New Clean Water Act Discharge Permit Comment Guide for Protecting Drinking Water Sources

A new guide entitled, “Using Clean Water Act Discharge Permits to Protect Drinking Water Sources,” is now available on the Source Water Collaborative (SWC) website. The guide was written and reviewed by a few representatives of the SWC including Clean Water Action, the Association of State Drinking Water Administrators, and the American Water Works Association, and the Environmental Integrity Project, as well as representatives from other partner organizations and water utilities.

The guide is designed to provide fundamental information for Public Water Systems (PWSs) and stakeholders to understand and provide meaningful comments on Clean Water Act (CWA) National Pollutant Discharge Elimination System (NPDES) permits that impact drinking water sources. It includes tips, tools, examples, and a template for providing comments on different types of NPDES permits, including permits with discharges that may contain PFAS and other contaminants.

Pollutants such as PFAS, that are present in NPDES discharges, have the potential to impact downstream drinking water sources. The guide aims to help PWSs in:

  • Understanding which upstream industrial, wastewater, stormwater, and nonpoint-source pollutant discharges are impacting, or have the potential to impact the quality of their drinking water sources and associated treatment processes; and
  • Learning how to provide comments, data, and information on the CWA NPDES permits for these sites and facilities to affect changes in monitoring, pollution discharge limits, and notifications to the PWS.

The guide is simplified and uses more general terms than an official government regulatory or guidance document, so that it is more understandable for PWSs and a public audience that is unfamiliar with CWA regulations. It is expected that PWSs and stakeholders may only use parts of the guide where it is relevant to their purpose. It is not expected that all portions of the guide will be relevant to every PWS. Please note that this guide is not a regulation or a regulatory document. It does not carry any legal force. Nor is it endorsed by the U.S. Environmental Protection Agency (EPA) or any other permitting agency.

To view and download this NPDES Permit Comment Guide, visit the SWC website here. On this page, you will also find a link to the SWC’s From Source to Tap infographic, a visual interactive tool with basic information about how to use all the different parts of the CWA to protect drinking water sources.

Stay tuned for an upcoming webinar! The SWC is planning for a webinar and other potential information sharing opportunities in the near future.

The SWC would love to hear from you! If you have examples of NPDES permit comments, or know of anyone who uses (or plans to use) this guide and comment on permits any time now or in the future, please provide your feedback and share your experience with the SWC at