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