The ECOS Proposal for Expanded State Assumption of the CWA
March 2009
Citation:
39
ELR 10209
Issue
3
Editors' Summary
The Environmental Council of the States (ECOS) recently proposed that Clean Water Act §404 be amended to "remove the barriers" to state assumption of the §404 program. ECOS' specific proposals are unnecessary, unwise, and unworkable. The best and most reliable approach for protecting aquatic resources involves a vigorous federal §404 program along with effective state use of state §401 water quality certifications, Coastal Zone Management Act consistency certifications, and supplemental state law to fill in any gaps in the federal program.