News & Analysis as of

Environmental Protection Agency (EPA) NPDES Navigable Waters

Pillsbury Winthrop Shaw Pittman LLP

Confronting Regulatory Fluidity in the Post-Maui and Post-Sackett World of Water Regulation

Both regulators and the regulated community must remain alert to accommodate the constantly changing regulatory scheme created in the post-Sackett world. The application of Maui and Sackett in recent months confirms the...more

Allen Matkins

Dissecting Discharges: Recent Ninth Circuit Rulings and EPA Guidelines Interpreting the Clean Water Act

Allen Matkins on

November was an eventful month for the Clean Water Act (CWA). The Ninth Circuit Court of Appeals issued two decisions last month—which will apply to cases and matters in California and other states within the Ninth...more

Maynard Nexsen

EPA Drafts New Guidance on County of Maui’s “Functional Equivalent” Test

Maynard Nexsen on

On November 20, 2023, the U.S. Environmental Protection Agency (EPA) issued Draft Guidance, again attempting to interpret the Supreme Court decision in County of Maui v. Hawaii Wildlife Fund and describe in practical terms...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Does Discharged Groundwater Require a Clean Water Act NPDES Permit? U. S. Environmental Protection Agency Issues Draft Maui...

The United States Environmental Protection Agency (“EPA”) is issuing for public comment draft guidance on applying the United States Supreme Court decision in County of Maui vs. Hawaii Wildlife Fund. EPA had previously...more

(ACOEL) | American College of Environmental...

Taking Bets: The Supreme Court Is Just About to Split NPDES and Section 404 Permitting Under the Clean Water Act

The first Monday in October is just around the corner, and the first oral argument on the Supreme Court’s agenda is Sackett v. EPA. The Supreme Court is stepping once more into Clean Water Act “waters of the United States,”...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Waters of the United States/Sackett v. US. Environmental Protection Agency: National Association of Clean Water...

The National Association of Clean Water Agencies (“NACWA”) and Waterkeeper Alliance (“Waterkeeper”) each filed Amicus Briefs in the Supreme Court of the United States appeal styled: Michael Sackett, et ux. v. U.S....more

(ACOEL) | American College of Environmental...

WOTUS: What to Watch For in 2022

In 2022, the on-going debate will continue over the hotly contested definition of “waters of the United States” (WOTUS), a phrase that determines the scope of federal jurisdiction over streams, wetlands and other waterbodies...more

Pillsbury - Gravel2Gavel Construction & Real...

The EPA and the Corps of Engineers Propose Another Revised Definition of “Waters of the United States”

On December 7, 2021, the most recent proposed revision to the Clean Water Act’s term, “Waters of the United States” was published in the Federal Register. (See 86 FR 69372.) Comments on this proposal must be submitted by...more

Foley Hoag LLP - Environmental Law

EPA Proposes to Use Science to Identify Waters of the United States. I’m Shocked, Shocked.

Last week, EPA and the Army Corps proposed a new rule to define what constitutes “waters of the United States.” Déjà vu all over again. Under the proposal, the agencies: are exercising their discretionary authority to...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Waters of the United States/Clean Water Act: U.S. Environmental Protection Agency/Corps of Engineers Proposed Rule

The United States Environmental Protection Agency and the United States Corps of Engineers (collectively “EPA”) announced on November 19th a revised definition of waters of the United States (“WOTUS”). The agencies are...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Does a Discharge to Groundwater Require a Clean Water Act NPDES Permit?: U.S. Environmental Protection Agency Rescinds Maui...

The United States Environmental Protection Agency (“EPA”) rescinded a guidance document it had previously issued titled: Applying the Supreme Court’s County of Maui v. Hawaii Wildlife Fund Decision in the Clean Water Act...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Waters of the United States/Clean Water Act: U.S. Environmental Protection Agency/Corps of Engineers Announces Intent to Revise...

The United States Environmental Protection Agency and Department of the Army (collectively “EPA”) announced in a June 9th news release their intent to revise the Clean Water Act definition of waters of the United States...more

Schwabe, Williamson & Wyatt PC

Murky Waters: Assessing EPA’s Draft Guidance on Groundwater Regulation After the Maui County Decision

Late last year, the Environmental Protection Agency (“EPA”) issued a draft guidance intended to assist regulated entities and permitting authorities in applying the U.S. Supreme Court’s decision in County of Maui, Hawaii v....more

Bracewell LLP

Will Congress Rollback Trump Regulatory Actions to Advance the Biden Policy Agenda?

Bracewell LLP on

Recent news that the Democrats flipped both U.S. Senate seats in Georgia’s run-off election means that the Democrats have enough votes to add the Congressional Review Act (CRA)[1] to the tools that could be used to advance...more

Morgan Lewis

EPA Narrowly Defines Discharges into Groundwater that Are Subject to Clean Water Act Permitting

Morgan Lewis on

Draft guidance from the US Environmental Protection Agency provides a clearer look at how the agency intends to apply the US Supreme Court's "functional equivalent" analysis to determine when National Pollutant Discharge...more

Bricker Graydon LLP

US EPA issues draft guidance regarding NPDES permitting requirements following Maui Supreme Court decision

Bricker Graydon LLP on

On December 8, 2020, U.S. EPA announced issuance of draft guidance to clarify its view of how the U.S. Supreme Court’s recent County of Maui v. Hawaii Wildlife Fund decision should be applied to its Clean Water Act National...more

Troutman Pepper Locke

EPA Seeks to Clarify Application of Maui and “Functional Equivalent” Test

Troutman Pepper Locke on

On December 12, the United States Environmental Protection Agency (EPA or the Agency) issued draft guidance to clarify the application of the “functional equivalent” test created by the United States Supreme Court in County...more

Ward and Smith, P.A.

Replacing the Clean Water Rule – Is the Dance Really Over?

Ward and Smith, P.A. on

On April 21, 2020, the United States Environmental Protection Agency ("EPA") and Army Corps of Engineers ("Corps") completed step two of the two-step "repeal and replace" process ordered by President Trump in 2017 by...more

Williams Mullen

Supreme Court Holds that NPDES Permit Can be Required for Discharges to Groundwater that Reach...

Williams Mullen on

As we have reported in previous articles, controversy over whether the Clean Water Act (CWA) regulates discharges of pollutants that travel through groundwater into surface waters has led to significant litigation across the...more

Jones Day

Supreme Court Rules Some Discharges to Groundwater Require Clean Water Act Permits

Jones Day on

The Situation: The Supreme Court held that a discharge through groundwater that is the functional equivalent of a direct discharge to navigable waters requires a Clean Water Act permit. The Result: Some discharges to...more

(ACOEL) | American College of Environmental...

SCOTUS Has Spoken: Kinda Sorta Direct Discharges Need A Permit

On April 23 the Supreme Court announced its decision in County of Maui v. Hawaii Wildlife Fund (No. 18-260), which addressed the fundamental issue of what is a discharge to navigable waters requiring a permit under the Clean...more

Hogan Lovells

New SCOTUS test for NPDES permitting under the CWA: County of Maui, Hawaii v. Hawaii Wildlife Fund et al.

Hogan Lovells on

On 23 April 2020 the Supreme Court, in a 6-3 opinion written by Justice Stephen Breyer, waded carefully into the very-muddied waters of Clean Water Act (CWA) jurisprudence when it issued a new test to determine when the...more

Sullivan & Worcester

Supreme Court Sets Test for Assessing NPDES Permit Requirement for Indirect Discharges of Pollutants Through Groundwater to...

Sullivan & Worcester on

In a busy week for environmental decisions, the Supreme Court of the United States ruled on April 23, 2020 on its second major case, County of Maui v. Hawai’i Wildlife Fund, finding a middle ground in its 6-3 decision on...more

Perkins Coie

Supreme Court Rules Clean Water Act May Regulate Discharges Through Groundwater to Navigable Waters

Perkins Coie on

Uncertainty has long reigned over the reach of the federal Clean Water Act, which applies to “navigable waters,” defined by statute only as “waters of the United States.” Over the last several decades of debate about federal...more

McGlinchey Stafford

The Maui “Functional Equivalent” Point Source Test

McGlinchey Stafford on

On April 23, 2020, the United States Supreme Court issued its opinion in County of Maui v. Hawaii Wildlife Fund, 590 U. S. ____ (2020), holding that, when pollutants originate from a point source, but are conveyed to...more

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