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EPA Drafts New Guidance on County of Maui’s “Functional Equivalent” Test

On November 20, 2023, the U.S. Environmental Protection Agency (EPA) issued Draft Guidance, again attempting to interpret the Supreme Court decision in County of Maui v. Hawaii Wildlife Fund and describe in practical terms...more

Is The WOTUS Carousel Finally Stopping Post-Sackett?

On July 12, 2023, Shortly after the Supreme Court’s ruling in Sackett v. Environmental Protection Agency, EPA and the Department of the Army issued a letter advising the ranking member of the Senate’s Committee on Environment...more

Less Room to Swim in the “Waters of the United States"

“On three prior occasions, this Court has tried to clarify the meaning of ‘the waters of the United States.’ But the problem persists. When we last addressed the question 17 years ago, we were unable to agree on an opinion of...more

New Year, New WOTUS Rule

EPA and the US Army Corps of Engineers announced on Friday, December 30, 2022, the final, pre-publication version of a “Revised Definition of ‘Waters of the United States’ [“WOTUS”]” rule. This 2022 WOTUS Rule will become...more

WOTUS Whack-a-Mole: What Definition Applies This Week?

You can be forgiven if you aren’t sure how jurisdictional waters are currently defined in the United States. Since 2015, the definition of Waters of the United States, or WOTUS, has changed more often than a college freshman...more

Supreme Court Rules Clean Water Act Protections Can Extend to Groundwater; Creates Conflict with New 2020 WOTUS Rule

On April 23, 2020, the United States Supreme Court ruled that the addition of pollutants to groundwater which travels a half mile to enter navigable waters is the functional equivalent of a direct discharge, and subject to...more

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