data
-All data below PQL
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4Compliance Schedule DurationsPermit Compliance Schedules Policy, CW-3 (2014)
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4.1Compliance schedule durations are not providing enough time to complete the necessary steps to acheive compliance with the permit limit.Understanding on: division's determination of ASAP;
necessary documentation for permittees to submit to support requested durations;
integrated planning considerations 		Guidance document/website information on the documentation necessary to justify compliance schedule durations
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4.2Facility requested timelines are not generally provided. There is little documentation from the division regarding the basis for the reduced timelineImprove fact sheet language justifying compliance schedule durations/ASAP
Increased communication during permit drafting between permittee and permit writer related to compliance schedule durations
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5Communication Prior to Public Notice & Sharing of Permit Builder ToolFee Stakeholder Group – need more info on work to be conducted & expected deliverables
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5.1Lack of communication prior to public notice are leading to:
-inaccurate permit conditions
-infeasible permit conditions
-surprises for permittees about not being aware that permitting actions are being worked on
-permittee confusion and frustration 		More communication between the permit writer and permittee during the permit drafting process
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6Flow TiersRegulation 61.8(2)(f)Reg. 22 discussions re: multiple and seasonal flow tiers
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6.1Provide clarity on flow tiers and when they are appropriateUnderstand when flow tiers are appropriate for a facility
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7Other Topics
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