CONGRESSIONAL ' S LC, :4 nae/2: :3 ~—— 7 703 (0 .-.- wt: 1: .. .«. .4-"'7 ‘,5 ? 3' V: 5 :' .7; “::'A{? "$5, z~;”Vz§§ 1;,/xé. .5’ x’ » K ’~ «-5 ‘~: 9 *2; 12- ' -5 ?’e. is ’ l '\'..'. ,-H " 54 -— S‘ ' x: 1 ~—~""*" * ' . . W. 1. .. W ‘ -y . A u. h ‘E L’ C ‘ - .' " V ";.—,l:Jjil ‘xi NOV 17 1989 Issue Brief J U‘ [Lush-'5i-”‘ I __ _... _‘ '31’. ‘I -2 In ,4. - l- '“ " ‘ ““’ Wu: 4,“... ‘.$ vs 411' EX‘ ‘:3’. /(}"'l S E O ‘».:;.:;."'\L.J“~-‘LUH39 5” ‘ ’ .5 «‘..'.'.4 i”Ieil“'itTl|l‘ifl)r“j"jil:l"'l'i flllfiifllfliiiallllllll 010- RESEARCH SERVICE 86113 LIBRARY OF CONGRESS '§ .0 I \ 433$‘ " . .2 9.3“ .-.0 WATER POLLUTION CONTROL: DISPOSAL OF DREDGE AND FILL ISSUE BRIEF NUMBER IB77026 AUTHOR: Copeland, Claudia Environmental and Natural Resources POliCY Division THE LIBRARY OF CONGRESS CONGRESSIONAL RESEARCH SERVICE MAJOR ISSUES SYSTEM DATE ORIGINATED 03/23/77 DATE UPDATED 05/27/82 FOR ADDITIONAL INFORMATION CALL 287-5700 0528 CRS- 1 IB77026 UPDATE-05/27/82 0.) ‘ISSUE DEFINITION The major Federal program affecting disposal of dredge and fill materials is authorized in the Clean Water Act. Congress established the current program in l972 (P.L. 92-500) and made certain refinements in 1977 (P.L. 95-217). Elements of the basic Act are due for reauthorization in 1982, and the 97th Congress may take that opportunity to examine the dredge and fill program contained in the law. - The 1972 Federal water Pollution Control Act (P.L. 92-500) called for eliminating discharges of pollutants into navigable waters by 1985 and for restoring the chemical, physical, and biological integrity of the Nation's waters. To achieve this objective, the Act established a strict regulatory program to control discharges of pollutants into the "navigable waters" of the United states. Discharges of dredged and fill materials into these waters are prohibited under section 404 of the Act unless a permit is issued by the U.S. Army corps of Engineers, which is the administering agency for this provision. Discharges of all other pollutants into navigable waters are allowed only under a permit issued by the Environmental Protection Agency (EPA)(section 402 of the Act). The EPA does have certain responsibilities under section 404 for oversight and issuance of guidelines. Amendments enacted in 1977 (P.L. 95-217) continued the broad Federal jurisdiction over U.s. waters and wetlands contained in the 1972 Act, as expanded by a 1975 court decision, but provided a mechanism for establishing \ State permit programs for_ controlling the disposal of dredge and fill ) materials into many water and wetland areas. Section 404 was amended to provide specific exemptions from permit requirements for certain activities and to provide for the use of general permits. Recent congressional concern has focused on implementation of the section 404 program and whether the 1977 legislative efforts to simplify the program and reduce Federal involvement are succeeding. Regulations‘ implementing changes authorized by those Amendments were slow in being proposed or promulgated. Nevertheless, current interest in further revisions to the program arises from at least two types of concerns: complaints about lengthy time delays in permit issuance and general desire to reduce what some persons believe to be unnecessary and burdensome Federal regulations. At the‘ same time, the Administration has been examining the section 404 program for nearly a year, and in May the White House directed the Corps of Engineers to make certain administrative changes intended to reduce the time it takes to get a decision on a permit application. BACKGROUND AND POLICY ANALYSIS Since 1899, the U.S. Army Corps of Engineers has had jurisdiction over navigable waters of the United states. Under the Rivers and Harbors Act of 1899 (33 U.S.C. 401), permits were required by the Corps for erecting bridges, dams, dikes, and causeways under section 9, and for constructing wharves and piers, as well as dredging and filling, under section 10 of the ) Act. Section 13, commonly referred to as the Refuse Act, required permits for dumping of any refuse matter -- except municipal wastes from streets and sewers -- into navigable waters. CRS- 2 IB77026 UPDATE-05/27/82 The definition of "navigable waters" under the 1899 Rivers and Harbors Act, which has been a subject of considerable controversy and litigation over the years, covered those waters that are, in the past were, or in the future could likely be used for commercial water transportation. For purposes of pollution control the Refuse Act was largely ignored, however, until it was "rediscovered" in 1970. A pollution control permit program was created, but soon bogged down in litigation. 1975 Court Decision On Mar. 27, 1975, Judge A. Robinson of the D.C. District Court [NRDC v. Callaway, 392 F. Supp. 685 (D.D.C., 1975)], ruling in favor of Natural Resources Defense Council and National Wildlife Federation, declared: Congress by defining the term "navigable waters" in Section 502(7) of the Federal Water Pollution Control Act Amendments of 1972, 86 Stat. 816, 33 U.S.C. section 1251, et seq. (the "Water Act") to mean "the waters of the United States, including the territorial seas," asserted Federal jurisdiction over the nation's waters to the maximum extent permissible under the Commerce Clause of the Constitution. (Accordingly, as used in the Water Act, the term is not limited to the traditional tests of navigability. As a result Of this decision, the COFPS was required t0 promulgate new regulations under section 404, taking into consideration the broader definition of navigable waters. Implementation by the Corps On May 6, 1975, the Corps published proposed regulations providing four alternatives to the definition of "navigable waters" and describing the requirements of the permit program regulating the discharges of dredged and fill materials into these waters (Federal Register, v. 40, no. 88, May 6, 1975). After receiving over 4,500 comments on the proposed regulations, the Corps promulgated interim final regulations on July 25, 1975 (30 CFR 209, Federal Register, v. 40, no. 144, July 25, 1975). The new regulations, WhiCh differed considerably from the proposed (regulations, established a three-phase implementation schedule for the Corps’ expanded jurisdiction over the dredge and fill permit program. Phase I, which went into effect in July 1975, required permits for discharges of dredged and fill materials into traditional navigable waters and their adjacent wetlands. Phase II, which took effect in September 1976 (after a 60-day suspension to allow congressional oversight), expanded jurisdiction to include primary tributaries of traditionally navigable waters, natural lakes greater than five acres in surface area, and their adjacent wetlands. Finally, Phase III, which became effective on July 1, 1977, extended coverage to all other waters falling under the expanded definition of navigable waters. These regulations under section 404 of the FWPCA elicited numerous adverse comments, particularly from foresters, ranchers, and developers. Critict_ have contended that: (1) the Corps has expanded its jurisdiction beyond the intent of 404, even CRS- 3 IB77026 UPDATE-O5/27/82 as interpreted by the courts; ) (2) the 404 program, as interpreted by the Corps, is being used for f'Federal land use control; (3) the 404 program duplicates coverage by other provisions of Federal statutes, particularly the Coastal Zone Management Act and section 208 of the FWPCA (areawide waste treatment management planning) and State laws; (4) the 404 regulations "bear little relationship" to the intent of the FWPCA by requiring the Corps to consider water quality objectives in carrying out its own maintenance programs in the navigable waters; (5) the Corps has "grossly underestimated" the number of permits required, and the Agency's regulations provide for a "very complex, costly, and time-consuming permit procedure"; (6) needless duplication and unnecessary delays are threatened at all levels of government; and (7) the program places an agency (Corps) with "no relevant experience" in Charge Of regulating the forest, agriculture, and road construction and building industries. ,$roponents of the expanded program, including the Environmental Protection Agency and most environmental groups, make the following points: (1) the 404 program can stop adverse wetland development; ,) . (2) the broad geographical jurisdiction should reduce the confusion and expense inherent in earlier approaches that established arbitrary boundaries; (3) hundreds of activities have beenn identified that do not require permits -- excluded are normal farming, silvicultural, and ranching activities such as plowing, cultivating, seeding, and harvesting; (4) general permits will be used for those categories of discharges that cause only minimal harm to water quality; 3 (5) phased implementation of the program provides for "moderation" and "flexibility"; 4 (6) States are directly involved in decision—making processes; (7) section 404(b) guidelines provide an effective means for’ screening permit applications to eliminate unnecessary chemical and biological analyses of dredged and fill materials. The corps of Engineers promulgated final regulations on July 19, 1977 (30 CPR 3203329, Federal Register, v. 42, no. 138). These final regulations clarify the types of "normal" farming, silvicultural, and ranching activities that are exempt from the permit program: plowing, seeding, cultivating, and V) harvesting for the production Of fOOd, fiber, and forest products. The final regulations also provide for nationwide and general permits, the purpose Of WhiCh is t0 eliminate administrative delay by not requiring individual permits for certain categories Of discharges that cause minimal environmental CRS- 4 IB77026 UPDATE-O5/27/82 harm. Nationwide permits are issued by the headquarters office, while general permits are issued by district offices of the Corps of; Engineers. Safeguards are included in the regulations to ensure that the nationwide permit system does not adversely affect water quality. A number of major policy questions emerged as a result of the litigation and the Corps‘ implementation of section 404. (1) To what extent should the Federal Government control activities affecting the Nation's navigable waters and adjacent wetlands? (2) Should regulation of the permit program governing the‘ discharges of dredged and fill materials remain with the Corps of Engineers, or should this responsibility be transferred to another agency, such as EPA? (3) Should Congress allow delegation of permit-granting authorities to States for dredge and fill discharges (as EPA can now delegate the authority for granting permits under section 402)? (4) To what extent should exemptions or variances be used in the dredge and fill permit program? (5) How can a permit program be structured to accommodate concerns for both sides, i.e., protecting wetlands and at the same time minimizing bureaucratic delays, complex procedures, and increased costs? Legislation in the 94th Congress After the NRDC v. Callaway decision forced the Corps to expand its jurisdiction over the regulation of dredge and fill discharges into navigable waters, a number of legislative proposals were introduced in the 94th Congress to return the Agency's jurisdiction to the more limited, traditionally defined navigable waters. Among the legislative options debated were proposals to require the Corps to issue permits for discharges of dredge and fill materials into traditionally navigable waters, while allowing the governor of a State and the Corps jointly or, alternatively, EPA 1220 issue permits fOI' discharges into all other waters. HOWEVGI‘, I10‘ amendments to the FWPCA were enacted during that Congress, and the section 404 issues were raised again in the 95th Congress. The 1977 Amendments- In the 95th Congress, amendments to the dredge and fill regulatory program were contained in the Clean Water Act (P.L. 95-217). The section 404 amendments ratified much of the regulatory program then being carried out by the Corps under the July 1977 rules. The l977 Act amends section 404 of the 1972 Act to provide a mechanism for establishing State permit programs for controlling disposal of dredged and fill material into Phase II and III waters. Specific exemptions from any permit requirements were provided for certain activities such as: normal farming, silvicultural, and ranching activities; certain construction and maintenance activities; Federal activities for which an environmental impact statement has been provided; and those activities already regulated by the States under other provisions of— the Act. P.L. 95-217 also provides for the use of general permits as a mechanism for eliminating the administrative burdens and delays associated with the program. CRS- 5 IB77026 UPDATE-O5/27/82 Under the 1977 Amendments the Corps retains regulatory jurisdiction over ;Phase I waters, while States may implement a permit program for discharge of dredged and fill material in Phase II and III waters, if approved by EPA. States having approved programs also may issue general permits. ISSUES Implementation of section 404 is now being examined in light of the 1977 Amendments to the Act. Many of the policy questions raised in the early years of the program concerning application of Federal controls and the need to balance environmental concerns with economic activities recur today. There has been criticism that activities having minor environmental impact are overly regulated by the Act and by the Corps‘ implementation. To some extent, these concerns were addressed in the 1977 Amendments, which authorized generic permits and specifically exempted certain categories of activities from permit requirements. some persons continue to be concerned, however, that the scope of section 404 permitting and the Act's definition of "navigable waters" are too broad. In particular, this relates to the extent to which wetland areas adjacent to navigable waters are to be regulated. Administration of the section 404 program is under some scrutiny. There is concern among some industrial developers and port authority operators that the process of obtaining dredge and fill permits is cumbersome and unnecessarily time—consuming. Yet, under the Clean Water Act and other statutes, a number of Federal and State agencies, including EPA, the Fish and Wildlife Service, and the National Marine Fisheries Service, are authorized to review and comment on permit applications. The Corps estimates that 85-90 days are routinely required to process such an application, with less than 1% of all requests exceeding the average time, because they are associated with large and complex project proposals, and also may involve public controversy. No State dredge and fill permit programs are operating. EPA regulations that would effect transfer of that authority to approved States were issued May 19, 1980, and are contained in Consolidated Permit Regulations (45 FR 33290) (The consolidated permit program would also include the National Pollutant Discharge Elimination System under the Clean Water Act, as well as programs under the Resource Conservation and Recovery Act,» Safe Drinking Water Act, and Clean Air Act.) Critics have suggested that most States will not seek permitting authority, due to complexity of the rules, lack of manpower and resources to manage a State program, and continuation of some Federal control. Currently these rules are undergoing review by the Administration's regulatory review task force. The failure of States so far to seek delegation of the section 404 program troubles some advocates of New Federalism and of general efforts by the Administration and others to transfer responsibilities from the Federal level to State and local governments. Although the section 404 program is administered by the Corps of Engineers, the EPA has limited but significant involvement. EPA issues qguidelines under section 404(b) for use by the Corps in reviewing permit requests. These guidelines, which have been in effect as interim final rules for four years, have been revised recently by EPA and were reissued Dec. 24, "1980 (45 F.R. 85336). Under the Act, the Corps may override these guidelines CRS- 6 1377025 UPDATE-O5/27/82 if navigation or anchorage requires. EPA has authority under section 404(c) to prohibit or restrict discharges of dredged or fill material if the — activity might have an adverse environmental effect. Rules finalizing the section 404(c) procedures were issued in October 1979, and EPA has never used the veto authority. In September l979 the U.S. Attorney General stated in an advisory opinion that EPA, not the corps of Engineers, has the final administrative authority to determine what constitutes "navigable waters" under section 404. The reasoning for the ruling was said to rely on the "structure of the Act as a whole," rather than explicit support either in the statute or legislative history. In May l980 the House Public Works and Transportation Committee reported a bill, H.R. 85, containing a provision to clarify that the authority to determine "navigable waters" rests with the Secretary of the Army, because the Corps issues section 404 dredge and fill permits. This provision was retained when the House passed the bill Sept. 19, 1980; however, the 96th Congress did not enact H.R. 85. The Senate Committee on Environment and Public Works held oversight hearings on the implementation of section 404 and activities of the Corps of Engineers affecting wetland areas on June 23 and July 1, 1980. The section 404 program has been undergoing scrutiny by the Administration since August 1981 through the Administration's Regulatory Relief Task Force, pursuant to Executive Order l229l, with a View toward suggesting possible administrative and legislative changes. The Corps of Engineers has been the lead agency on this review, submitting comments and recommendations on the program early in 1982. So far, the Administration has not rapproved making legislative recommendations regarding section 404, but in May the White House directed the Corps of Engineers,_EPA, and other Federal agencies to make a number of administrative changes to the program by revising key regulations. This directive came after a lengthy interagency review process that included the Office of Management and Budget and the Cabinet Council on Natural Resources and the Environment. The following regulatory changes have been ordered: '-- Restricting higher level review of permit decisions by the Corps to cases specifically requested by the , EPA administrator or deputy administrator, the assistant secretary of the Interior for fish and wildlife and parks, or the administrator of the National Oceanic and Atmospheric Administration in order to limit elevation of cases to those of national importance or insufficient interagency coordination. -- Revising rules to aim for a 90-day deadline for decisions on permit applications. ‘ "' Requiring EPA t0 revise itS regulations t0 provide increased incentives and simplified procedures fOI' State assumption Of the program. -— Requiring the Corps to clarify the scope of the permit program so that it does not encompass all biological wetlands, however defined or regardless of their connection to waters. The details of such clarification will be developed by the Corps. A number of environmental groups and some officials of other Federal» agencies involved with the section 404 program reportedly have objected to changes intended to shorten the review process, particularly on the grounds that such a change could result in insufficient opportunity to determine the CRS- 7 IB77026 UPDATE-05/27/82 environmental impact of a dredge or fill project. A LEGISLATION H.R. 393 (Paul) Amends the Federal Water Pollution Control Act to restrict the jurisdiction of the United States over discharge of dredgeior fill material to discharges into waters which are navigable. Introduced Jan. 5, 1981; referred to Committee on Public Works and Transportation. H.R. 3083 (Hall, S.) Amends the Federal water Pollution Control Act to restrict the jurisdiction of the United States over the discharge of dredged or fill material to those discharges which are into navigable waters, and has other purposes. Introduced Apr. 7, 1981; referred to Committee on Public Works and Transportation. 1 H.R. 3962 (Hightower et al.) Amends the Federal Water Pollution Control Act to restrict the jurisdiction of the United States over the discharge of dredged or fill material to those discharges which are into navigable waters, and for other purposes. Introduced June 18, 1981; referred to committee on Merchant Marine; and Fisheries, and Committee on Public works and Transportation. H.R. 5766 (Hansen, J.) Amends the Federal water Pollution Control Act to I restrict U.s. jurisdiction over discharge of dredge or fill materials into navigable waters. , Introduced Mar. 9, 1982; referred to Committee on Public Works and Transportation. S. 777 (Tower et al.) Amends the Federal Water Pollution Control Act to ‘ restrict the jurisdiction of the United States over the discharge of dredged or fill material to those discharges which are into navigable waters, and for other purposes. Introduced Mar. 24, 1981; referred to Committee on Environment and Public Works. HEARINGS U.s. Congress. House. Committee on Public works and Transportation. Subcommittee on Water Resources. Hearings on H.R. 3199, amendments to the Federal Water Pollution Control Act. Hearings, 95th Congress, lst session. Mar. 1, 2, 3, and 4, 1977. Washington, U.S. Govt. Print. off., 1977. U.S. Congress. House. Committee on Public Works and Transportation. Subcommittee on Water Resources. Development of new regulations by the Corps of Engineers. Implementing section 404 of the Federal Water Pollution Control Act concerning REPORTS U.S. CRS- 8 IB77026 UPDATE-O5/27/82 Hearings, 1975. permits for disposal of dredge or fill material. 94th Congress, lst session. July 15, 16, and 22, Washington, U.S. Govt. Print. Off., 1975. 292 p. Committee on Science and Technology. Subcommittee on Natural Resources and Environment. Long Sound dredge-spoil dumping. Hearing, 96th Congress, lst session. Oct. 13, 1979. Washington, U.S. Govt. Print. 1980. l80'p. "No. 97"/ Congress. HOUSE. Island Off., Congress. Senate. Committee on Public Works. Section 404 of the Federal Water Pollution Control Act Amendments of 1972. Hearings, 94th Congress, 2d session. July 27 and 28, 1976. Washington, U.S. Govt. Print. Off., 1976. 794 p. Congress. Senate.. Committee on Public Works. Subcommittee on Air and Water Pollution. Water pollution control legislation: refuse act permit program (part 9). Hearings, 92d Congress, lst session. June 22 and 23, 1971. Washington, U.S. Govt. Print. Off., 1971: 4291-4415. Committee on Public Works. Subcommittee on Implementation of certain sections Hearings, 96th Congress, 2d session. 1980. Washington, U.S. Govt. Print. congress. Senate. Environmental Pollution. of the Clean Water Act. June 23, 24, and July 1, Off., 1980. 376.p. "Serial no. 96-H55" AND CONGRESSIONAL DOCUMENTS Committee OH Environment and Public WOFKS. as amended through December 1981. Washington, 1982. 132 p. . Congress. Senate. The Clean Water Act, U.S. Govt. Print. 0ff., "Serial no. 97-8“ A legislative history of the Clean Water Act of 1977, a continuation of the legislative history of the Federal Water Pollution Control Act, together with a section-by-section index. v. 3 and 4. Washington, U.S. Govt. Print. Off., 1978, 1505 p. At head of title: 95th Congress, 2d session. Committee print. "Serial no. 95-14" CHRONOLOGY OF EVENTS 10/09/79 -- EPA issued final rules implementing section 404(c) of Act. . 09/18/79 -- EPA proposed revised Guidelines regarding discharge of dredged or fill material into waters of the U.S. 06/14/79 -- EPA proposed procedures for transfer of dredge and fill permit authority to eligible States as part of CRS- 9 IB77026 UPDATE-05/27/82 Consolidated Permit Regulations proposal. ) 12/27/77 -- Clean Water Act enacted (P.L. 95-217). Section 57 « contains major amendments to section 404 of the FWPCA. 07/19/77 -— Corps published final regulations for the 404 ’ program. 07/01/77 -- Phase III of the "404" program became effective. 09/00/76 -- Phase II of the "404" program became effective ' following a 60-day moratorium by former President Ford. ’ ' ‘ 07/00/76 -- Senate Public Works Committee conducted hearings on the implementation of the 404 program. 06/00/76 -- Former President Ford announced a 60+day moratorium yon implementation of Phase II, pending a congressional oversight. 07/25/75 -- Corps promulgated interim final regulations under 404, ; thus implementing Phase I of its expanded jurisdiction "over navigable waters. ‘ 94- House Public Works Committee conducted hearings ” jregarding the development of 404 regulations. 05/06/75 -- Corps published proposed regulations for the 404 ~ 4 ~program, containing four alternatives for regulation of dredge and fill. 03/00/75 -- D.c. Federal District Court judge ordered the corps" to expand its jurisdiction of navigable waters. 08/00/74 -— The Natural Resources Defense Council and the National 4 Wildlife Federation filed suit against the Corps of Engineers regarding its definition of navigable waters under its 404 program. 04/00/74 —- Corps published regulations under Section 404 Ef the FWPCA permitting discharges of dredged and fill materials into navigable waters. lo/00/72 -- Congress enacted the Federal Water Pollution Control Act Amendments of 1972; including a provision under section 404 regulating the discharges of dredged and fill material into navigable waters. ADDITIONAL REFERENCE SOURCES Blumm, Michael C. The Clean Water Act's section 404 permit . enters its adolescence: an institutional and programmatic w) perspective. Ecology law quarterly, v. 8, 1980: 409-472. . LRS80-2926 Corps‘ wetlands control survives trip though a legislative — — %——-:——.v—,—— ERS-1o'l 1377025 UPDATE-O5/27/82 swamp. National jbfi;fiai,;y; g, Oct. 23, 1976: ;1506-1512. Dredged material disposal: Keffects and alternatives. Water spectrum, v. 6, no. 3, 1974: 26-33. LRS74-21549 Every pond and puddle -- or, how far can the Army Corps stretch the intent of Congress? Natural resources lawyer, v. 9, no. 3, 1976: 467-475. Federal control over wetland areas: the Corps of Engineers expands its jurisdiction. University of Florida law review, v. 28, spring 1976: 787-800. LRS76-18254 FWPCA interpreted to subject dredging operations of Corps of Engineers to state permit programs. Minnesota law review, v. 60, February 1976: 610-619. - LRS76-8783 Jurisdictional expansion of the Army Corps of Engineers under the Federal water Pollution Control Act Amendments of 1972. Houston law review, v. 13, October 1975: 135-152. LRS75-23240 Mosher, Lawrence. when is a prairie pothole a wetland? when the Federal regulators get busy. National journal, v. 14, Mar. 6, 1982: 410-414. LRS82-1354 Sections 9 and,l0 of the Rivers and Harbors Act of 1899: potent tools for environmental protection. Ecology law quarterly, v. 6, no- 1, 1976: 109-159. LRS76-19373 The Clean water Act of 1977. Natural Resources Lawyer, v. 11, no. 2, 1978: 343-372. A LRS78-21780 The wetlands: how well are they protected? conservation foundation letter, September 1974: 1-8. ’ LRS74-21955 Wetlands? reluctant champion: the Corps takes a fresh look at "navigable waters." Environmental law, v. 6, fall 1975: 217-241. ’ LRS75-21290 U.S. General Accounting Office. Managerial changes needed to speed up processing permits for dredging projects. June 9, 1980. Washington, U.S. Govt. Print. Off., 1980. 65 p. (can-so-71) ' 1 LRS80-7221 IJBRAWPY OF WASHINGTON uwnvsnsmr ST- LOWS - M0. 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