• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to footer
Already an ACWA member? Log in here.

Association of Clean Water Administrators HomepageAssociation of Clean Water Administrators

The Voice of States & Interstates since 1961

  • Home
  • Focus Areas
    • Legislation, Regulation and Litigation
    • Monitoring, Standards and Assessment
    • Nutrients Policy
    • Permitting, Compliance and Enforcement
    • Watersheds, TMDLs and Nonpoint Sources
  • Events
  • Documents
  • Tools
  • Members
    • Join Us
    • New Members
    • Committees
    • Awards
  • About
    • Staff
    • Leadership
    • Partnerships and Collaboration
    • Financials
  • Contact
Login
Home > Documents > Final ACWA Comment Letter Criminal Negligence Standard Proposal

Final ACWA Comment Letter Criminal Negligence Standard Proposal

Posted: January 8, 2021

Share This:

Comment Letter: ACWA would like to express support for the Environmental Protection Agency’s (EPA) recent proposed rule clarifying that “state or tribal programs approved pursuant to CWA Sections 402 and 404 are not required to include the same criminal intent standard that is applicable to EPA under Section 309 of the CWA.” States support the position that EPA has the authority to approve NPDES and Wetlands programs that allow for prosecution based on a state’s negligence standard, including simple/ordinary, gross, and recklessness. States’ criminal negligence standards are not universally identical, and states appreciate EPA recognizing the need for this flexibility.

Final ACWA Comment Letter Criminal Negligence Standard Proposal 1-8-2021

Download PDF (264.28 KB)

More documents like this

Focus Areas

  • Legislation, Regulation and Litigation

Document Types

  • Letters

Primary Sidebar

Recent Documents

  • Draft ECHO Usability Facility Searches Proposal

    June 30, 2022
  • 2022 Modeling Workshop Agenda

    June 15, 2022
  • 2022 Annual Meeting Agenda

    June 10, 2022

Footer

ACWA

The Association of Clean Water Administrators

nonprofit [501(c)3] organization

1634 I Street, NW

Suite 750

Washington, DC 20006

Phone: (202) 756-0605

Fax: (202) 793-2600

  • LinkedIn
  • RSS
  • Twitter

Learn More

  • Meeting Materials
  • Weekly Wrap
  • Job Opportunities
  • Policies

Are you an ACWA Member?

Log In

Our Member365 site gives you the opportunity to talk to your fellow members and gain insights!

Not a member? Learn how to join ACWA.

- Site by Rocketkoi -

ACWA

  • Home
  • Focus Areas
    • Legislation, Regulation and Litigation
      • Rulemakings
    • Monitoring, Standards and Assessment
    • Nutrients Policy
      • Nutrients Reduction Progress Tracker
    • Permitting, Compliance and Enforcement
    • Watersheds, TMDLs and Nonpoint Sources
      • Waters of the U.S. (WOTUS) Resources
  • Tools
  • Members
    • Join Us
    • New Members
    • Member365 Frequently Asked Questions
    • Committees
    • Awards
  • Events
  • Meeting Materials
  • About
    • Staff
    • Leadership
    • Partnerships and Collaboration
    • Financials
  • Documents
  • Weekly Wrap
  • Job Opportunities
  • Contact