ABSTRACT
In Chapter 3 we argued that EPA NPDES personnel employ a pragmatic enforcement approach to enforce surface-water pollution control legislation because a strict by-the-book approach is not feasible. This is because of the diverse nature of the existing regulatory environment. As Rosenbaum (1985: 156) wrote, the 1972 Federal Water Pollution Control Act delegated "enormous administrative discretion . . . to the EPA in prescribing the multitude of technologies that must be used by effluent dischargers to meet the many different standards established by the law." Likewise, we have argued that the provisions of the 1972 act, and the EMS manual establishing the operating procedures for the NPDES program, have delegated considerable discretion to NPDES personnel.
