What to examine in a permit

Whenever possible, compare a draft permit to the previous permit.

• Cover sheet
  Review the discharger’s name and address, discharge locations, receiving water body(ies), and dates of expiration, modification and effectiveness.

• Quality of receiving water(s)
  If the permit doesn’t describe the uses and condition of receiving water bodies, use the water quality standards, 305(b) report, 303(d) list, any TMDLs or other information in the file to determine the condition of the water (Chapter 3).

• Pollution (effluent) limits
  Generally, no “backsliding” or weakening of existing permit limits is allowed (CWA Section 402(o)). Compare the receiving water standards with the limits in the permit. If they don’t match, there should be some discussion in the permit about a mixing zone.

• Flow of receiving water
  Is there enough flow to handle the pollution? What are the dilution assumptions behind the permit limits?

• Mixing zone(s)
  Because mixing zones and variances suspend the limits in the permit, it is important to understand exactly the extent (over time and space) of these allowances.

• Antidegradation analysis
  If the permit will allow new or expanded discharges, an antidegradation analysis should be performed and the findings should be summarized in the permit or in the fact sheet. Look for any reference to antidegradation.

• Monitoring plan and reporting requirements
  It is important to examine the location, type and frequency of monitoring activity.

• Management plans
  Stormwater permits, concentrated animal feeding operation permits and mining permits will be based mostly on management plans that describe best management practices.

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