UMRBA Update
January 30, 2001
Washington Update
- Regulatory Moratorium---In one of the Bush
Administration's first acts, Chief of Staff Andrew Card issued a
"regulatory review plan" on the afternoon of the inaugural,
January 20. Card's memo directs all heads and acting heads
of executive departments and agencies to take the following steps:
1) except for emergencies, no new proposed or final rules are to be
submitted to the Office of the Federal Register (OFR) until a Bush
appointee has approved the action; 2) regulations submitted to OFR, but
not yet published, are to be withdrawn and reviewed by Bush appointees; 3)
implementation of regulations that have been published in the Federal
Register, but that have not yet taken effect, is to be postponed for
60 days. The memo does not apply to regulations promulgated pursuant
to statutory or judicial deadlines and agency heads may apply to the OMB
for other exemptions. While independent agencies are not subject to
the directive, Card's memo urges their voluntary compliance "in the
interest of sound regulatory practice and the avoidance of costly, burdensome,
or unnecessary regulation." According to various reports,
executive agencies are scrambling to determine which of the Clinton
Administration's many final actions are subject to the hold.
Republican members of Congress generally welcomed Bush's directive, and
several have also expressed interest in using the 1996 Congressional
Review Act (CRA) to disapprove some of the new rules. Under the CRA,
a majority of the House and Senate can vote to reject executive branch
regulations, subject to certain timing limitations.
- Wetland Regulation---The Corps of Engineers and
Environmental Protection Agency wasted no time in issuing guidance in the
wake of the Supreme Court's recent landmark wetlands decision. On
January 9, the Supreme Court rendered its decision in Solid Waste
Agency of Northern Cook County v. U.S. Army Corps of Engineers (SWANCC
decision). (See the January 9 UMRBA Update for a summary of
the decision.) On January 19, the Corps and EPA issued a joint
interpretation of SWANCC, providing guidance on "what is and is not
affected by this ruling." Interpreting the Court's ruling
fairly narrowly, the guidance indicates that Clean Water Act jurisdiction
cannot be extended to nonnavigable, isolated, intrastate wetlands
solely on the basis of use by migratory birds. However, the
Corps and EPA attorneys leave open the possibility that there may be other
legitimate grounds for extending jurisdiction to such
wetlands. The guidance also concludes that EPA and the
Corps retain the authority "to assert CWA jurisdiction over ...
all of the traditional navigable waters, all interstate waters, and all
tributaries to navigable or interstate waters, upstream to the highest
reaches of the tributary systems, and over all wetlands adjacent
to any and all of those waters."
Wisconsin DNR
Secretary George Meyer warned that the impacts of the SWANCC decision could be
dramatic, even under the Corps and EPA's reading. According to Meyer,
"we're cautiously optimistic that this initial interpretation of the
court's decision will hold. While it narrows the breadth of the decision,
it appears that millions of Wisconsin wetland acres are still at risk. We
will know the precise acreage only after Corps biologists apply their new
guidance." Preliminary estimates from Wisconsin DNR indicate that 70
to 80 percent of the state's remaining 5.3 million acres of wetlands may no
longer be protected under Section 404 of the CWA. This includes
"some of the state's most sensitive wetlands: calcareous fens,
ephemeral wetlands among them." The lack of federal jurisdiction is
especially significant because Wisconsin's state wetlands protections,
like those of many other states, are integrally linked with federal
law. Under current state law, according to Franc Fennessy of
Wisconsin DNR, "if the Corps has no jurisdiction, then we have no
jurisdiction." Wisconsin DNR's web site notes that the agency is
"urging state lawmakers and Congress to look at this issue and work with
DNR to act to protect these wetlands." On February 1, the Wisconsin Senate
Environmental Resources Committee is scheduled to hear a bill designed to
address potential gaps in wetlands protection stemming from the SWANCC
decision. Information related to the Supreme Court decision is available
on the EPA and Wisconsin DNR web sites.
Also on the
wetlands front, the January 17 Federal Register includes a final rule
from the Corps and EPA revising the definition of discharge of dredged
material. This new rule comes in response to a 1998 federal appeals court
decision striking down the Tulloch Rule, under which "incidental
fallback" during wetlands drainage was equated with wetlands
filling and thus subject to Section 404 regulation. The court invalidated
the Tulloch Rule as overly broad, leaving what some viewed as a loophole
in wetland protection. The Corps and EPA issued their proposed
replacement for the Tulloch Rule back in August. Homebuilders and others
in the regulated community criticized the proposed rule's "rebuttable
presumption" provision, under which a range of activities would have been
presumed to result in more than incidental fallback. Critics charged that
this shifted the burden of proof to the regulated community. According to
EPA and the Corps, the final rule clarifies that no such shift has occurred and
defines "incidental fallback." The agencies maintain that the
new rule protects wetlands and provides predictability for the regulated
community while allowing "for case-by-case evaluations as to whether a
regulable discharge of dredged material results from a particular activity,
thus retaining necessary program flexibility to address the various
fact-specific situations that are presented." The text of the new
rule and related materials are on EPA's web site.
· Barge
Numbering---The
Coast Guard published a proposed rule requiring barge numbering in the January 11 Federal Register. This
rulemaking is pursuant to the 1992 Abandoned Barge Act, which prohibits the abandonment
of barges in U.S. waters and mandates a numbering system for barges greater
than 100 gross tons. Capping a series of delays, the January 11 notice
marks the Coast Guard's effort to implement the numbering requirement.
Under the proposed rule, barge owners would be required to obtain a unique
number from the National Vessel Documentation Center for barges over 100 gross
tons and to permanently mark both the inside and outside of the vessel with
this number. According to the Coast Guard, there are 20,000 undocumented
barges greater than 100 gross tons in U.S. waters, 89 percent of which operate
on the Mississippi River System and the Gulf Intracoastal Waterway. The
numbering system is designed to reduce barge abandonment and to facilitate
tracking owners of abandoned barges. A 1992 General Accounting Office
report estimated that there were 82 pollution incidents associated with
abandoned vessels between 1988 and 1992. While expressing support for the
goal of reducing pollution, American Waterways Operators questions the need for
the new rule, noting that "the problems the [Abandoned Barge] Act was
intended to solve have abated significantly since its passage."
Comments on the proposed rule are due by April 11, 2001.
- Hydropower Licensing---The Interagency Task Force (ITF)
to Improve Hydroelectric Licensing Processes has completed its work.
Led by the Federal Energy Regulatory Commission and comprised of six other
federal agencies, the ITF was formed in 1998 to identify ways
of increasing the efficiency, effectiveness, and timeliness of the
hydro licensing process. In a January 10, 2001 letter, FERC and the
Interior Department outline the ITF's key recommendations concerning the
National Environmental Policy Act process, environmental studies performed
in connection with hydropower licensing, consultation under the Endangered
Species Act, mandatory license conditions provided by fish and wildlife
resource agencies, public notice procedures, guidelines for the
streamlined Alternative Licensing Procedures, and methods for drafting
enforceable and trackable license conditions. According to the
January 10 letter, these recommendations will "make hydropower
licensing decisions more timely and well-supported by reducing redundancy,
improving communications, finding efficiencies, and streamlining the
licensing process, while maintaining the balance between developmental and
non-developmental values mandated by Congress." In a related
effort, the Interior and Commerce Departments have issued joint guidance
governing public notice and comment on the resource agencies' proposed
mandatory license conditions. Information related to the ITF's
activities and recommendations is on FERC's web site. The Interior/Commerce
guidance is on DOI's web site.
- Invasive Species---The National Invasive Species
Council issued the final version of its Management Plan, Meeting the
Invasive Species Challenge, on January 18. The Council,
composed of eight federal agencies, was established by Presidential
Executive Order 13112 in February 1999 and charged, among other things,
with coordinating federal efforts related to invasive species and
preparing the Plan finalized this month. The plan identifies a
variety of actions in nine areas: leadership and coordination, prevention,
early detection and rapid response, control and management, restoration,
international cooperation, research, information management, and education
and public awareness. Among the proposed actions that may be of
particular interest to states is authorization of matching federal funds
for state programs to manage invasive species, including assistance to
states for the development of state invasive species management
plans. Directly related to the challenge faced in the Upper
Mississippi River Basin, is the proposal that, by January 2002, the Corps
of Engineers "prepare a list of connecting waterways to develop
a strategy for preventing movement of aquatic species among watersheds and
initiate a research program on methods to prevent such
movement." The Council's plan is available at the invasive species website that the Council
established in response to the Executive Order directive to develop an
Internet-based information sharing system.
- Aquatic Nuisance Species---On December 28, the Coast Guard
issued voluntary guidelines for recreational activities to control the
spread of aquatic nuisance species (ANS). The guidelines address a
range of water-related recreational activities, including scuba diving,
waterfowl hunting, non-commercial bait harvesting, angling, boating,
operating float planes, and operating personal watercraft. According
to the Coast Guard, the guidelines "give the public clear, concise
information on how to avoid the transport of ANS." Generic
recommendations applying to all activities include always inspecting
equipment and not transporting plants, animals, mud, or water between
waterbodies. Activity-specific recommendations include suggestions
regarding specific types of decoy anchors for waterfowl hunters and
cleaning procedures for boat and personnel watercraft operators. The
voluntary guidelines, which took effect on January 29, are available in
the December 28 Federal Register.
- Estimating Streamflows---USGS has released Streamstats, a
new tool that dramatically reduces the time required to estimate
streamflows for areas that lack gages. According to USGS hydrologist
Kernell Ries, the user selects a site and "automatically the physical
characteristics of the watershed that drains to the site will be measured,
a set of equations will be solved, and the estimated streamflow statistics
and a location map will be provided ... within seconds." The
current tool uses 13 equations to produce its estimates. These focus
primarily on low-flow statistics, but work is underway to incorporate
flood statistics. The pilot Streamstats was completed
for Massachusetts and USGS plans to extend the tool nationwide as
part of the National Streamflow Information Program. The
Massachusetts model and related materials are available on USGS's web site.
- National Wildlife Refuge Policies---On January 16, the U.S. Fish and
Wildlife Service released four new draft policies for inclusion in its
manual that provides official guidance for managing units of the National
Wildlife Refuge System. The new draft "Mission, Goals, and
Purposes" policy articulates the mission of the refuge system,
establishes its goals, and provides guidance for determining the purposes
of individual refuge units within the system. The new
"Appropriate Uses" policy sets forth criteria that refuge
managers are to use for determining when it is appropriate to allow
non-priority uses to occur on refuges. Non-priority uses are those
uses other than the six priority wildlife-dependent recreational uses
defined by law (i.e., hunting, fishing, wildlife observation, photography,
environmental education, and interpretation). The draft
"Wildlife-Dependent Recreational Uses" policy explains how the
Service will provide priority to the six mandated recreational uses.
The revised "Wilderness Stewardship" policy gives
refuge managers uniform direction and procedures for making decisions
regarding the conservation and use of wilderness areas within the refuge
system. Comments on the draft policies are due by March 19, 2001.
In a related move,
on January 16, the Fish and Wildlife Service also issued its final
"Policy on Maintaining the Biological Integrity, Diversity, and
Environmental Health of the National Wildlife Refuge System." The
policy, which was offered for public comment last October, provides guidance
for implementing the clause of the National Wildlife Refuge System Improvement
Act of 1997 directing the Secretary of the Interior to "ensure that the
biological integrity, diversity, and environmental health of the System are
maintained." In particular, the policy provides guidelines for a)
determining what conditions constitute biological integrity, diversity, and
environmental health; b) preventing degradation of environmental conditions,
and when appropriate, restoring lost or degraded components; and c) dealing
with external threats to the environmental health of refuges. The final policy is effective February 15,
2001.
- National Wildlife Refuge Law Enforcement---According to a recent assessment
conducted by the International Association of the Chiefs of Police,
national wildlife refuge system leaders "should enhance the quantity
and quality of law enforcement." The report, Protecting the
National Wildlife Refuge System: Law Enforcement Requirements for the 21st
Century, was prepared at the request of Fish and Wildlife Service
Director Jamie Clark and the Department of the Interior's Office of the Inspector
General. It calls for stronger centralized leadership of the
program; more full-time refuge officers; and improvements to operations,
training, and recruitment in order to meet the challenges associated with
increasing visitation and encroaching urbanization. The report is
available on the Fish and Wildlife Service web site.
- Boating Infrastructure Grants---In the January 18 Federal Register,
the Fish and Wildlife Service published guidelines for the Boating Infrastructure Grant
Program. What is commonly known as the BIG program uses excise
taxes paid by boaters and anglers under the Sport Fish Restoration Program
to provide matching grant funds to states to install tie-up facilities for
transient recreational boats 26 feet or more in length. In
publishing the guidance, the Service is making $32 million available for
distribution through 2003.
- State Wildlife Grants---In the January 24 Federal
Register, the Fish and Wildlife Service published a description of
the process that states must use to apply for grant funds under the new
Wildlife Conservation and Restoration Program and the new State Wildlife
Grants Program, both of which were authorized at $50 million in FY
2001. The Wildlife Conservation and Restoration program will use a
formula-based apportionment, similar to that used for existing Pittman
Robertson Act funds. The formula, based on land area and population,
allocates the following amounts to UMR states in FY 2001: Illinois
($1,651,820), Iowa ($610,179), Minnesota ($973,316), Missouri ($971,961),
and Wisconsin ($876,862). In contrast, the State Wildlife Grants
Program is a cost-shared, competitively awarded, project-based
program. State program and plan descriptions are due by March 1,
2001. Additional information is provided in the Federal Register notice.
- Migratory Birds---On January 11, President Clinton issued an
Executive Order requiring federal agencies to avoid or minimize the
negative impact of their actions on migratory birds and to take active
steps to protect birds and their habitat. In particular,
within two years, each federal agency taking actions that are having
or will likely have a measurable negative impact on migratory bird
populations must develop and implement an MOU with the Fish and Wildlife
Service for the conservation of migratory bird populations. Agencies
are also directed to ensure that their NEPA assessments evaluate the
effects of agency actions and plans on migratory birds and to design
migratory bird conservation measures into their plans and planning
processes. Fish and Wildlife Service Director Jamie Clark applauded
the Executive Order saying "birds are
important, not only as a measure of the overall health of our environment,
but also to our quality of life and our economy. Protecting them
just makes sense."
New Bills
- H.R. 109 "Municipal Biological Monitoring Use
Act"---Amends the Federal Water Pollution
Control Act to provide for the use of biological monitoring and whole
effluent toxicity tests in connection with publicly owned treatment works,
municipal separate storm sewer systems, and municipal combined sewer
overflows. Introduced January 3 by Joel Hefley (R-CO).
- H.R. 144 "Pipeline Safety Act"---Provides for state oversight of
interstate pipelines, requires risk analysis and integrity management
programs for pipeline facilities, includes provisions related to
enforcement and community-right-to-know, requires pipeline facility
operators to have qualification programs for personnel, directs DOT to
develop a strategic plan to reduce pipeline releases caused by outside
force damage, and creates a pilot program of pipeline oversight by
Regional Advisory Councils. Authorizes appropriations for three
years to fund federal pipeline safety activities and state
grants. Introduced January 3 by James Oberstar (D-MN) and eleven
others. Substantially similar to legislation offered
last year by Oberstar, who criticized Senate-approved legislation
from last session as being too weak.
- H.R. 181 "Truth in Water Transportation Budgeting
Act"---Provides
for off-budget treatment for the Inland Waterways Trust Fund and the
Harbor Maintenance Trust Fund. Provides safeguards against deficit
spending out of the two trust funds. Introduced January 3 by Bud
Shuster (R-PA), James Oberstar (D-MN), and Don Young (R-AK).
- S. 71 "Hydroelectric Licensing Process
Improvement Act"---Amends the Federal Power Act by
setting forth a process for federal agencies to use in considering
conditions to hydropower licenses. In particular, consulting
agencies would be required to consider the impacts of the condition on
economic and power values; electric generation capacity and system
reliability; air quality; and drinking, flood control, irrigation,
navigation, and recreation water supply. Each condition would be
subjected to "appropriately substantiated scientific review" and
review by an administrative law judge to determine the
"reasonableness" of the condition. In addition, the bill
would impose time limitations on consulting agencies' submittal of final
conditions. The Federal Energy Regulatory Commission (FERC) would be
required to conduct an economic analysis of each condition submitted by a
consulting agency and to conduct a single consolidated environmental
review for each licensed project. Finally, the bill would require
FERC to conduct a study of the feasibility of establishing a separate
licensing procedure for small hydroelectric projects. Introduced
January 22 by Larry Craig (R-ID) who sponsored an identical bill last
session.
In his
introductory comments, Craig characterized the current hydropower
licensing process as "extremely costly, time consuming, and, at times,
arbitrary," adding "indeed, the current Commission licensing program
is burdened with mixed mandates and redundant bureaucracy and prone to gridlock
and litigation.... My bill will help remedy the inefficient and complex Commission
licensing process by ensuring that federal agencies involved in the process act
in a timely and accountable manner."
- S. 141 "Pipeline Safety Improvement Act"---Identical
to legislation that passed the Senate, but died in the House, last
session. Requires pipeline operators to develop plans to improve the
qualifications for pipeline personnel. Requires DOT to issue
regulations mandating pipeline operators to periodically determine the
safety of their pipelines and implement integrity management programs to
reduce identified risks. Requires pipeline operators to carry out a
continuing public education program and communicate with state and local
emergency response officials. Directs DOT to develop a comprehensive
plan for collecting and using pipeline data. Operators would be
required to report incident releases greater that five gallons.
Includes provisions related to research on technologies to improve
pipeline safety and authorizes appropriations over three years for both
federal activities and state grants. Introduced January 22 by John
McCain (R-AZ) and six others.
- S. 159 "Department of Environmental Protection
Affairs Act"---Elevates
the Environmental Protection Agency (EPA) to a cabinet level department
and redesignates the EPA as the Department of Environmental Protection
Affairs. Introduced January 23 by Barbara Boxer (D-CA).
River Basin News
- Hypoxia Action Plan---On January 18, EPA, on behalf of
the Mississippi River/Gulf of Mexico Watershed Nutrient Task Force,
transmitted the final Action Plan for addressing Gulf hypoxia to
Congress. "This landmark agreement will help protect
the Gulf of Mexico," said Chuck Fox, EPA Assistant Administrator for
Water. "We are especially pleased that all nine states along
the Mississippi River have committed to work with the federal government
to resolve a national water quality problem." The Action Plan
establishes a goal of reducing the size of the Gulf "dead
zone" by roughly half by 2015. A series of specific
actions is proposed, including the establishment of sub-basin
committees to develop nutrient reduction strategies and coordinate
implementation, as well as expanded monitoring efforts in the Gulf and
throughout the basin. The first recommended action is that the Task
Force develop an integrated budget proposal for additional funding to
support the actions outlined in the Plan. That proposal, to be
completed by December 2000, is still under development, but is expected to
call for roughly $5 billion over five years. The Action Plan and
associated background material are available on EPA's website.
- Minnesota Resolution in Support of Waterway
Transportation---Following a
set of informational hearings, the Minnesota House of Representatives'
Transportation Policy Committee passed a resolution on January 23
supporting waterway modernization. In particular, the resolution
"recognizes the importance of inland waterway transportation to
Minnesota agriculture and to the economy of the state, the region, and the
nation and urges Congress to authorize funding to modernize the Upper
Mississippi River System." In addition, the resolution expresses
support for Minnesota's share of the funding for new construction at the
Sault Ste. Marie Lock on the Great Lakes Seaway and for continued funding
of the state's Port Development Assistance Program, which has helped
support Mississippi River ports in Winona, Red Wing, and St. Paul,
Minnesota. The Committee heard testimony on the environmental
benefits of waterway transportation, as well as the future of industry in
the Minneapolis upper harbor. Environmental groups, including the
Izaak Walton League, have expressed opposition to the resolution, which
had been placed on the Consent Calendar for consideration by the full
House. As a result, the Minnesota House Environment Committee may
hold additional hearings on the measure, which is supported by the River
Resource Alliance and other navigation and agriculture groups.
- Wisconsin Proposed Rules on Nonpoint Pollution---On January 24, the Wisconsin
Natural Resources Board approved a set of eight draft rules, essentially
redesigning the state's nonpoint pollution programs. The new rules
come in response to instructions from the state legislature, in the
1997-1999 state budget, that the Department of Natural Resources and
Department of Agriculture, Trade and Consumer Protection overhaul the
programs by developing performance standards for both agricultural and
non-agricultural activities. Following public hearings last March,
workgroups developed the new rules, which will be the topic of public
hearings in the spring of 2001.
According
to Wisconsin DNR, "under the revised proposed rules ... agricultural
operations would need to meet standards for applying fertilizer, controlling
soil erosion from cropland, and managing manure. But grant programs would
help farmers offset the lion’s share of those costs, and DNR would not be able
to enforce those standards against specific farmers unless the state has paid
at least 70 percent of the cost of controlling that nonpoint source
pollution." The new rules also include performance standards for
municipal storm water control and for soil erosion and stormwater
management at construction sites. Municipalities and other
non-agricultural operators would be held to the standards regardless of whether
there was state money to help them cover some of the cost of controlling the
runoff. However, a competitive urban storm water and runoff management
grant program would be available to help defray costs. Additional
background information, including input from the public hearings and the new
draft rules, is available at DNR's website.
· Minnesota's Nonpoint Source Management Program Plan---The Minnesota Pollution Control
Agency is asking for public comment on its "Minnesota 2001-2005
Nonpoint Source Management Program Plan." The plan is a requirement
for Minnesota to remain eligible for EPA grants under Section 319 of the
federal Clean Water Act. The draft plan includes an updated assessment of
nonpoint sources of pollution, a watershed planning and management framework,
and detailed strategies for each water resource (i.e. groundwater, lakes,
rivers and streams, and wetlands) and for activities such as monitoring,
feedlots, agricultural erosion, agricultural pesticides, urban runoff,
forestry, mining, and atmospheric deposition. The comment period on the draft plan ends February 23, 2001.