In re Clean Water Act Rulemaking

CourtDistrict Court, N.D. California
DecidedOctober 21, 2021
Docket3:20-cv-04636
StatusUnknown

This text of In re Clean Water Act Rulemaking (In re Clean Water Act Rulemaking) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Clean Water Act Rulemaking, (N.D. Cal. 2021).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 NORTHERN DISTRICT OF CALIFORNIA 8

10 In re No. C 20-04636 WHA No. C 20-04869 WHA 11 CLEAN WATER ACT No. C 20-06137 WHA RULEMAKING. 12

13 This Document Relates to: (Consolidated)

14 ALL ACTIONS. ORDER RE MOTION FOR REMAND WITHOUT VACATUR 15 16 17 INTRODUCTION 18 Plaintiff states, tribes, and non-profit conservation groups have challenged EPA’s Clean 19 Water Act certification rule, and now EPA moves to remand the proceedings without vacatur. 20 For the reasons stated, the rule is remanded to the agency with vacatur. 21 STATEMENT 22 The Federal Water Pollution Control Act Amendments of 1972, commonly known as the 23 Clean Water Act, is the primary federal statute regulating water pollution. Congress enacted 24 the Clean Water Act in 1972 — over then-President Nixon’s veto — but the roots of the Act 25 extend much farther back to 1899 and the Rivers and Harbors Act. That statute, often referred 26 to as the Refuse Act, primarily ensured free and open navigability of the waters of the United 27 States, but also prohibited the discharge of “refuse matter of any kind or description whatever 1 navigable water of the United States,” and authorized the Secretary of the Army to permit such 2 discharges under certain conditions. See 33 U.S.C. §§ 407 et seq. In 1948, following an 3 increase an industrialization throughout the country, Congress passed the Federal Water 4 Pollution Control Act (FWPCA). See generally Joel Gross & Kerri Stelcen, Clean Water Act 5 2–7 (2d ed. 2012). 6 In 1969, two events would help foster a new environmental awareness in the United 7 States and prompt the promulgation of amendments to the FWPCA: A catastrophic oil spill of 8 three million gallons of crude off the coast of Santa Barbara (creating a thirty-five-mile slick); 9 and a fire on the surface of the Cuyahoga River in northeast Ohio. A 1968 Kent State 10 University symposium on the state of the Cuyahoga River is worth briefly quoting: 11 The surface is covered with brown oily film observed upstream as far as the Southerly Plant effluent. In addition, large quantities of 12 black heavy oil floating in slicks, sometimes several inches thick, are observed frequently. Debris and trash are commonly caught up 13 in these slicks forming an unsightly floating mess. Anaerobic action is common as the dissolved oxygen is seldom above a 14 fraction of a part per million. The discharge of cooling water increases the temperature by 10 to 15° F. The velocity is 15 negligible, and sludge accumulates on the bottom. Animal life does not exist. 16 17 The Cuyahoga River Watershed: Proceedings of a Symposium Held at Kent State University 18 104 (George D. Cooke, ed., 1969); Gross & Stelcen, supra, at 7; Christine Mai-Duc, The 1969 19 Santa Barbara oil spill that changed oil and gas exploration forever, L.A. Times, May 20, 2015, 20 https://www.latimes.com/local/lanow/la-me-ln-santa-barbara-oil-spill-1969-20150520- 21 htmlstory.html. 22 Three years after these events, Congress passed the Clean Water Act. Section 101 of the 23 act expressed Congress’ goal “to restore and maintain the chemical, physical, and biological 24 integrity of the Nation’s waters.” 33 U.S.C. § 1251(a). The congressional declaration in 25 Section 101(b) recited: 26 It is the policy of the Congress to recognize, preserve, and protect the primary responsibilities and rights of States to prevent, reduce, 27 and eliminate pollution, to plan the development and use exercise of his authority under this chapter. 1 2 Section 101(d) charged EPA to administer the act while Section 101(e) explicitly enshrined 3 public participation into the statutory scheme: 4 Public participation in the development, revision, and enforcement of any regulation, standard, effluent limitation, plan, or program 5 established by the Administrator or any State under this chapter shall be provided for, encouraged, and assisted by the 6 Administrator and the States. 7 Under Section 401 of the Clean Water Act, a federal agency may not issue a permit or 8 license to an applicant that seeks to conduct any activity that may result in any discharge into 9 the navigable waters of the United States unless a state or authorized tribe where the discharge 10 would originate issues a water quality certification or waives the requirement. EPA is 11 responsible for the certification by non-authorized tribes or when a discharge would originate 12 from lands under exclusive federal jurisdiction. Importantly, “No [federal] license or permit 13 shall be granted if certification has been denied by the State, interstate agency, or the 14 Administrator, as the case may be.” 33 U.S.C. § 1341; see also Overview of CWA Section 15 401 Certification, epa.gov/cwa-401/overview-cwa-section-401-certification (last visited Oct. 16 21, 2021). Several major federal licensing and permitting schemes are subject to Section 401, 17 such as National Pollutant Discharge Elimination System (NPDES) permits under Section 402, 18 permits for discharge of dredged or fill material into wetlands under Section 404, Federal 19 Energy Regulatory Commission (FERC) licenses for hydropower facilities and natural gas 20 pipelines, and Rivers and Harbors Act Section Nine and Section Ten permits. 21 While EPA has promulgated myriad rules to administer the Clean Water Act, iterations 22 of the administrative rule implementing Section 401 had remained, until recently, singular. 23 EPA originally promulgated 40 C.F.R. Part 121 to implement water quality certifications for 24 Section 21(b) of the FWPCA as it existed in 1971 — a year before the Clean Water Act 25 amendments to the FWPCA. See 36 Fed. Reg. 22,487 (Nov. 25, 1971), redesignated at 37 Fed. 26 Reg. 21,441 (Oct. 11, 1972), further redesignated at 44 Fed. Reg. 32,899 (June 7, 1979). EPA 27 would continue to use this rule for the Section 401 licensing scheme. In brief, 40 C.F.R. Part 1 EPA’s administrative processes; (ii) the procedures for determining the effects of a license 2 upon other, non-certifying states; (iii) the procedures the EPA Administrator employs to certify 3 an application for a project under exclusive federal jurisdiction; and (iv) the procedures for 4 EPA consultations on obtaining a license or permit. EPA employed this procedure for 5 certifications as-is for half a century. 6 * * * 7 On April 10, 2019, President Trump issued Executive Order 13,868, entitled Promoting 8 Energy Infrastructure and Economic Growth. 84 Fed. Reg. 15,495 (Apr. 10, 2019). The order 9 stated: “The United States is blessed with plentiful energy resources, including abundant 10 supplies of coal, oil, and natural gas,” and, the “Federal Government must promote efficient 11 permitting processes and reduce regulatory uncertainties that currently make energy 12 infrastructure projects expensive and that discourage new investment.” To that end, Executive 13 Order 13,868 asserted that “[o]utdated Federal guidance and regulations regarding section 401 14 of the Clean Water Act . . . are causing confusion and uncertainty and are hindering the 15 development of energy infrastructure,” and instructed EPA to review and issue new guidance 16 regarding Section 401. Id. at 15,496. 17 Pursuant to the executive order, EPA revised its general Section 401 guidance in June 18 2019. Two months later, EPA published an economic analysis of existing Section 401 19 processes.

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Bluebook (online)
In re Clean Water Act Rulemaking, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-clean-water-act-rulemaking-cand-2021.