Resources

Since 1973, UWAG has participated in the development and implementation of Clean Water Act-related requirements by federal and state agencies. The group has filed detailed comments on countless EPA, Corps, and other agency proposals and, in some cases has participated in litigation, seeking always to ensure that the agencies have all the relevant facts, look carefully at the law from all perspectives, and understand the practical implications of their regulations. The following are some of the most recent comments and briefs UWAG has submitted:

Effluent Limitation Guidelines

• Opinion Re Challenges of EPA's 2015 ELG Rule, SWEPCO v. EPA, Case No. 15 60821 for the 5th Circuit (Apr. 12, 2019)

• Intervenor-Respondent Brief Re Petition for Review of EPA's ELG Postponement Rule (Oct. 17, 2018)

Water Quality

• Comments on EPA's Proposed Water Quality Standards; Establishment of Numeric Criterion for Selenium for the State of California (Mar. 27, 2019)

• Comments on Proposed Establishment of Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California and Toxicity Provisions (Dec. 20, 2018)

NPDES Permitting and Related Issues

• Comments on EPA's Proposed Information Collection Request for NPDES Provisions Affecting Applications and Program Updates Final Rule (Nov. 5, 2018)

• Comments on EPA Region 10 Proposed Issuance of NPDES General Permit for Hydroelectric Facilities Within State of Idaho (Jul. 11, 2018)

• Comments on EPA's Request for Comment on CWA Coverage of Discharge of Pollutants via a Direct Hydrologic Connection to Surface Water (May 21, 2018)

CWA Section 404 and Related Issues

• Comments on the CEQ's Proposal to Update Regulations Implementing the Procedural Provisions of NEPA (March 10, 2020)

• Comments on EPA and USACE's Proposed Rule to Revise the Definition of WOTUS (Apr. 15, 2019)

• Comments on USACE's Draft Section 408 Engineer Circular (Apr. 6, 2018)

Protected Species

• Comments on Definition of Habitat (Sept. 4, 2020)

• Comments on FWS and NMFS Proposals to Revise the Regulations for Listing Species and Designating Critical Habitat, Regulations for Interagency Cooperation, and Regulations for Prohibitions to Threatened Wildlife and Plants (Sep. 24, 2018)

• Amici Brief in Support of Weyerhaeuser Co., Weyerhaeuser Co. v. U.S. Fish and Wildlife Service, No. 17-71, Sup. Ct. (2018)

Nonpoint Source/Storm Water

• Comments on EPA's Proposed Modification to NPDES General Permit for Stormwater Discharges from Construction Activities (Jan. 28, 2019)

Cooling Systems and Section 316(b) issues

• Comments on EPA Region 10’s Proposed Permits for Federal Hydroelectric Facilities in the Lower Columbia and the Lower Snake Rivers (May 4, 2020)