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Full-Text Articles in Law
Generally Illegal: Npdes General Permits Under The Clean Water Act, Jeffrey M. Gaba
Generally Illegal: Npdes General Permits Under The Clean Water Act, Jeffrey M. Gaba
Faculty Journal Articles and Book Chapters
Under the Clean Water Act, it is unlawful for a point source to discharge pollutants without a National Pollutant Discharge Elimination System (“NPDES”) permit. Most NPDES permits are issued to individual facilities, but since 1979, EPA and States have had a process of issuing “General Permits” to satisfy the requirements of the Clean Water Act. These General Permits may contain enforceable effluent limitations and other requirements, but, unlike individual permit, they may apply to large numbers of sources discharging into many different bodies of water. The conditions of a General Permit are developed through a “notice and comment” process similar …