David Van Slyke Authors Blog for American College of Environmental Lawyers

In a surprising turn of events, on March 12, 2014, EPA Regions 1, 3 and 9 each simultaneously but separately responded, and each in a somewhat different way, to three virtually identical NGO petitions asking those Regions to use their Clean Water Act ("CWA") Residual Designation Authority ("RDA") to require that stormwater discharges from impervious surfaces at existing commercial, industrial and institutional ("CII") sites be permitted under CWA Section 402. The three petitions were filed in July 2013 by several different and somewhat overlapping consortia of environmental organizations....

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