Any given major industrial facility often must obtain literally dozens of permits under a variety of pollution control laws in order to operate. A common complaint of plant operators has been that this welter of differing permit requirements and procedures is arcanely confusing, full of redundancies and contradictions, time consuming, and unjustifiably costly. The Environmental Protection Agency (EPA) recently responded to these concerns by issuing "consolidated permitting regulations"¹ that attempt simultaneously to coordinate and streamline the Agency's five major permit programs. The rules are designed to consolidate the procedures for obtaining permits rather than the permits themselves, and separate permitsof essentially unchanged substance must still be obtained to satisfy each applicable statute.

The new regulations are part of EPA's continuing effort to eliminate regulatory dissonance, reduce compliance costs to permittees, and lessen the administrative burdens on the Agency's own limited resources. EPA concedes that the rules are lengthy and replete with numerous cross-references and has apparently adopted a gradualist approach toward consolidation. Nevertheless, the new regulations promise to harmonize and simplify to some degree the plethora of permit requirements and procedures with which dischargers have up to now had to contend.