State Water Control Board v. Train

424 F. Supp. 146, 8 ERC 1609, 6 Envtl. L. Rep. (Envtl. Law Inst.) 20243, 8 ERC (BNA) 1609, 1976 U.S. Dist. LEXIS 16800
CourtDistrict Court, E.D. Virginia
DecidedFebruary 6, 1976
DocketCiv. A. 74-0328-R
StatusPublished
Cited by4 cases

This text of 424 F. Supp. 146 (State Water Control Board v. Train) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Water Control Board v. Train, 424 F. Supp. 146, 8 ERC 1609, 6 Envtl. L. Rep. (Envtl. Law Inst.) 20243, 8 ERC (BNA) 1609, 1976 U.S. Dist. LEXIS 16800 (E.D. Va. 1976).

Opinion

MEMORANDUM

MERHIGE, District Judge.

This action is one brought by the State Water Control Board, an agency of the Commonwealth of Virginia, against Russell E. Train, Administrator of the United States Environmental Protection Agency in an attempt to obtain the relief for Virginia and certain of her political subdivisions from compliance with the July 1,1977 deadline attainment of certain effluent limitations by publicly owned treatment plants imposed by the Federal Water Pollution Control Act Amendments of 1972, Pub.L. 92-500 § 101 et seq., 86 Stat. 816, 33 U.S. C.A. §§ 1251, 1311(b)(1)(B). Intervenor Newton H. Ancarrow was granted leave to intervene as a defendant in this action in his capacity as a riparian landowner and citizen, vested with certain rights under the Act. Plaintiff seeks declaratory and in-junctive relief. Jurisdiction is attained pursuant to 28 U.S.C. §§ 1331, 1361. The matter comes before the Court on motions by the respective parties for summary judgment.

Plaintiff contends that publicly-owned treatment plants need not comply with otherwise applicable effluent discharge limitations imposed by statute until such time as federal grant funds are available in an amount sufficient to underwrite seventy-five percent (75%) of the eligible cost of construction of such plants and a reasonable time has been afforded to complete the necessary construction. Plaintiff’s contention is premised on the belief that the discharge limitation provisions of the Act are inextricably linked to the funding provisions. Defendant and Intervenor deny that any such link exists and maintain that the effluent limitations and deadlines are to be strictly adhered to. As the controversy centers on the construction of the Federal Water Pollution Control Act Amendments of 1972, 1 a brief look at the Act as it applies to the instant case is required. 2

The primary objective of the Act “is to restore and maintain the chemical, physical, and biological integrity of the Nation’s water.” 33 U.S.C.A. § 1251(a). This objective is to be partially realized through the maintenance of water quality standards. More important however, is the mechanism by which the discharge of effluents into the Nation’s waterways is to be regulated. The Act renders unlawful any discharge of pollutants unless authorized by a special permit. 33 U.S.C.A. § 1311(a). Such permits may be issued by the EPA or by the state officials pursuant to a federally approved permit program. 33 U.S.C.A. § 1342(b)-(f). The statute calls for a two phase program for application of effluent limitations. In Phase I, publicly-owned treatment works must provide, by July 1, 1977, secondary treatment 3 (33 U.S.C.A. § 1311(b)(1)(B)) or *148 higher levels of treatment required to implement water quality standards (33 U.S. C.A. § 1311(b)(1)(C)), whichever is more stringent. The failure to provide secondary treatment to effluent discharge within the statutorily imposed period renders that publicly-owned treatment plant ineligible for a discharge permit, and hence in violation of the law. Phase II increases the standard of regulation by requiring public plants to utilize the best practicable waste treatment technology in order to qualify for a discharge permit. 33 U.S.C.A. § 1311(b)(2)(B). The duty of enforcement of these limitations and deadlines is imposed upon the EPA and the right to require such enforcement is granted to private citizens. 33 U.S. C.A. §§ 1319, 1365. In addition to injunc-tive sanctions, a violator faces potential criminal and civil penalties. 4 Attorneys’ *149 fees and costs may be awarded to private litigants for their aid in enforcing the Act. 33 U.S.C.A. § 1365(b).

The federal government through the Administrator of the EPA is to assist municipalities in undertaking to comply with the demands of the Act by providing grants to help finance the construction of treatment facilities. 33 U.S.C.A. § 1281(g)(1). The amount of such grants “shall be seventy-five percentum of the cost of construction” of the project. 33 U.S.C.A. § 1282(a). Congress authorized $18 billion for such grants for fiscal years 1973, 1974 and 1975. 33 U.S.C.A. § 1287. Each state’s share of money is based on its needs. 33 U.S.C.A. § 1285. The approval of the Administrator of plants, specifications and cost estimates for a treatment works project contractually obligates the United States to pay its proportional contribution to any such project. 33 U.S.C.A. §§ 1282(a), 1283(a). Succinctly stated, the Act provides for a set of technology-based effluent discharged standards to be met within specific time periods. Federal funds are available to assist local governments in complying with these standards. Incentive to comply with the Act is provided by the sizable fine facing violators and the enforcement potential of the EPA and private citizens.

Plaintiff has set forth convincing evidence that many publicly-owned treatment plants are unable to meet the Phase I deadline of July 1, 1977 established by § 301(b)(1)(B) of the Act. Several factors contribute to this problem. First, there is a significant delay of thirty to forty-five months between the approval of a grant, and completion of a sewage treatment plant. Indeed, EPA officials have estimated the lag time is as much as five years. The lag time is due, in part, to the administrative process of approving the plans submitted by municipalities. See 40 C.F.R. §§ 35.917, 35.920-35, 35.925-19 (1975). Administrative approval of a grant request is estimated to require six months to one year. Construction is unlikely to commence prior to this approval as the funds are not committed until after final EPA approval of the grant application. The actual construction of the project accounts for the remainder of the lag time. The generally recognized shortage of monetary resources also contributes to municipal difficulty in meeting § 301(b)(1)(B) deadlines. Upon congressional enactment of this legislation overriding a Presidential veto, and pursuant to a Presidential directive, the Administrator refused to allocate approximately 55% of the funds intended to be used to finance Virginia projects. The impounded funds have been subsequently released. See Train v. City of New York, 420 U.S. 35, 95 S.Ct. 839, 43 L.Ed.2d 1 (1975). The disruption that the impoundment imposed on the flow dollars plus the lead time required to construct treatment plants, virtually guarantees that many municipalities will not have secondary treatment facilities operational by the July 1, 1977 deadline despite their having received federal grants.

Plaintiff also contends that there simply were not enough funds appropriated under the Act to provide 75% grants to all municipalities in need of assistance. State studies estimate that $1,417 billion are required to construct the facilities needed in Virginia to comply with § 301(b)(1)(B). The federal share of this amount would be $1,063 billion. The EPA figures are quite comparable.

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Bluebook (online)
424 F. Supp. 146, 8 ERC 1609, 6 Envtl. L. Rep. (Envtl. Law Inst.) 20243, 8 ERC (BNA) 1609, 1976 U.S. Dist. LEXIS 16800, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-water-control-board-v-train-vaed-1976.