Water pollution harms plant and animal habitats and negatively impacts human health. The National Pollutant Discharge Elimination System (NPDES) permit program addresses water pollution by regulating point sources that discharge pollutants to waters of the United States. Created in 1972 by the Clean Water Act, the NPDES permit program authorizes the Environmental Protection Agency (EPA) and state, tribal, and territorial governments to perform many of the permitting, administrative, and enforcement aspects of the NPDES program.
In 2015, in an effort to improve oversight and ease reporting burdens, EPA published the NPDES Electronic Reporting Rule (NPDES eRule). The rule required EPA and states to modernize Clean Water Act reporting for municipalities, industries and other facilities by replacing paper-based NPDES reporting requirements with electronic reporting. The move to a paperless process required EPA to implement solutions that are compliant with EPA’s legal framework for electronic reporting [Cross-Media Electronic Reporting Rule (CROMERR)], available not only to EPA itself but also to state permitting authorities.
EPA turned to CGI to develop and continually optimize a platform for much of this electronic reporting– the NPDES Electronic Reporting Tool (or “NeT”). CGI has deep expertise in developing, implementing, and maintaining environmental regulatory business systems, supporting both the EPA and state environmental regulatory agencies for over 40 years. Today, all 10 EPA Regions and five states have implemented NeT to support critical permitting functions required under the NPDES eRule and the Clean Water Act.
Additional government agencies, including the Fish and Wildlife Service, National Marine Fisheries Service, the Office of Historical Preservation as well as state agencies leverage NeT to implement the Endangered Species Act (ESA) and the National Historic Preservation Act (NHPA).
Single permitting process tool meets unique state and EPA requirements
EPA first engaged CGI to develop tools for highly utilized general permits related to stormwater discharges from construction and industrial activities: the Construction General Permit (CGP) workflow was delivered in 2017 within just months of project commencement, immediately followed by the Multi-Sector General Permit (MSGP) workflow. These critical workflows allow construction site and industrial plant operators to electronically submit requests for coverage under permits where EPA is the NPDES permitting authority. Since implementing these successful applications, the program has grown; as of March of 2022, 14 total permitting workflows have been developed and implemented using NeT.
As part of their NPDES eRule implementation, states have the option to work with EPA to leverage NeT for their own general permits. As each permit issuer (e.g., a state or EPA Region) uses NeT to create a new permitting workflow, CGI develops reusable services. The focus on reuse reduces overall costs to EPA for developing each new permitting workflow, while permit issuers benefit from the faster time to create and implement new e-reporting workflows. For example, reusable services for access control and entity management provide a single, consistent implementation for the regulated community to manage permissions for and information about their facilities. CGI continues to work with permit issuers including EPA and state partners to build out new workflows for various permit types.
NeT also supports public access to information regarding permit activities. Anyone can use the Permit Lookup tool to search for permit coverage records and related submissions (such as annual reports for Industrial Stormwater permits) for EPA and state issued general permits using NeT to gain greater insight into the permitted activities within their own communities.
Tool framework designed to scale
With the need to support 24 different general permit categories and various state and EPA permitting authorities, the NeT solution needed to be architected to address diverse and complex business rules. When considering both business needs and technology, EPA and CGI recognized the value of developing the tool framework on a cloud-ready architecture leveraging platform services and micro services. The NeT architecture served as the critical prototype for EPA’s efforts to enable the various systems within its Central Data Exchange (CDX)—the system used for many electronic environmental data submissions—to move to the cloud.
Taking an agile approach enables concurrent development of multiple workflows supporting various permit types and issuers. As NeT increasingly becomes the framework of choice for these permit workflow activities CGI and other contractors have used the NeT architecture, with its reusable services, to build out new workflow capabilities to support the permitting process. The core architecture and agile approach enable significant speed in delivering new permitting workflows while supporting various permitting authorities’ reissuance cycles.
Improving the permitting process for all stakeholders
With the development of NeT, EPA implemented core capabilities to comply with the NPDES eRule, providing the means for EPA regions and states to rapidly develop new permitting workflows. NeT provides the technical framework to support a wide variety of permitting activities including industrial and municipal wastewater, aquaculture, storm water and pesticide permitting to control discharge into receiving waters to protect human health and the environment. States leverage NeT to stand up their electronic permit workflows, building upon existing workflows while implementing their own unique business rules.
The companies and municipalities who are required to obtain permit coverage can now submit their requests online, avoiding the delays and costs associated with paper-based submissions. Permit holders also have a leg up in permit compliance, as NeT provides early insight into the specific metrics that must be gathered and reported on in order to maintain permit compliance.
As our nation continues to focus on protecting our environment—especially those communities most impacted by pollution—NeT will serve as the core platform for EPA and states to carry out the critical permitting activities required to protect America’s waters.
