ILMA Compoundings – October 2019 - 49

populous state, with 12% of America's population, and
the fifth-largest economy in the world. When California
does something, many other states follow its lead, even if it
conflicts with the federal government.
IS CLEAN WATER NEXT?
Section 401 of the Clean Water Act requires anyone seeking a
federal license for an activity that may result in discharge into
"navigable waters" to obtain an environmental certification from
a state agency. The Trump administration has done a number
of things to limit federal jurisdiction under the Clean Water Act,
including redefining the scope of the "Waters of the U.S." rule,
and introducing a rule to limit the state certification time to
under a year. Importantly, this limits the scope of environmental
review, which is of increasing interest to politicians appealing
to popular demand. Of course, just as the EPA challenged the
California automakers deal, states took on the Section 401
rules. I have to wonder if there is an option, like in California,
to demonstrate a willingness to make some steps forward so
everyone can have their cake - and their certifications, too.

As I have noticed in my limited time with ILMA, one comment oft repeated is that environmental considerations, while
always present, are at an all-time high. A number of businesses
have affirmed their commitment to reducing emissions and
waste and considering society writ large, which may take the
shape of further subnational regulatory negotiations.2 From
a cynical perspective, it garners customers interested in such
commitments - but if it helps the environment, then worse
things have happened.
1. www.npr.org/2019/07/25/745389326/california-signs-deal-with-automakers-to-produce-fuel-efficient-cars
2. In August, CEOs at the Business Roundtable changed "the purpose of a
corporation" from higher profits to considering all stakeholders - employees, customers and society.

Levetown serves as associate counsel to ILMA through
Bassman, Mitchell, Alfano & Leiter Chtd. He may be
reached at 202-466-6502 or mlevetown@bmalaw.net.

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49

http://www.npr.org/2019/07/25/745389326/california-signs-deal-with-automakers-to-produce-fuel-efficient-cars http://www.npr.org/2019/07/25/745389326/california-signs-deal-with-automakers-to-produce-fuel-efficient-cars http://www.crystal-clean.com http://www.crystal-clean.com

ILMA Compoundings – October 2019

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