Wally, 
 
Some questions:
 
1. Is the rationale for the court ruling that the Clean Water Act  National 
Pollutant Discharge Elimination System (NPDES) permits are not required  
for Concentrated Animal Feeding Operations (CAFOs) the fact that pollutant  
emissions from a CAFO into waterways are not expected to occur  routinely, as 
they would from, say, a sewage treatment plant, but only  occasionally--and 
then only by accident? What other rationale could there be?  (Not a 
rhetorical question; if you know of alternative reasoning the court could  be 
following, I would be fascinated to hear it.)
 
2. Maybe the need to ask is a sign of my naivete, but is the  omission of 
so many categories of required information in the proposed  rule an oversight 
on the part of the EPA, or the result blatant  pro-industry bias?
 
3. Are you doing this excellent work pro-bono, as I suspect you are?  If so 
thank you. If not, it's worth every penny the Chapter can pay you. 
 
Tom

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