GLIN==> Water Transfers...No NPDES Permit Required

["Alex J. Sagady & Associates" <ajs@sagady.com>]

Today the US EPA published a notice of proposed rule saying that water transfers
from one part of the waters of the US to another part of waters of 
the US need not have a National Pollution Discharge Elimination System 
Permit.   Since transfer of Great Lakes waters might fall into this 
category, this proposed rule deserves scrutiny.

Although the rule claims to only deal with excepting the permit requirement from 
water transfers not involving a commercial, industry or municipal use of the 
waters, I still wonder about the issue of impairment of water quality caused 
in either the source waters or receiving waters.....such as damage to wetlands
from reduced water levels, turbidity contained in transferred flood waters and other
issues we haven't yet even thought of with the invocation of mass transfer of 
waters of the US from one location to another location.   Can there be a 
water quality impairment under the Clean Water Act through the transmittal of 
exotic, non-native species and would this be allowed without a permit?

http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.gpo.gov/2006/pdf/E6-8814.pdf


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Alex J. Sagady & Associates        http://www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy, 
Evidence Review and Litigation Investigation on Air, Water and 
Waste/Community Environmental and Resource Protection
Prospectus at:  http://www.sagady.com/sagady.pdf 

657 Spartan Ave,  East Lansing, MI  48823  
(517) 332-6971; (517) 332-8987 (fax); ajs@sagady.com
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