Federal water pollution control act amendments of 1972, P Law

Tags: Clean Water Act, the Clean Water Act, pollutants, Environmental Protection Agency, implementation, policy window, Public Law, Federal Water Pollution Control Act, challenges, National Pollutant Discharge Elimination System, pollution, Environmental Law Institute, water quality, biological integrity, Public Administration, navigable waters, waters of the United States, pollution control, Clean Water Act of 1972, underground waters, pollutant, point source pollution, EPA, surface waters, surface water, United States, water quality programs, Water Pollution, Train v. City of New York, Environmental Law Institute Jurisdictional, Drinking Water, Supreme Court, Retrieved, American Bar Association, Office of Enforcement and Compliance Assurance, water resource projects, Section 404, Congressman Frenzel, Army Corps of Engineers, Congressman Robison, Congressman Roe, Fill Material, successful policy implementation, National Marine Fisheries Service
Content: Federal water pollution Control Act Amendments of 1972 Public Law 92-500 "Clean Water Act of 1972" Mikaylah Heffernan FALL 2016 PPL 807 Page 1 of 22
Table of Contents Introduction | 3 Causes and Challenges of Implementation|9 Judicial Analysis Post Implementation |13 Outcome |18 Conclusion |20 Works Cited | 20 Page 2 of 22
Introduction Initially known as the Federal Water Pollution Control Act of 1948 (FWPCA), the Clean Water Act (CWA) is intended to regulate the spread of pollutants into waters of the United States and to "restore and maintain the chemical, physical, and biological integrity of the Nation's waters." (Public Law 92-500, 1972) The policy has undergone many heavy amendments. The FWPCA sought to control water pollution, and was the first major law in the United States to do so. It authorized the Surgeon General of the Public Health Service, in cooperation with other federal, state and local entities, to prepare programs intended to eliminate or reduce the pollution of waters and tributaries and improve the sanitary condition of surface and underground waters across the United States. (Houck, 2002) It also addressed the arguments of who should pay attention to the quality of intercostal waters, and who, in what capacity, should be responsible for the quality of waters across the states. Prior to the enactment of the FWPCA, only the Rivers and Harbors Appropriation Act of 1899 governed water pollution on a federal level, and was rendered useless if a discharge did not interfere with navigation. (Ryan, 2011) A policy window may open when a problem is recognized, a policy is available and the political context is positive for change. (Kingdon) Following the initial implementation, the Federal Water Pollution Control Act of 1948 was subject to many amendments in order to authorize new water quality programs, provide new standards and procedures, and reauthorize the act for federal funding. Page 3 of 22
Once the amendments of 1972 were passed, the Federal Water Pollution Control Act of 1948, became known commonly as the Clean Water Act, though the name was not officially recognized as changed until 1977 (Summary of the Clean Water Act). In essence, the Clean Water Act established a basic framework for regulating the amount of pollutants discharged into waters of the United States and for regulating quality standards for surface waters, while also providing necessary support for missing infrastructure (Summary of the Clean Water Act). The language of the legislation put forth the following goals: first, to ensure discharge of pollutants into navigable waters be eliminated by 1985; second, that an interim goal of water quality which provides for the protection and continuation of water based recreation and water habitats be established by 1983; Third, that national policy recognize that discharge of pollutants into waters is prohibited; and, fourth, that waste treatment management planning processes were set in place federally. This was to be done with the provision of federally funded waste treatment works that would ensure waste be properly treated to the best of available abilities, and by the adoption of a national policy that would ensure the development of technology to end the discharge of pollutants into all waters within United States boundaries and on United States borders (Federal Water Pollution Control Act Amendments of 1972). According to the Environmental Protection Agency (EPA), the 1972 updates contributed the following amendments to the FWPCA, in efforts to achieve those goals listed above. First, it established a basic structure to regulate pollutant discharges. Second, it gave the Environmental Protection Agency authority to implement pollution control programs. Third, it preserved the existing requirements to set water quality standards for surface water contaminants. Fourth, it was made unlawful for any person to discharge any pollutant from a Page 4 of 22
point source, or definite, controlled source, into navigable waters, unless a provisioned permit was obtained. Fifth, it funded the construction of sewage treatment plants under the construction grants program and recognized the need for planning to address the critical problems posed by non-point source pollution, which is released from multiple sources concurrently (History of the Clean Water Act). Written within the language of the Clean Water Act was massive restructuring of the FWPCA in order to improve policy enforcement. (Craig, 2009). Specific mechanisms intended to achieve the goals of this policy, or, the in informal bureaucratic terms to "restore and maintain the chemical, physical, and biological integrity of the Nation's waters," include the National Pollutant Discharge Elimination System (NPDES) and Section 404 permit programs (Ryan, 2011). In addition, the 1972 amendments added language that authorized the EPA to issue an administrative order that would essentially suspend any contractor convicted in a violation of section 309 of the Clean Water Act, from government contracting. Language within section 309, authorizes the EPA to sue for civil penalties, if there is any violation of a NPDES permit, an EPA order, or the Act itself. It is important to note here, that the term person is represented by any responsible corporate officer or corporation, and is not limited to just noncommercial pollution by an individual (Ryan, 2011). Section 301 of the CWA states that "Except as in compliance with this section and sections 302, 306, 307, 318, 402, and 404 of this Act, the discharge of any pollutant by any person shall be unlawful. " (Public Law 92-500, 1972) Once enacted, the policy was passed on to the Page 5 of 22
Environmental Protection Agency (EPA) and other federal, state and local entities. They were tasked with ensuring the cohesive application and implementation of the policies mandates within, including the amendments of 1972. These amendments to this policy dictate the regulatory system still used today to establish if and when pollutants have entered the water system or if they will be permitted to. In order complete this task, the amendments of 1972 established two major permitting systems, the National Pollutant Discharge Elimination System (NPDES) program and the Section 404. After their implementation, these two systems were intended to cover entirely different spectrums of pollutant. The NPDES program is, in essence, governed by the Environmental Protection Agency (EPA), but is generally a state run permit program that allows a specific "person" to release pollutants. After the application and approval of the permit, point source pollution is allowed. However, it is heavily constrained, and the permits contain limits on what can be discharged, strict monitoring and reporting requirements, and other instance specific provisions to ensure that this pollution does not damage water quality or people's health beyond an acceptable level. The permits are only available for issue in states that have obtained EPA approval or by EPA regions in states without such approval. A NPDES general permit is written to cover multiple dischargers with similar types of discharges, based on the permit writer's knowledge of those types of activities and discharges. Individual NPDES permits are written for site-specific conditions of a single discharger that is unique to that discharger, based upon information found in the application for a permit. Applications are evaluated by Environmental Protection Agency officials and state officials. ("NPDES Frequent Questions | National Pollutant Discharge Elimination System (NPDES) | US EPA", 2016) Page 6 of 22
Section 404 works similarly to the NPDES program, though it has slightly more stringent checks and controls. Section 404 also uses permits, but uses them to regulate the discharge of dredged or fill material into waters of the United States, including wetlands, for specific one time occurrences of discharge. Activities regulated under this program include fill for development, water resource projects, infrastructure development and mining projects. ("Section 404 Permit Program | Section 404 of the Clean Water Act: Permitting Discharges of Dredge or Fill Material | US EPA", 2016) The basic premise of Section 404's permit program is that no discharge of material may be permitted if there is a practicable alternative that would be less damaging to the aquatic environment, or if the nation's waters would be significantly degraded. When applying for a permit, it must first be shown that steps have been taken to avoid, lessen, or negate the impact on wetlands, streams and other water sources. This also includes minimizing potential impacts, and if there will be an unavoidable impact, providing some type of compensation, either monetary, or through action. ("Section 404 Permit Program | Section 404 of the Clean Water Act: Permitting Discharges of Dredge or Fill Material | US EPA", 2016) Individual permits are reviewed by the U.S. Army Corps of Engineers to establish if there will be a significant effect. The Corps evaluates individual applications based on public interest, as well as the environmental criteria set out in Section 404. If there will be minimal impact, a general permit is issued. General permits under Section 404 can be issued on a nationwide, regional, or state basis, based upon the different categories of discharge. The Section 404 permit system is evaluated by joint efforts from the U.S. Fish and Wildlife Service and National Marine Fisheries Service, the U.S. Army Page 7 of 22
Corps of Engineers, and the Environmental Protection Agency, depending on what area of the U.S. waterways the permitted pollution would affect. ("Section 404 Permit Program | Section 404 of the Clean Water Act: Permitting Discharges of Dredge or Fill Material | US EPA", 2016) Causes and Challenges of Implementation There are many challenges to successful policy implementation, including legal, political, or economic conflicts. The implementations of the Clean Water Act and the amendments of 1972 are no exception to this rule. First, one of the more obvious challenges were the political limitations on a state level. A policy window may open when a problem is recognized, a policy is available and the political context is positive for change. (Kingdon, 1995) The policy window for the improvements of the Clean Water Act was mirrored in each case by political limitations and stressors. A focusing event is "an event that is sudden; relatively uncommon; can be reasonably defined as harmful or revealing the possibility of potentially greater future harms; has harms that are concentrated in a particular geographical area or community of interest; and that is known to policy makers and the public simultaneously" ( Kingdon 1995, 94­100). The focusing event will often cause the opening of a policy window. Examples of stressors that were focusing events for the Clean Water Act included events such as; a report released that indicated the annual loss of three million dollars due to pollution in the Chesapeake Bay, measured bacteria levels within the Hudson river recorded at over 170 times the safe limit, and a Record Number of fish deaths in 1969, totaling 41 million. ("NOW with Bill Moyers. Science & Health. Troubled Waters - A Brief History of the Clean Water Act | PBS", 2016) Page 8 of 22
However, what could arguably be seen as one of the largest focusing events was `burning river.' On June 22, 1969, the Cuyahoga River in Cleveland caught fire when sparks from a passing train set fire to oil-soaked debris floating on the water's surface. The occurrence caught national attention, despite reporting that used photos from a 1952 fire on the same river.. This small flare up was more shocking in that it showed the improvement that the water had already made, despite not containing any visible living organisms, and catching fire quite often, as the quantity of industrial dumping had actually decreased since the 1952 fire (Latson, 2016). In any case, the Cuyahoga became a notable name in the nation's mounting battle over environmental issues. This focusing event is credited with sparking the concerns that led to wideranging reforms, including the passage of the Clean Water Act and the creation of federal and state environmental protection agencies. Following the initial implementation, the Federal Water Pollution Control Act of 1948 was subject to many amendments in order to authorize new water quality programs, provide new standards and procedures, and reauthorize the act for federal funding. Amendments prior to 1972 were responsible for modifying the basic structure of the act and received little attention, while the policy window, framed by growing public concern led to the larger, sweeping amendments of 1972, which were then backed by political interest and concern (Ryan). The requests of many, including more than six state governors from across the political spectrum, multiple representatives of state and federal agencies, and interest groups indicated increasing interest in an updated federal standard, based on new and better technologies, and as a continuation of existing strong state level water quality standards. As a result of the petitions before the legislation, work on the new federal water act began in April of 1970, and a draft was in place by Page 9 of 22
the beginning of 1971. This draft was known as S.2770, and was introduced by then Democratic Senator Edmund Muskie. Despite the obvious pattern of public concern, there was a great deal of opposition to the bill, notably from state legislators, who were under pressure from their home jurisdictions to defend states rights to regulate their own waterways. As Chairman of the House Public Works Committee John Blatnik said, "They are all men of good intentions, but they get beat over the head by powerful interests back home" (Houck, 2002). The statesmen, especially those of the more conservative kind, were more inclined to support the state's rights, arguing that water should be regulated by local uses, instead of national standards. Congressman Roe (RTennessee) , Congressman Robison (R-New York), and Congressman Frenzel (R-Minnesota), were all avid supporters of a states rights to regulate, and made this known on the record, before committee and their fellow congress members, lamenting centralism and an overreaching government. (Houck, pg. 15, 2002) Not only was there only a great deal of anger toward the initial policy from individual state legislators, seeking to defend their state's right to regulate their own waterways, but there was also the challenge of state capacity to properly handle and implement the newly updated legislation (Houck, 2002). Federal funding and support for infrastructure was needed, as was the political "know-how" to soothe the fears of legislators and constituents and ensure that there was nationwide support of the policy's legitimacy. Despite his initial political support for the environmental bill, President Nixon vetoed the act, due to the rising costs of the policy and his insistence that all environmental proposals meet the cost-benefit standards of the Office of Management and Budget (Madel, 2012). The bill was eventually passed, despite the two veto attempts, as on October 18, 1972, first the Senate, then the House overrode Nixon's veto and the Page 10 of 22
bill became law. Afterwards, a new struggle appeared, as Nixon refused to spend the money appropriated by Congress for the purposes of the Clean Water Act. Using his presidential powers to impound half of the money, Nixon was eventually challenged in the Supreme Court. In "Train v. City of New York (1975), the court ruled "that the president had no authority to withhold funds provided by Congress in the Clean Water Act of 1972," holding that "the 1972 Amendments do not permit the Administrator to allot to the States under § 205(a) less than the entire amounts authorized to be appropriated by § 207. Pp. 420 U. S. 42-49. In addition, the Impoundment Control Act of 1974 provided a means of controlling the President's ability to impound funds for programs that they don't support. (Train v. City of New York, 1975) It may also be worth noting that in 1972, there was a spike in quasi-sentences recorded for both the Democratic and Republican platforms regarding "drinking water," and for the Republican platform on "conservation." The Democratic platform had a spike in recorded quasisentences for "conservation" just after 1972. This data gives a hint to the changing nature of environmental awareness during the time period of the 1972 amendments, as well as future amendments, though the connotation of the speech is disregarded and not included in the final results. Figure 1 is constructed from data provided by Christina Wolbrecht and contains data sourced from the American Political Party Platforms: 1948-2008. It details the amount of recorded quasi-sentences regarding conservation and drinking water from the Democratic and Republican party platforms from 1948 until 2012. Page 11 of 22
Figure 1. Major Party Platforms 1948-2016; Conservation & Drinking Water Judicial Analysis Post-Implementation Second to the political challenges of implementation were the technical challenges of the Clean Water Act. These vary immensely depending on the portion of the act being reviewed. There was a distinct lack of trained and informed personnel at the outset of this policy's implementation, and a great deal of Interagency Cooperation that had to be established. Many of the terms used within the act were defined, however, their meanings were not always plainly evident, or specific, leading to complaints that the law was far too vague, which lead to challenges in court after enforcement of the policy was attempted. Page 12 of 22
The following is taken direction from the Environmental Law Institute Jurisdictional handbook on the Clean Water Act, and serve to give an indication of just how broad the directions contained within the act can be; "The term "discharge" includes the "discharge of a pollutant" or the "discharge of pollutants," which in turn means "any addition of any pollutant to navigable waters from any point source." A pollutant can be practically anything: "dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt and industrial, municipal, and agricultural waste discharged into water." A "point source" under the Act is "any discernible, confined and discrete conveyance, including but not limited to any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, or vessel or other floating craft, from which pollutants are or may be discharged." (Environmental Law Institute, 2012) Given the wide ranging definitions, it is no surprise that there were many court cases involving the CWA that made it to the federal level. In turn, these lapses in the policy led to the further amendments to the CWA, such as the addition of a specific Total Maximum Daily Load (TMDL) regulation, which describes the maximum amount of a pollutant that a body of water can receive while still meeting water quality standards. These further amendments and policy changes were brought forward by many levels of the legislation and the bureaucracy, including the EPA itself, which spearheaded the TMDL regulation changes in 1992. Page 13 of 22
One of the largest problems that occurred once the Clean Water Act was amended to include these stronger regulatory systems, was defining what could be categorized as being in offense, or in breach of the policy. In the past, implementation of policy has been considered, simple, and almost unimportant in that once the policy had passed it was now up to a "series of mundane decisions and interactions unworthy of the attention of scholars" (Van Meter & Van Horn, 1975,). We know, of course, that this is not true. Implementation is not a simple task, nor is it unimportant. For one, it has no clear starting point, and no clear ending. There are numerous challenges that can be found and are often largely unexpected by those who initiated the policy change (Hill & Hupe, 2014). If a policy change like the Clean Water Act were to be smoothly implemented, one can assume that there would be few judicial challenges on the basis of definition after a suitable time frame that allowed for confusion, adjustment of practices, and the cyclical nature of policy. One can also assume that in due time, the amount of challenges would decline (Van Meter & Van Horn, 1975). When looking at judicial analysis of the elements of major judicial challenges, we can see that this smooth and easy implementation was not quite achieved. There were many cases brought forward in regards to the Clean Water Act, a measure that can be used to indicate how smoothly implementation went. By looking at a detailed analysis of how Federal Courts have interpreted each element of the Clean Water Act, we may gain an understanding of where the implementation went wrong, either in defining offenses, or in enforcement. The following data is drawn from the last article in a series of four, titled; in Plain Meaning, Precedent, and Metaphysics: Lessons in Statutory Interpretation From Analyzing the Elements of the Clean Water Act Offense and written by Jeffrey Miller. It is used to draw conclusions about general statutory interpretation by focusing Page 14 of 22
on the judicial action taken for cases involving the Clean Water Act. Within the data analyzed, we see that there are 258 federal cases that dealt with statutory issues of the Clean Water Act, each case covering at least one out of the four categories of offenses; addition, pollution, navigable waters, and point source, all of which were defined prior. Figure 2: Analyzed Federal Court Cases by Offense Type, 1974-2013. Spanning from 1974 to 2013, 63 of the analyzed cases dealt with offenses of addition, 72 with offenses of pollution, 141 dealt with offenses of navigable waters, and 71 with offenses of point source (Fig. 2). This analysis may actually give a positive reflection of the Court's ability to affect policy, building upon prior precedent due to the lack of anything more concrete to focus Page 15 of 22
their interpretation on, but ultimately we do see one of the strongest arguments that the implementation of the Clean Water Act Amendments of 1972 was not smooth nor effective toward its end goal ("Implementation: Putting Policy into Practice", 2016). The definitions, as stated above, were vague, which speaks to a failure within the construction and implementation of the policy, as opposed to an enforcement level. The enforcement was occurring, it was just lacking in proper basis and obviously struggling, despite the potential that the Clean Water Act presented. It is worth noting that some of these cases overlap, and the type of offense is qualified by the courts stand on the issue. As stated by the author, "where text has no clear meaning or is ambiguous, plain meaning won't help much; and if the interpretation is a matter of first impression, precedent may not help much either. In those situations, other interpretive devices must be used" (Miller, 2016). Outcomes An argument commonly put forward about the 1972 amendments to the CWA is that by allowing permits to be purchased through the NDPES and Section 404 programs, that the purpose of the act, especially with attention to the clause that sought to "maintain" the integrity of the U. S. waters, was voided. It was also questioned after the implementation of the 1972 amendments, whether or not the EPA would have the resources needed to continue to develop and update federal water quality criteria or to properly evaluate the water quality standards developed by the states. But, there was some hope and improvement, as testified the EPA Assistant Administrator for Water, in 1986: Page 16 of 22
"Before the 1972 law, you'd get into these long, long debates with dischargers who would say "No, let me prove to you that this isn't a problem." So I guess my feeling is that having established a very strong nationwide enforcement structure, we have got a tool that will allow us not to get lost in endless scientific debates." (Houck, 2002) In any case, the proposals for modifying, overturning, or extending the policy as it was enacted were many, even after the major amendments of 1972. It was obvious that improvements were needed, and following 1972, major amendments to the act occurred in 1977 and 1987, with some smaller amendments occurring in the years between. A unique feature to come about from these amendments was the "citizen suit." According to the act, any citizen can bring a civil suit against a corporation or citizen, the U.S. government or federal agency, or the EPA Administrator for engaging in conduct unlawful under the Clean Water Act. Established by the Office of Enforcement and Compliance Assurance (OECA), which is housed in the EPA, this addition not only reinforces the idea that the Clean Water Act was designed to protect Citizen's rights, but it also allows for non-bureaucratic enforcement in the form of concerned citizens, lifting some burdens from the EPA. It also allows citizens to provide oversight, as a citizen may also sue the EPA or any other government agency that is not fulfilling or following the policies of the Clean Water Act. The citizen suit came about as a part of the Clean Water Act (CWA) Action Plan, which outlines how the EPA will improve the way it addresses the water pollution challenges. The Action Plan was issued on October 15, 2009, and prior to February 22, 2010, was known as the Clean Water Act Enforcement Action Plan (Environmental Protection Agency, 2009). Page 17 of 22
There are some fiscal drawbacks to the Clean Water Act. As Nixon feared back the 1970's, the price of this policy was high, especially in maintaining this legislation. It must also be noted that in protecting our Nation's waters, we gain much that cannot be easily measured. There are the health benefits to the citizens, the lack of infrastructure damage due to heavy pollutants, the economic benefits that fishing, boating and tourism industries bring in across the nation, and to specific states. However, 2015, the U.S. EPA and Army estimated that the annual costs occurring from new Clean Water legislation would range from $153.4 million to $306.6 million, while the benefits of the Clean Water Act will fall between $338.9 million to $349.5 million, showing that even fiscally, the benefits of environmental legislation outweigh the costs (Wharton, 2015). There are also the arguments as we move forward, that the Clean Water Act is harming business owners, and destroying jobs, though there is no factual basis for this. In fact, many small business owners are calling for stronger legislation, knowing how dependent upon clean water they, and their consumers, are (American Sustainable Business Council, 2014). Conclusion Early legislation such as the Federal Water Pollution Control Act Amendments of 1972 play a crucial role in today's fight for environmental justice, especially in resolving the pollution that impacts water of the world. Arguably, and an argument parroted by William Ruckelshaus, first head of the EPA, the two persons that were affected most by the passage of this policy were the community members, and the dischargers. The dischargers were no longer allowed to pollute any waterway they wished, and instead, could be fined or taken to court over their actions. The Page 18 of 22
community members received cleaner waters, swimmable, drinkable, and fishable waters, along with the rises in economic health, public health, and environmental quality that came with such policy changes. While the 1972 amendments did not fully achieve their specific goals, this legislation did lay the necessary framework for future policy work, including future amendments within the same bill. Most importantly, an often overlooked effect of the CWA is that it reveals the complexity between the Constitution, states' rights, and federal policy, ushering in a new standard in widespread environmental policy (Craig, 2009). The public has an undeniable legal right to a clean and healthy environment, and while the Clean Water Act still has room for improvement, there is no denying that the relatively simple implementation of the 1972 amendments, as well as the progress that followed from this occasion is both laudable and a standard to which newly enacted policy can be held.
Works Cited
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[1] American Sustainable Business Council. Small Business Owners Favor Regulations to Protect Clean Water (2014). July 2014. Web. [2] The Cost of Regulations Implementing the Clean Water Act. (2016). Mercatus Center. Retrieved 28 November 2016, from https://www.mercatus.org/publication/cost-regulations-implementing-clean-wateract [3] Craig, R. K., & Environmental Law Institute. (2009). The Clean Water Act and the Constitution: Legal Structure and the public's right to a clean and healthy environment. Washington, D.C: Environmental Law Institute. [4] Details for S. 2770 (92nd): An Act to amend the Federal Water Pollution Control Act - GovTrack.us. (2016). GovTrack.us. Retrieved 14 October 2016, from https://www.govtrack.us/congress/bills/92/s2770/details [5] Economic Implications, Viewpoints and Solutions for the Success of the Clean Water Rule:Penn Wharton Public Policy Initiative. (2015). Publicpolicy.wharton.upenn.edu. Retrieved 28 November 2016, from https://publicpolicy.wharton.upenn.edu/live/news/743-impact-of-the-clean-water-rule-on-the-useconomy [6] Environmental Law Institute ,. (2012). The Clean Water Act Jurisdictional Handbook. Washington DC: Environmental Law Institute. Retrieved from http://www.eli.org/sites/default/files/eli-pubs/d2201.pdf Page 20 of 22
[7 ]Environmental Protection Agency,. (2009). Clean Water Act Action Plan. Office of Enforcement and Compliance Assurance (OECA). [8] Federal Water Pollution Control Act Amendments of 1972, Public Law 92-500-OCT. 18, 1972. [9] Houck, O. A. (2002). The Clean Water Act TMDL program: Law, policy, and implementation. Washington, D.C: Environmental Law Institute. [10] Hill, M. & Hupe, P. (2014). Implementing public policy (1st ed.). Los Angeles [i.e. Thousand Oaks, Calif.]: Sage Publications. [11] History of the Clean Water Act | Laws & Regulations | US EPA. (2016). Epa.gov. Retrieved 14 October 2016, from https://www.epa.gov/laws-regulations/history-clean-water-act [12] Implementation: Putting Policy into Practice. (2016). Public Administration. Retrieved 11 November 2016, from http://www.ru.nl/publicadministration/research/our-research-0/read-more/ [13] Latson, J. (2016). The Burning River That Sparked a Revolution. TIME.com. Retrieved 28 November 2016, from http://time.com/3921976/cuyahoga-fire/ [14] Madel, R. (2012). Nixon's Clean Water Act Impoundment Power Play. The Huffington Post. Retrieved 28 November 2016, from http://www.huffingtonpost.com/robin-madel/nixons-clean-water-actim_b_1372740.html [15] Miller, J. (2016). Plain Meaning, Precedent, and Metaphysics: Lessons in Statutory Interpretation From Analyzing the Elements of the Clean Water Act Offense. Page 21 of 22
[16] NOW with Bill Moyers. Science & Health. Troubled Waters - A Brief History of the Clean Water Act | PBS. (2016). Pbs.org. Retrieved 28 November 2016, from http://www.pbs.org/now/science/cleanwater.html [17] NPDES Frequent Questions | National Pollutant Discharge Elimination System (NPDES) | US EPA. (2016). Epa.gov. Retrieved 11 November 2016, from https://www.epa.gov/npdes/npdes-frequentquestions [18] O'Toole, L. (2004). The Theory-Practice Issue in Policy Implementation Research. Public Administration, 82(2), 309-329. http://dx.doi.org/10.1111/j.0033-3298.2004.00396.x [19] Ryan, M., & American Bar Association. (2011). The Clean Water Act Handbook. Chicago: Section of Environment, Energy, and Resources, American Bar Association. [20] Section 404 Permit Program | Section 404 of the Clean Water Act: Permitting Discharges of Dredge or Fill Material | US EPA. (2016). Epa.gov. Retrieved 11 November 2016, from https://www.epa.gov/cwa-404/section-404-permit-program [21] Summary of the Clean Water Act | Laws & Regulations | US EPA. (2016). Epa.gov. Retrieved 14 October 2016, from https://www.epa.gov/laws-regulations/summary-clean-water-act [22] Van Meter, D. & Van Horn, C. (1975). The Policy Implementation Process: A conceptual framework. Administration & Society, 6(4), 445-488. http://dx.doi.org/10.1177/009539977500600404 Page 22 of 22

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