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EPA Region 9 Finalizes Purported Expansion of NPDES Stormwater Regulation for Two Watersheds in Los Angeles County

On November 20, 2024, the U.S. Environmental Protection Agency (EPA) Region 9 published in the Federal Register its Final Designation of stormwater discharges from commercial, industrial, and institutional (CII) properties...more

EPA Region 1 Doubles Down on Unprecedented Effort to Require Stormwater Permits for an Expansive Range of Formerly Unregulated...

Key Takeaways - What Is Happening? On October 31, 2024, the U.S. Environmental Protection Agency (EPA) Region 1 provided notice of two proposed actions pursuant to its “residual designation authority” (RDA) under the Clean...more

EPA Issues Final Rulemaking on Clean Water Act Hazardous Substance Facility Response Plans

Key Takeaways - • What Is Happening? On March 14, 2024, The U.S. Environmental Protection Agency (EPA) signed a final rule requiring certain facilities to develop Facility Response Plans (FRPs) for a potential worst-case...more

EPA Issues Long-Awaited (and Disappointing) Proposed Guidance on Combined Sewer Overflows

The U.S. Environmental Protection Agency (EPA) is soliciting comments on a draft guidance document on approaches to issuing National Pollutant Discharge Elimination System (NPDES) permits for communities that have completed...more

EPA Issues Aggressive Interpretation of Maui Supreme Court Decision in Latest Draft Guidance

The U.S. Environmental Protection Agency (EPA or Agency), on November 27, 2023, released its draft guidance addressing its proposed interpretation to apply the Supreme Court decision in County of Maui v. Hawaii Wildlife Fund,...more

Supreme Court Narrows CWA Jurisdiction Over Waters of the U.S.

On May 25, the U.S. Supreme Court issued its long-awaited decision in Sackett v. EPA, No. 21-454, holding that Clean Water Act (CWA) jurisdiction extends to wetlands only if they have a continuous surface connection to...more

EPA Region 1 Expands NPDES Stormwater Permitting Requirement to Sites Across Three Massachusetts Watersheds

Key Takeaways - • What Is Happening? On September 14, 2022, the U.S. Environmental Protection Agency (EPA) Region 1 exercised its Clean Water Act (CWA) Residual Designation Authority to require National Pollutant Discharge...more

EPA Expands Clean Water Act Spill Response Planning to Hazardous Substances

Key Takeaways - • What Is Happening? The U.S. Environmental Protection Agency (EPA) published a proposed rule requiring certain facilities to prepare Facility Response Plans (FRPs) for responding to worst case discharges...more

Oregon Adopts a Significantly Modified (and Legally Vulnerable) Industrial Stormwater General Permit

Oregon Department of Environmental Quality’s (DEQ’s) policy and rulemaking board adopted rules renewing Oregon’s National Pollutant Discharge Elimination System (NPDES) Stormwater Discharge General Permit No. 1200-Z (1200-Z...more

EPA Proposes New, More Flexible Clean Water Act Affordability Guidance for Public Utilities

Public water, wastewater, and stormwater utilities face an array of compliance obligations under the federal Clean Water Act (CWA) that require investment in upgrades and maintenance of critical wastewater infrastructure....more

EPA Tackles Controversial Clean Water Act Certification Requirements

The U.S. Environmental Protection Agency (EPA) published a final rule to interpret the requirements for water quality certification under section 401 of the Clean Water Act. This Section grants states and approved tribes the...more

SCOTUS: Clean Water Act Permits Required for Some Releases into Groundwater

The U.S. Supreme Court held today, in a much-anticipated ruling, that the Clean Water Act’s (CWA) requirement to obtain a National Pollutant Discharge Elimination System (NPDES) permit, can apply to certain releases of...more

EPA Releases 2020 Multi-Sector General Permit for Comment

The U.S. Environmental Protection Agency (EPA) published for public comment its proposed 2020 National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP), which authorizes stormwater discharges...more

Ruling in First CWA Case to Rely on EPA’s Interpretive Statement on Groundwater Releases

On November 26, a federal district court judge in Massachusetts held that releases of pollutants reaching surface waters through groundwater do not require permits under the Clean Water Act (CWA), “irrespective of any...more

Justices Wrestle with Scope of the CWA’s Permitting Requirement

The Supreme Court of the United States heard oral argument in County of Maui v. Hawai’i Wildlife Fund, No. 18-260, a case in which the justices will decide a key jurisdictional issue under the Clean Water Act (CWA): whether...more

EPA Proposed Regulations Aim to Further Clarify CWA Section 401 Certification Reviews

On August 8, 2019, the U.S. Environmental Protection Agency (EPA) published a proposed rule to revise its regulations (40 C.F.R. Part 121) implementing Section 401 of the Clean Water Act (CWA), 33 U.S.C. § 1341. The proposed...more

Supreme Court to Decide Whether “Indirect” Discharges Require NPDES Permits

The U.S. Supreme Court has granted certiorari on a critical question affecting the scope of the Clean Water Act (CWA): whether releases of pollutants require National Pollutant Discharge Elimination System (NPDES) permits...more

Justices Request the Government’s Views on CWA Discharge Cases

On December 3, 2018, the U.S. Supreme Court requested the federal government’s views on two petitions for certiorari asking the Court to decide whether the Clean Water Act (CWA) regulates releases of pollutants that reach...more

Pair of Clean Water Act Decisions Creates Circuit Split over Discharges to Groundwater

On Monday, divided panels of the U.S. Court of Appeals for the Sixth Circuit issued a pair of decisions holding that Clean Water Act (“CWA”) Section 301’s prohibition on unpermitted discharges does not apply to pollutants...more

Petitions Seek Supreme Court Review of Fourth and Ninth Circuit Decisions That Could Expand the CWA’s NPDES Program

Earlier this year, the Fourth and Ninth Circuits decided a pair of cases that have the potential to greatly expand the scope of the National Pollution Discharge Elimination System (NPDES) permit program under the Clean Water...more

Cert Petition Seeks Supreme Court Review of Ninth Circuit’s Expansion of the CWA’s NPDES Program

On February 1, 2018, the Ninth Circuit issued a decision in Hawai’i Wildlife Fund, 886 F.3d 737 (9th Circ. 2018), that has the potential to greatly expand the scope of the National Pollution Discharge Elimination System...more

Environmental Groups Score First Victory to Expand Regulation of Stormwater Under the NPDES Program

Last week, the U.S. District Court for the Central District of California gave environmental groups a significant win in their bid to force EPA to regulate new sources of stormwater discharges under the Clean Water Act...more

Fourth Circuit Joins Ninth In Holding That “Indirect” Discharges May Violate the CWA

On April 12, the Fourth Circuit became the second federal court of appeals this year to hold that a point source need not directly introduce pollutants into navigable waters in order for the Clean Water Act’s (CWA)...more

Ninth Circuit Holds That Indirect Discharges Require NPDES Permits

On February 1, the Ninth Circuit issued a decision that has the potential to sweep regulated groundwater discharges that reach surface waters, and similarly remote-in-place discharge situations, into the Clean Water Act’s...more

First Circuit Shuts Down Use of TMDLs to Expand NPDES Stormwater Permitting

The past several months have witnessed multiple attempts by environmental groups bring currently unregulated entities that discharge stormwater into the Clean Water Act (CWA) National Pollution Discharge Elimination System...more

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