final clean water act rulef.datasrvr.com/fr1/115/92908/san_francisco_ppt...what does “adjacent”...

Some jurisdictions in which Perkins Coie LLP practices law may require that this communication be designated as Advertising Materials. Perkins Coie LLP | July 2015 perkinscoie.com/

THURSDAY, JULY 9, 2015 11:30 a.m. – 1:00 p.m.

PERKINS COIE Four Embarcadero Center Suite 2400 San Francisco, CA 94111-4131

The New Clean Water Rule and What It Means in California A LUNCH SEMINAR PRESENTED BY PERKINS COIE’S LAND DEVELOPMENT INDUSTRY GROUP

The New Clean Water Rule and What It Means in California

TABLE OF CONTENTS

Tab 1: Perkins Coie PowerPoint Presentation

Tab 2: WRA PowerPoint Presentation

Tab 3: Biographies

Some jurisdictions in which Perkins Coie LLP practices law may require that this communication be designated as Advertising Materials. Perkins Coie LLP | July 2015 perkinscoie.com/

Perkins Coie LLP

History of the Definition of “Waters of the United States” July 9, 2015 San Francisco, CA

Marc Bruner & Laura Zagar Perkins Coie

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Perkins Coie LLP | PerkinsCoie.com

How Did We Get Here?

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The Clean Water Act

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The Clean Water Act regulates discharges of pollutants into the “waters of the United States.”


Section 404 of the Clean Water Act

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• Section 404 requires a permit from the. Army Corps of Engineers for “the discharge of dredged or fill material into the navigable waters.”

• “Navigable waters” defined only as “waters of the United States, including territorial seas.”

• Final rule also affects permit requirement under Section 402 for the discharge of wastewater or storm water into navigable waters.


What is a Water of the United States?

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Rapanos v. United States, 547 U.S. 715 (2006)

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Supreme Court interprets “waters of the U.S.”

Traditional navigable waters + relatively permanent waters + wetlands with a “continuous surface connection” to one of the above

Traditional navigable waters + all other waters (including intermittent flows) with a “significant nexus” to a traditional navigable water

Endorsed the agencies’ historically broad view of Clean Water Act jurisdiction


More on Rapanos

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• Be careful what you wish for: Chief Justice Roberts (who joined Scalia’s opinion) scolded the EPA and the Corps for not conducting a formal rulemaking to better define the term “waters of the U.S.”

• Chief Justice Roberts also predicted in Rapanos – quite correctly – that without a clear standard, “lower courts and regulated entities will have to feel their way on a case-by-case basis.”


Rapanos: Clear As Mud?

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The Agencies’ Attempt to Resolve the Uncertainty through Informal Guidance

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2007-2008 Guidance • Interpretive guidance – not a formal regulation • As Justice Roberts predicted, the guidance relied on a

cumbersome case-by-case scientific analysis to determine whether or not a “significant nexus” exists

Draft 2011 Guidance • Five years after Rapanos, still no formal rulemaking • Much broader view of Clean Water Act jurisdiction than

the 2007-2008 guidance • Politically controversial, never finalized and ultimately

abandoned


The Connectivity Study: Background

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• Purpose: To create scientific evidence to support a rule defining the “waters of the US”

• Sept. 2013: Draft Report released: Connectivity of Streams and Wetlands to Downstream Waters: A Review and Synthesis of the Scientific Evidence

• Apr. 2014: Agencies adopt proposed Clean Water Act rule

• Oct. 2014: EPA Scientific Advisory Board completes peer review of the Connectivity Report

• Jan. 2015: EPA releases the final Connectivity Report • June 29, 2015: Agencies adopt final Clean Water Act

rule


The Connectivity Study: Key Findings

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• All streams, without regard to size or duration of flow, are connected to and have important effects on downstream waters

• Wetlands and open waters in floodplains and riparian areas are integrated with and strongly influence downstream waters

• Isolated wetlands and open waters may benefit downstream waters, depending on a site-specific analysis, even when there is no hydrologic connection

Perkins Coie LLP

The Clean Water Act Rule Explained

July 9, 2015 San Francisco, CA


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Proposed “Waters of the U.S.” Rule

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• Apr. 2014: EPA and Army Corps issue proposed regulation to define “waters of the U.S.” The proposed rule takes an expansive view of federal jurisdiction.

• Goals: To increase “transparency, predictability, and consistency” leading to “increased clarity” and “less litigation”

• Response: Extremely controversial – over 1 million comments


More on the Proposed Rule

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Proposed definition of “waters of the U.S.” included: (1) Navigable waters (including waters that are currently used,

were used in the past, or may be susceptible to use in the future for interstate or foreign commerce);

(2) All interstate waters; (3) The territorial seas; (4) Impoundments of water bodies that otherwise meet the

definition of “waters of the U.S.”; (5) All “tributaries” of water bodies in categories (1) – (3); (6) Waters “adjacent” to water bodies in categories (1) – (5); (7) “Other waters” that are determined on a case-specific basis

to have a “significant nexus” to a water body in categories (1) – (3).


June 29, 2015 Final “Waters of the U.S.” Rule

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Final definition of “waters of the U.S.” includes: (1) Navigable waters; (2) All interstate waters; (3) The territorial seas; (4) All “tributaries” of water bodies in categories (1) – (3); (5) Impoundments of water bodies that otherwise meet the definition of

“waters of the U.S.”; (6) Waters “adjacent” to water bodies in categories (1) – (5); (7) Certain types of waters that are determined, on a case-specific basis,

to have a “significant nexus” to a water bodies in categories (1) – (3); (8) Waters within the 100-year floodplain of a water body in categories

(1) – (3) and waters within 4,000 of the high-tide line or ordinary high water mark of a water body in categories (1) – (5), when it is determined, on a case-specific basis, that the water has a “significant nexus” to a water body in categories (1) – (3).


What Has Changed? Tributaries

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After Rapanos, it was an open question whether intermittent or ephemeral tributary streams were jurisdictional.

The proposed rule defined tributaries to include all waterways (natural or man-made) that have a bed & banks and an ordinary high water mark, and contribute flows (either directly or indirectly) to a downstream navigable water.

The final rule is similar to the proposed rule.

The final rule explains that the presence of a bed & banks and an OHWM demonstrate sufficient volume, frequency and duration of flow to qualify as a jurisdictional tributary.


More on Tributaries

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• Intermittent and ephemeral steams, regardless of size or duration of flow, are automatically jurisdictional under the final rule if they have a bed & banks and an OHWM and contribute flow (directly or indirectly) to a downstream navigable water.

• Tributaries that qualify under the rule do not lose their jurisdictional status “if, for any length, there are one or more constructed breaks (such as bridges, culverts, pipes or dams), or one or more natural breaks (such as wetlands along the run of a stream, debris piles, boulder fields, or a stream that flows underground) ….”

• As explained in the following slides, water bodies without a bed & banks and an OHWM can still be jurisdictional either (1) as an “adjacent” water, or (2) under a case-specific significant nexus analysis.


Ordinary High Water Mark – Flow Indicators?

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Bed and Banks – Flow Indicators?

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What Has Changed? “Adjacent” Waters

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Under the prior regulations, wetlands adjacent to jurisdictional waters were also jurisdictional. This “adjacency jurisdiction” applied only to wetlands, which are a special type of aquatic feature.

The proposed rule would have expanded the definition of adjacency to cover any water within the floodplain or riparian area of a navigable water. In some cases, floodplain areas can extend for miles.

The final rule defines adjacency in terms of fixed distances between the water body in question and other jurisdictional waters. Like the proposed rule, “adjacency jurisdiction” is not limited to wetlands.


What Does “Adjacent” Mean?

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“Adjacent” means bordering, contiguous to, or neighboring a jurisdictional water. Under the final rule, “neighboring” is defined to include any water body that is located: (1) within the 100-year floodplain and within 1,500 feet of the

OHWM of a jurisdictional water; or

(2) within 100 feet of the OHWM of a jurisdictional water, regardless of where the floodplain is located; or

(3) within 1,500 feet of the high-tide line of a tidally influenced water.

Note that “adjacent” waters are automatically jurisdictional and do not require a case-specific significant nexus analysis.


What Has Changed? Significant Nexus

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After Rapanos, case-by-case “significant nexus” analysis was needed for many waters to determine if they had “more than speculative or insubstantial” effect on the chemical, physical or biological integrity of downstream navigable waters.

The proposed rule sought to avoid most case-by-case analysis by categorically asserting authority over a broader set of water bodies. “Other waters” not falling into a defined category of “waters of the U.S.” would still be subject to case-by-case significant nexus analysis.

The final rule sets out two specific categories for case-by-case analysis: (1) certain specific types of water bodies, such as vernal pools; and (2) waters (not otherwise jurisdictional) that are either in a 100-year floodplain or within 4,000 feet from the high-tide line or OHWM. The final rule also broadens the definition of “significant.”

Perkins Coie LLP | PerkinsCoie.com 25

The final rule sets up a three-step process for determining whether a significant nexus exists:

(1) What is the “region” where the target water is located? (2) Are there “similarly situated” waters within the region? (3) Is there a significant chemical, physical, or biological effect on a jurisdictional water from either the target water or the combined similarly situated waters?

Process for “Significant Nexus” Determination


What Is a “Significant” Nexus?

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• Under the final rule, a significant nexus may be based on one or more of the following functions provided by the water body in question: • Sediment trapping • Nutrient recycling • Pollutant trapping, transformation, filtering or transport • Retention & attenuation of flood waters • Runoff storage • Contribution of flow • Export of organic matter or food resources • Provision of life cycle dependent habitat.

• “Significant” defined as “more than a speculative or insubstantial” effect on downstream waters – but what does this mean?

• The EPA and the Corps retain a lot discretion and flexibility in determining whether or not a significant nexus exists.


What Has Changed? Ditches

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• Historically, certain types of ditches were generally exempted from Clean Water Act coverage, but the agencies retained the ability to assert permitting authority on a case-by-case basis.

• The proposed rule would have excluded from jurisdiction upland ditches with “less than perennial flow,” but there was concern that federal authority over ditches would be greatly expanded.

• The final rule addresses some of this concern by excluding from jurisdiction ditches with ephemeral or intermittent flows that do not relocate a tributary and are not excavated in a tributary.


Other Exemptions

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• Artificially irrigated areas that would revert to dry land if the irrigation ceased

• Constructed lakes and ponds created in dry land (e.g., farm or stock watering ponds, irrigation ponds, settling basins, etc.)

• Artificial reflecting or swimming pools or small ornamental waters created in dry land

• Water-filled depressions crated in dry land that are incidental to mining or construction activity

• Erosional features such as gullies, rills and other ephemeral features that do not meet the definition of a “tributary”

• Puddles • Groundwater • Storm water control features created in dry land • Wastewater recycling facilities

Perkins Coie LLP

Clean Water Act Rule: Uncertainties & Implications July 9, 2015 San Francisco, CA


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Uncertainties and Potential Problems

• Ephemeral Waters & the Definition of “Tributary”: Many ephemeral waters in the West have a bed and banks and an ordinary high water mark – and thus meet the definition of “tributary” – due to powerful but extremely infrequent flows, with only insignificant and temporary effects on downstream waters.

• Adjacency: The definition of “adjacent” extends out to 1,500 feet and thus eliminates any notion of close physical proximity.

• Significant Nexus Test: The test is extremely broad, flexible, and open-ended – allowing a significant nexus finding for isolated waters based on any one of nine different factors.

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Uncertainties and Potential Problems - Ditches

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• Various terms in the new rule are important in ascertaining whether or not a ditch is jurisdictional (“intermittent,” “ephemeral,” “relocated tributary”), but these terms are not defined.

• Do the terms “intermittent” and “ephemeral” involve some notion of seasonal or perennial regularity?

• Many man-made ditches in the West derive their water from lawful diversions from rivers and streams. Do these man-made ditches constitute “relocated streams”?

• The new rule allows for some portions of a ditch to be exempt and other portions to be jurisdictional. This segment-by-segment approach may be confusing and difficult to implement.


Implications for Development in California

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• The final rule likely will increase costs for Clean Water Act permitting, compliance and mitigation. In addition, the Act’s requirement to adopt the Least Environmentally Damaging Practicable Alternative (LEDPA) may result in restrictions and limitations on developing property.

• However, under California state law (Porter-Cologne Water Quality Control Act), the Regional Water Quality Control Boards have asserted broad permitting authority over “waters of the state” – regardless of whether there is federal jurisdiction under the Clean Water Act.

• As a result, even where a landowner or developer can successfully avoid federal jurisdiction, it may still have to meet state law requirements that are equally or more stringent.

• The interplay between the new federal rule and the independent state law requirements should be carefully considered.


Practical Tips

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• Use existing jurisdictional determination if you have one: JDs generally last for five years. If you have an existing, approved JD that finds that your property is not jurisdictional, explore ways to maximize use of the JD before its expiration. This could help to complete any development work that might be deemed jurisdictional under a renewed JD based on the new final rule.

• Consider “Preliminary JD” when jurisdiction is in dispute: Instead of engaging in a prolonged dispute with the Corps (and potentially the EPA) over the precise scope of federal jurisdiction, some developers elect to use a Preliminary JD, which effectively concedes jurisdiction in return for more expeditious permitting.


Final Tip

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If you’ve got a development on the drawing board or even just a piece of land, it is a good idea to sit down now with your attorney and consultant and plan how you’re going to proceed under the new rule.

Perkins Coie LLP

Challenges to the New Rule

July 9, 2015 San Francisco, CA


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Proposed Legislation in the House

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The rulemaking has been extremely controversial in Congress, where legislative efforts have intensified in recent months to block or overturn the rule: • H.R. 1732, Regulatory Integrity Protection Act (passed the House in

May 2015): Would require the agencies to withdraw the rule and work closely with state and local governments on a revised rule.

• H.R. 2020, FY 2016 Energy and Water Appropriations Bill (passed the House in May 2015): Would prohibit Corps from spending money to implement any change in regulations pertaining to the discharge of fill material under the Clean Water Act.

• Other House bills: H.R. 594, Waters of the U.S. Regulatory Overreach Protection Act; H.R. 897, Reducing Regulatory Burdens Act; H.R. 1029, EPA Science Advisory Board Reform Act; and H.R. 1030, Secret Science Reform Act


Proposed Legislation in the Senate

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• On June 10, 2015, the Senate Committee on Environment & Public Works voted along party lines to move forward with S. 1140, the Federal Water Quality Protection Act.

• This bill is similar to H.R. 1732, which recently passed the House. The bill would require the agencies to withdraw the Clean Water Act rule and would establish a set of legislative principles that a revised rule would need to satisfy.

• Any measure that Congress enacts likely would encounter a Presidential veto.


Lawsuits Challenging the Final Rule

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• Numerous lawsuits already have been filed in federal court to challenge the final rule. These lawsuits contend that the rule is arbitrary and unsupported, violates the Clean Water Act, exceeds federal government authority under the Commerce Clause, and infringes on the authority of the States under the Tenth Amendment. • A coalition of 13 states brought suit in North Dakota • Ohio brought suit in the Southern District of Ohio • Texas, Mississippi and Louisiana brought suit in the Southern District

of Texas • Numerous plaintiffs (including the American Farm Bureau Federation,

American Petroleum Institute, and National Association of Home Builders) also brought suit in the Southern District of Texas.

• Murray Energy brought suit in the Northern District of West Virginia


What’s Next?

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• As Justice Alito lamented about the term “waters of the U.S.” a few years ago in Sackett v. EPA, 132 S. Ct. 1367 (2012), “the words themselves are hopelessly indeterminate” and since the Clean Water Act was first adopted in 1972, “Congress has done nothing to resolve this critical ambiguity.”

• In the absence of Congressional action, the agencies have now sought to reassert and expand their authority through the issuance of the final rule.

• And in the absence of decisive Congressional action, it will be for the courts to decide the boundaries of Clean Water Act jurisdiction and what constitutes a “water of the U.S.”


CLE Credit

40

We are offering CLE credit for live and webinar attendees in California. If you are attending via

webinar, please e-mail Keri Sweet at [email protected] and indicate you are

seeking CLE credit.

If you are here in person, please use the sign in sheet.

mailto:[email protected]

SAN RAFAEL • SAN DIEGO • DENVER • FORT BRAGG www.wra-ca.com (415) 454-8868 41

(415) 454-8868 SAN RAFAEL SAN DIEGO DENVER FORT BRAGG

Case Studies and Applications of the Final Rule

Waters of the US – Final Rule What does this mean for you and your project

(415) 454-8868 SAN RAFAEL SAN DIEGO FORT BRAGG DENVER

http://www.wra-ca.com/



http://bit.ly/16cfWVU



What is Jurisdictional

Always: 1. Traditional Navigable Waters 2. Interstate Waters 3. Territorial Seas 4. Impoundments of jurisdictional waters 5. Tributaries 6. Adjacent Waters Sometimes (Always?) Jurisdictional 1. Case-Specific Significant Nexus Determinations






Adjacent Waters (Jurisdictional)

“Under this final rule, ‘‘adjacent’’ means bordering, contiguous, or neighboring…” Neighboring: 1) Waters located in whole or in part within 100 feet of the

OHWM of a traditional navigable water or tributary 2) Waters located in whole or in part in the 100-year

floodplain and that are within 1,500 feet of the ordinary high water mark of a traditional navigable water or tributary






The Final Rule on the Landscape






Case-Specific Significant Nexus

Which waters apply? “…waters within 4,000 feet of the high tide line or the ordinary high water mark of a traditional navigable water, interstate water, the territorial seas, impoundments, or covered tributary are subject to case-specific significant nexus determinations.”

Justification: “In establishing the 4,000 foot bright line boundaries for these case-specific significant nexus determinations in the rule, the agencies are carefully applying the available science.”






The Final Rule on the Landscape






Significant Nexus Criteria

- Sediment trapping - Nutrient recycling - Pollutant trapping, transformation, filtering, and transport - Retention and attenuation of flood waters - Runoff storage - Contribution of flow - Export of organic matter - Export of food resources - Provision of life-cycle dependent aquatic habitat for species located in a TNW






How easy is it to meet the SNX?

EPA 2013: Connectivity of Streams and Wetlands to Downstream Waters: A Review and Synthesis of the Scientific Evidence Over 1500 studies reviewed showing SNX

Final Rule: “…if a water, either alone or in combination with similarly situated waters, performs just one function, and that function has a significant impact on the integrity of a traditional navigable water, interstate water, or the territorial seas, that water would have a significant nexus.”

“Significant” - more than ‘‘speculative or insubstantial’’






Significant Nexus Process

Similarly situated waters: “function alike and are sufficiently close to function together in affecting downstream waters…” “…aggregating ‘similarly situated’ waters is scientifically justified, given that the combined effects of these waters on downstream waters are often only measurable in aggregate.”






Case Study – Case-Specific Significant Nexus Previously isolated group of depressional wetlands located within 4,000 ft. of tributary to TNW - Sediment trapping - Pollutant trapping, transformation,

filtering, and transport - Retention and attenuation of flood

waters - Runoff storage = 1 acre of new jurisdictional wetlands






Case Study – Case Specific Significant Nexus Previously isolated waters located within 4,000 ft. of tributary to TNW






Case Study – Case Specific Significant Nexus Previously isolated waters located within 4,000 ft. of tributary to TNW

- Pollutant transport - Contribution of flow - Export of organic

matter - Export of food

resources






What does this mean for your project?

Increase of Waters of the US • More difficult avoidance and minimization • Reduced project footprint or increased wetland impacts • Increase potential for Individual Permit/Section 404(b)(1)

Alternatives Analysis • Increased mitigation requirements • Increased permitting timelines (new policy = new forms,

more training, lots of confusion…) • Varied application by PM and District, means lack of

consistency and unknown outcomes






When Will this Take Effect!?

As a general matter, the agencies’ actions are governed by the rule in effect at the time the agency issues a jurisdictional determination or permit authorization, not by the date of a permit application, request for authorization, or request for a jurisdictional determination.

Individual Corps districts may elect to treat the application of the new rule differently






When Will this Take Effect!?

• Existing Jurisdictional Determinations (or associated permits) will not change as long as they are valid

• Existing PJDs will not change • Delineations submitted for verification before the rule

issued may be treated under old rule • Delineations submitted for verification after the rule

published likely treated under the new Final Rule






What is NOT Jurisdictional

Newly Exempt Waters Category:

Puddles

Insert puddle pic






Source: SFEI CARI dataset

17 individual areas outside of

4,000 feet of a mapped tributary




LAURA GODFREY ZAGAR | PARTNER | SAN DIEGO, CA www.perkinscoie.com/LZAGAR/

An environmental law counselor and litigator, Laura Godfrey Zagar has played a prominent part in several innovative transmission lines, renewable energy, and infrastructure projects. Laura is a partner in the Environment, Energy & Resources practice, and regularly manages multijurisdictional energy and infrastructure projects as well as complex environmental litigation.

Laura represents utilities, agencies, energy developers and others before federal, state and local agencies. Her project experience includes numerous major transmission lines, as well as wind, solar, and conventional energy projects. Laura has extensive experience with federal, state and local land use and natural resource agencies, including the Bureau of Land Management (BLM), the U.S. Forest Service, the U.S. Fish and Wildlife Service, the California Public Utilities Commission, and the U.S. Army Corps of Engineers. Laura provides clients with comprehensive counseling on compliance with a wide array of environmental statutes. Areas of focus include the National Environmental Policy Act (NEPA), federal and California Endangered Species Acts (ESA), the Clean Water Act, the Clean Air Act, the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and California Environmental Quality Act (CEQA).

Laura often advises clients on Clean Water Act permitting issues, as well as state water quality statutes, such as California’s Porter-Cologne Act. She has also represented clients in enforcement actions involving water quality issues.

EDUCATION • UCLA School of Law, J.D., Order of the Coif, 2002 • Princeton University, A.B., cum laude, 1999

BAR ADMISSIONS • California

Biographies

Perkins Coie LLP | Confidential

MARC R. BRUNER | PARTNER | SAN FRANCISCO, CA www.perkinscoie.com/MBRUNER/

Marc Bruner represents governmental entities and private companies in a wide variety of environmental matters. He regularly works with clients in resolving complex compliance issues under the federal Clean Water Act, the California Porter-Cologne Water Quality Control Act, the federal and California Endangered Species Acts, the National Environmental Policy Act, the California Environmental Quality Act, the California Integrated Waste Management Act, and the panoply of California laws and regulations governing water supply, air quality, coastal development, development along the banks of streams and rivers, historic resources, and the management and disposal of solid and hazardous wastes.

Marc is particularly well-versed in the rules and regulations governing wetlands and aquatic resources, as well as the management of industrial, municipal and construction stormwater and the treatment and discharge of process wastewater under federal NPDES permits and state law waste discharge requirements. He is very familiar with the recent developments in these rapidly emerging areas of the law, and with the regulations and proceedings of the U.S. Army Corps of Engineers, the Environmental Protection Agency, the State Water Resources Control Board and the California Regional Water Quality Control Boards. He has advised companies and local governments on a broad range of stormwater, wastewater and wetlands compliance issues.

Marc has a keen understanding of the differences between the federal and state law requirements as well as the areas of overlap and the opportunities and best practices for coordination. Marc also understands the strategic and practical considerations involved in negotiating compliance issues with the federal and state regulators.

Marc is co-author of the chapters covering wetlands and endangered species in Curtin's California Land Use and Planning Law, a leading treatise routinely relied upon by landowners, developers and local governments throughout the state. He speaks regularly on environmental and land use topics, including wetlands and water quality, endangered species, NEPA and CEQA, and water supply requirements for new developments.

EDUCATION • Yale Law School, J.D., 1993, Managing Editor, Yale Journal of Law and the Humanities • Harvard College, A.B., magna cum laude, 1987

BAR ADMISSIONS • California


GEOFF A. SMICK | PRESIDENT | WRA, INC. website

Geoff Smick is the President of WRA, Inc. He received his Bachelor’s degree in Biology, with honors, from the University of Oregon prior to obtaining a Master’s degree in Ecology and Systematic Biology from San Francisco State University. During his graduate studies Geoff worked as a rare plant and wildlife biologist for the National Park Service at Point Reyes National Seashore and held Curatorial Assistant positions with both the Botany and Entomology departments at the California Academy of Sciences in San Francisco.

At WRA Geoff focuses on federal, state and local environmental regulatory compliance and permitting for a variety of clients at the private, commercial and public sector levels. His project management experience includes sensitive habitat inventorying and management, conservation banking, and development, restoration and mitigation projects in a variety of California’s habitat types including coastal, wetland, grassland, riparian, woodland, chaparral, and montane communities.

EDUCATION • MA Ecology and Systematic Biology, San Francisco State University, 2004 • BS Biology, with Honors, University of Oregon, 1998


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