97001: Clean Water Act Reauthorization In the 105th Congress (contd.)

Claudia Copeland
Environment and Natural Resources Division

October 29, 1998

CONTENTS FOR THIS SECTION

Stormwater
Combined sewer overflows

Critical Areas/Sensitive Habitats

Wetlands

Other Issues

Regulatory relief
Toxic pollutants in the nation's waters
TMDLs and state water quality standards

The Administration's Clean Water Initiative
CONGRESSIONAL HEARINGS, REPORTS, AND DOCUMENTS
FOR ADDITIONAL READING

CRS Issue Briefs
CRS Reports

Stormwater. Stormwater discharge systems are the pipes and sewer lines that carry rainwater or snow melt (but not sanitary wastes) away from urban areas and commercial and industrial facilities. Although stormwater is discharged from pipes, like other wet-weather pollution problems, it is intermittent in nature and weather-dependent. Thus, it has characteristics of both point and nonpoint source pollution.

Although stormwater can transport significant amounts of pollutants, it had been largely unregulated until the 1987 amendments directed EPA to implement a specific permit program for stormwater discharges from industrial sources and municipalities. Delays in issuing regulations, coupled with high compliance costs (especially for some cities), have been frustrating and controversial. Industrial facilities and cities with populations of 100,000 or more are in the process of obtaining and complying with permits under EPA's current regulations. Smaller cities were to comply with rules that EPA was to have issued by October 1993. However, EPA missed that deadline and subsequently the agency worked with an advisory committee of stakeholders to develop rules for regulating smaller stormwater dischargers. Draft rules were proposed in December 1997, and final rules are due March 1, 1999. (For further information, see CRS Report 97-290, Stormwater Permits: Status of EPA's Regulatory Program.) Questions of how small sources will be regulated and the general complexity of the permit program have brought stormwater back as a legislative issue. Modifying current law to provide regulatory relief, particularly to municipalities, was a legislative issue in the 104th Congress and could recur in the future.

Combined sewer overflows. Nearly 1,200 municipalities have combined sewers where domestic sanitary sewage, industrial wastes, infiltration from groundwater, and stormwater runoff are collected and treated together. These systems serve approximately 40 million persons, mainly in older urban and coastal cities. Normally (under dry-weather conditions), the combined wastes are conveyed to a municipal sewage treatment plant to remove pollutants.

Properly designed, sized, and maintained combined sewers can be an acceptable part of a city's water pollution control infrastructure. However, combined sewer overflow (CSO) occurs when the capacity of the collection and treatment system is exceeded due to high volumes of rainwater or snowmelt, and the excess volume is diverted and discharged directly into receiving waters, bypassing the sewage treatment plants. Often the excess flow that contains raw sewage, industrial wastes, and stormwater is discharged untreated. Many combined sewer systems are found in coastal areas where recreational areas, fish habitat and shellfish beds may be contaminated by the discharges.

Combined sewers are categorized as point sources under the Act, yet for a long time they were not considered a high regulatory or permitting priority for EPA or states. There are no express provisions in the Act dealing with CSOs, except to the extent that they are subject to permit requirements and deadlines as are other point sources. Congress has recognized the impacts of CSO discharges, however, and legislative options to address the CSO issue directly have been discussed.

In both the 103rd and 104th Congresses, consensus began to emerge on modifying the CWA to endorse EPA's current permitting strategy which was developed in 1994 after negotiations with key stakeholder groups. As a first priority, EPA's strategy calls for eliminating overflows from combined sewers that occur even in the absence of rainfall (due to overcapacity of the sewers) and then calls for states and cities to address CSOs based on impacts on water quality and human health. Cities also were to implement nine minimum controls by Jan. 1, 1997 (e.g., proper operation and maintenance programs for sewer systems and pollution prevention programs). The EPA strategy does not contain a deadline for issuance of permits or for controlling CSOs. Deadlines will be contained in plans developed by permitting authorities. Controls are available and generally are based on combinations of management techniques (such as temporary retention of excess flow during storm events) and structural measures (ranging from screens that capture solids to construction of separate sewer systems). EPA officials stated in May 1998 that only about one-half of the cities with combined sewers have implemented the minimum measures called for in the 1994 strategy. EPA will soon begin working with states to remind cities of their obligations to address CSO problems. However, a formal enforcement strategy is not contemplated.

A more recent issue of concern to some cities is the problem of overflows from municipal separate sanitary sewers (SSOs) that are not CSOs and do not transport stormwater. Discharges of untreated sewage from these sewers occur from manholes, broken pipes and deteriorated infrastructure, and undersized pipes, and can occur in wet or dry weather. EPA estimates that there are approximately 18,000 municipalities with separate sanitary sewers, all of which can, under certain circumstances, experience overflows. No explicit EPA or statutory control policy currently exists. In 1995, EPA convened a stakeholders' group to discuss how to address those overflows that pose the highest environmental and public health risk first. Agency officials are working on a document that will detail regulatory priorities and circumstances appropriate for enforcement action.

Critical Areas/Sensitive Habitats

While the objectives of the Act apply broadly to chemical, physical and biological aspects of water quality, implementation has emphasized restoring the chemical integrity of the nation's waters by focusing on controlling individual pollutants and chemicals. Geographic areas such as the Great Lakes and Chesapeake Bay, with unique characteristics or pollution problems, have received broader attention under the Act. But, in general, less emphasis has been given to the related statutory objectives of restoring the physical and biological integrity of those same waters. More recently EPA identified a need to focus renewed attention on ecological concerns, in addition to the longstanding concern with protecting public health. EPA and others have recognized that the standard focus on individual chemicals may not adequately reflect other adverse effects on ecosystem health, for example, cumulative effects of discharges of multiple pollutants (including from atmospheric sources), effects from unknown or unregulated chemicals, or effects from episodic events such as spills, dumping, or treatment plant malfunctions. Thus, while maintaining control requirements already in place, EPA is also augmenting the water quality programs in more targeted ways.

Critical aquatic ecosystem areas such as wetlands and sediments are receiving new attention. Coastal and inland wetlands are valued as habitat for wildlife and aquatic species -- they often serve as spawning areas for fish and shellfish. Wetlands also have the potential to control or modify flood waters and to filter pollutants. Another critical ecological concern is sediments, which are found at the bottom of rivers, harbors, and lakes. They can be rich in some of the smaller forms of aquatic life that provide food for larger species. Yet, sediments also are areas where pollutants can settle and accumulate, thus harming species that reproduce and live there.

Wetlands. Wetlands are special areas in many respects. The marshes, bogs, and swamps that constitute many wetlands were long viewed as waste lands to be drained and converted to more productive use. Yet, as the habitat, flood control, and other functions of wetlands have been identified, efforts to protect those areas have grown. Activities in wetlands are regulated by a permit program under Section 404 of the Clean Water Act. Section 404 has evolved through judicial interpretation and regulatory change to become one of the principal federal tools used to protect wetlands, although that term appears only once in Section 404 itself and is not defined there. (For further information, see CRS Issue Brief 97014, Wetlands Issues in the 105th Congress.)

Unlike the rest of the Act, the permit aspects of Section 404 are administered by the U.S. Army Corps of Engineers, using EPA guidance. Other federal agencies including the Fish and Wildlife Service (FWS) and Natural Resource Conservation Service (NRCS) have significant but more limited roles in the Corps' permitting decisions. Tension has existed for many years between the regulation of activities in wetlands under Section 404 and related laws, on the one hand, and the desire of landowners to develop property that may include wetlands, on the other hand. The conflicts over wetlands regulation have for the most part occurred in administrative proceedings, as Congress has not amended Section 404 since 1977, when it provided exemptions for categories of routine activities, such as normal farming and forestry.

Pressure to revise Section 404 and wetlands regulation in general has grown. In January 1989, the four federal agencies that regulate wetlands activities adopted and issued a federal manual to provide a uniform definition and method for delineating wetland areas. While the manual was intended to provide consistency among the Corps, EPA, FWS, and NRCS, one result was a perception in some regions that areas not previously regulated now are considered wetlands and are subject to permit requirements. Developers and other groups contend that wetlands regulatory programs have been extended to areas with little or no resource value, yet at great cost to the landowner.

In August 1993 the White House announced new federal policies in an effort to reconcile conflicting interests in wetlands issues. The policies embody several principles and a large number of regulatory, administrative, and legislative details. Some were implemented by the Administration quickly (such as designating the NRCS as the lead agency for wetlands determinations on agricultural lands), while others are not yet complete (such as establishing a new administrative appeals process for review of wetlands permit decisions). Nonetheless, many critics of federal wetlands programs contend that these administrative changes do not provide the full extent of reform that they believe is needed.

Recent debate about federal wetlands protection efforts has involved agricultural policy, as well as environmental policy. National surveys indicate that agricultural activities have been responsible for a large portion of wetland modification in recent decades. The principal wetland protection program specifically for agricultural lands is known as swampbuster. Enacted in the 1985 farm bill, it is designed to remove federal farm program incentives that encourage farmers to convert wetlands to agricultural production. While it is a disincentive rather than a regulatory program, it was still controversial with farmers when implemented. Farmers have been confused over how swampbuster relates to the Section 404 program and concerned about continuing oversight by EPA and FWS. Attempting to resolve this uncertainty, the federal agencies responsible for wetlands programs signed a Memorandum of Agreement (MOA) in January 1994 implementing the Administration's pledge to designate NRCS as the lead agency for delineations and certifications on agricultural lands.

Still, many agricultural producers continue to argue that they have been adversely affected by wetland protection efforts, especially federal agency processes, and during debate on farm bill reauthorization, they sought a narrower coverage by a redefinition of affected wetlands. The 1996 farm bill (P.L. 104-127) contains wetland provisions with a number of program changes but not the wetlands redefinition supported by some farm groups. Several provisions amend the swampbuster program in ways intended to provide greater program flexibility, such as expanding the definition of agricultural land used in the MOA to include pasturelands and rangelands, and giving USDA the discretion to determine which farm program benefits swampbusters are ineligible for and to grant good-faith exemptions. (For additional information, see CRS Report 96-330, Conservation Provisions in the 1996 Farm Bill: A Summary.)

While the wetlands provisions of the 1996 farm bill address many concerns of the agricultural community, other groups continue to advocate Clean Water Act wetlands reform, as well. Among recent proposals for amending Section 404, a number of issues have been raised, including whether all wetlands should be treated the same or not and whether some could be accorded less stringent regulatory protection, whether activities or areas covered by regulation should be modified, and whether the institutional arrangements for implementing Section 404 (at federal and state levels) should be revised. Views on each of these issues vary. Many conservationists and environmentalists contend that any changes would weaken wetlands protection, while many landowners say that changes are needed to make the regulatory program workable again. During the last three Congresses, the continuing focus on Section 404 effectively overshadowed congressional consideration of other portions of the Act and was a key reason why no action on comprehensive reauthorization legislation occurred. Many observers believe that resolving changes to Section 404 remains the key to overall Clean Water Act reauthorization.

Two developments have pushed wetlands onto the congressional agenda recently. One is a January 1997 Federal District Court decision, upheld by an appeals court in June 1998, that voided the so-called "Tulloch" rule, issued by the Corps in 1993, which expanded the scope of regulation to include certain landclearing and excavation activities. Corps officials view the ruling as a major setback for the regulatory program, as do environmentalists. Industry groups support the decision. For now, the ruling leaves unsettled the scope of the Corps authority to regulate certain activities. The second development was the Corps' reissuance in December 1996 of nationwide permits, which are a key means by which the Corps minimizes the burden of its regulatory program. In the 1996 revisions, the Corps made changes to strengthen the environmental restrictions on one of the permits which has been most controversial, Nationwide Permit 26 (NWP 26). The changes to this permit pleased wetland protection advocates but were opposed by development and commercial interests who contend that permitting will now be more burdensome. Further, in July 1998, the Corps proposed six new permits to replace NWP 26. This proposal has been criticized both by developers, who say the new permits would be of little benefit to them, and environmentalists, who say the proposal is too expansive and would result in environmental damage to wetlands. (For more information, see CRS Report 97-223, Nationwide Permits for Wetlands Projects: Permit 26 and Other Issues and Controversies.)

On April 29, 1997, the House Transportation and Infrastructure Subcommittee on Water Resources and Environment held an oversight hearing on these developments. On June 26, the Senate Environment and Public Works Subcommittee on Clean Air, Wetlands and Private Property held a similar hearing on recent issues. At both hearings, witnesses representing developers and other groups subject to wetlands regulation expressed concern about impacts of the overall wetlands regulatory program and were critical of the 1996 changes to the nationwide permit program, saying that the changes would be costly and could result in project delays. Administration witnesses supported the modifications as reissued in December 1996, saying that the changes will allow the Corps to implement a more fair, flexible, and effective regulatory program which is appropriately responsive to environmental protection needs. They said that the Administration disagrees with the federal court's ruling on the "Tulloch" regulation and hopes that it will be overturned. At the Senate hearing, other public witnesses supported the changes to NWP 26, discussed the need to regulate excavation activities, and criticized the federal court's ruling concerning the Tulloch regulation. (Background information and testimony from the House subcommittee hearing is available via http://www.house.gov/transportation/water/wrhearin/4-29-97/429.htm. Testimony from the Senate subcommittee hearing is available via: http://www.senate.gov/~epw/stmts.htm).

Other Issues

Other issues have received attention as part of the water quality agenda. The Republican majorities of the House and Senate redefined clean water issues in the 104th Congress by focusing more on the need for flexibility and cost-effectiveness and less on the need to strengthen existing water pollution control programs.

Regulatory relief. Three issues emerged prominently on the policy agenda in 1993 and impacted debate on environmental and other legislation in the 103rd and 104th Congresses. The three, referred to as the regulatory relief agenda, are: unfunded mandates (how the federal government imposes requirements on states and cities without providing sufficient money to pay for those actions or flexibility in achieving them), private property takings (federal regulatory actions considered to infringe on property rights and diminish the value of private property holdings), and risk assessment (defined as whether EPA should be required to conduct risk and cost/benefit analysis in developing regulations or in setting regulatory priorities). None of these issues is limited to the Clean Water Act or is uniquely environmental, yet they have been considered extensively in connection with environmental and natural resource legislation, because many believe that is where relief is most needed.

These three issues, along with other reforms, were included in the House Republican "Contract with America." The 104th Congress addressed the unfunded mandates issue in a measure (P.L. 104-4) that requires the Senate and House to take a separate, majority vote in order to pass any bill that would impose unfunded mandates of more than $50 million on states and cities. It also requires the Congressional Budget Office to report information on bills that would impose more than $100 million in costs on the private sector. Another enactment, P.L. 104-121, authorized congressional review of major federal agency regulations. Both regulatory "takings" and regulatory reform were addressed in a broad measure passed by the House to carry out a number of items in the Contract with America (H.R. 9). The Senate did not act on H.R. 9 or other comprehensive regulatory reform legislation. Many of these issues have been controversial with some interest groups, including environmentalists, who view regulatory reform as attempts at undermining environmental, health and safety policies and law.

In the 105th Congress, some of these issues received renewed attention, focusing particularly on the costs and benefits of environmental and other federal regulations. On March 10, 1998, the Senate Committee on Governmental Affairs approved comprehensive regulatory reform legislation, S. 981. It would require agencies to evaluate and compare costs, benefits, and risks when proposing or promulgating rules expected to have a major impact on the national economy. However, the Senate did not take up S. 981. It also is possible that cost/benefit and risk assessment issues will be considered in the context of statute-specific debates, including the CWA, when Congress takes up review of that law in the future. Also, in May 1998, the House passed H.R. 3534, the Mandates Information Act of 1998, that would broaden the current unfunded mandates law with respect to impacts on the private sector. The Senate did not act on the House-passed bill.

Toxic pollutants in the nation's waters. Despite reductions in industrial wastewater discharges as a result of 25 years' of pollution control, toxic pollutants remain a serious cause of water pollution, threatening public health and the aquatic environment. Thus, even as the focus of clean water programs has shifted to address wet weather pollution problems from diffuse and intermittent sources, many persons argue that there is continuing need to maintain and strengthen the Act's toxic pollutant control programs. The General Accounting Office, among others, recommended that EPA expand the scientific criteria that are the backbone of state water quality standards (EPA Needs to Set Priorities for Water Quality Criteria Issues, GAO/RCED-94-117). Both environmentalists and states have urged EPA to update the effluent guidelines program, under which discharge controls are established for industry, in order to give federal and state regulators better tools for setting limits in discharge permits on a wider range of toxic pollutants.

TMDLs and state water quality standards. The CWA requires states to identify pollution-impaired water segments and develop "total maximum daily loads" (TMDLs) that set the maximum amount of pollution that a water body can receive without violating water quality standards. If a state fails to do so, EPA is required to develop a priority list for the state and make its own TMDL determination. Most states have lacked the resources to do TMDL analyses, which involve complex assessment of point and nonpoint sources, and EPA has both been reluctant to override states and has also lacked resources to do so. Thus, there has been little implementation of the provision which Congress enacted in 1972.

In recent months, national and local environmental groups have filed more than 25 lawsuits against EPA and states, claiming they have failed to fulfill CWA requirements. Courts in Georgia, Oregon and several other states have ordered EPA to develop TMDLs expeditiously. EPA officials are concerned about diverting resources from other high-priority activities in order to meet the courts' orders, especially if other lawsuits yield similar results. At the same time, EPA officials say they are interested in strengthening the long-neglected TMDL program and using it as a key assessment and management tool to address water quality problems on a watershed basis. In October 1996, EPA created an advisory committee to solicit advice on the TMDL problem. Some persons believe that the pressure of lawsuits on EPA and states will elevate this issue to congressional attention as part of CWA reauthorization. If this occurs, issues of interest are likely to include modifying TMDL requirements and deadlines, providing states with resources to develop TMDLs and related assessments, and reviewing the basic water quality standards requirements of the Act. While Congress has taken some steps to be more cautious in imposing new unfunded mandates, the TMDL provision of the CWA is an example of the many significant unfunded mandates that states still face under existing law. (For additional information, see CRS Report 97-831, Clean Water Act and Total Maximum Daily Loads (TMDLs) of Pollutants.)

The Administration's Clean Water Initiative

In October 1997, on the 25^th anniversary of the CWA, Vice President Al Gore announced an initiative intended to build on the environmental successes of the Act and to address the nation's remaining water quality challenges, especially nonpoint source pollution. The Vice President directed EPA and USDA to coordinate the work of other federal agencies to develop an action plan to improve and strengthen water pollution control efforts. The purpose of the plan is to coordinate federal efforts to achieve three goals: enhanced protection from public health threats posed by water pollution, more effective control of polluted runoff, and promotion of water quality protection on a watershed basis.

President Clinton and Vice President Gore released the action plan on February 19. Components of the plan, nearly 100 actions, consist mainly of existing programs, including some planned regulatory actions that agencies have had underway, now to be enhanced with increased funding or accelerated with performance-specific deadlines. (The text is available at http://www.epa.gov/cleanwater/) The individual elements of the plan are built on 4 concepts: utilizing collaborative watershed-based partnerships to clean up impaired waters; maintaining strong federal and state standards; calling on federal natural resource and conservation agencies to assist in restoring and protecting watersheds; and ensuring that citizens and officials have improved information for decisionmaking.

Complementing the plan, the President's FY1999 budget identified the Clean Water Initiative as a high-priority for environmental programs in the budget. It requested a total of $2.2 billion, a $568 million, or 35%, increase over 1998, to fund activities in 5 departments and agencies, plus interagency funds. Almost one-half of the total increases, $265 million, is designated as assistance to states and localities or to individual landowners (farmers).

The FY1999 increases for EPA would total $145 million and consist of $95 million more for grants to states to manage nonpoint source pollution (a 95% increase for CWA Section 319 grants); $20 million more for grants for state administration of water quality programs (a 20% increase for Section 106 grants); and $30 million for various water quality activities, including EPA development of water quality criteria for nutrients and updated regulations for animal feeding operations, other grants for watershed restoration and wetlands protection, and EPA actions to reduce the need for fish advisories. Other involved departments include USDA, the Departments of Interior and Commerce, and the U.S. Army Corps of Engineers.

The action plan was not accompanied by proposals or legislation to reauthorize the CWA. In Congress, it was considered primarily through the appropriations process, rather than authorizing committee activity. Funding to support the plan is contained in several separate appropriations bills, including the Omnibus Consolidated and Supplemental Appropriations Act (P.L. 105-277) passed just before the 105^th Congress adjourned. In those bills, congressional support for the action plan was quite mixed. Appropriators funded few budgetary elements of the Action Plan, citing reasons such as difficulty in supporting new initiatives, on top of existing priorities. Overall, the bills provided about 20% of the increased funds requested by the Administration. While EPA received full funding for the requested action plan activities contained in its budget, other agencies and departments received no or only small increases to support the plan.

(For further information, see CRS Report 98-150, The Clean Water Action Plan: Background and Early Implementation, and CRS Report 98-745, The Clean Water Action Plan: Budgetary Initiatives.)

CONGRESSIONAL HEARINGS, REPORTS, AND DOCUMENTS

U.S. Congress. Committee on Transportation and Infrastructure. Subcommittee on Water Resources and Environment. Reauthorization of the Federal Water Pollution Control Act. Hearings on H.R. 961, held Feb. 9, 16, 21, 24, Mar. 7, 9, 1995. 104th Congress, 1st session. Washington, U.S. Govt. Print. Off. 2 vols., 3149 p. (104-13)

----- Meeting Clean Water and Drinking Water Infrastructure Needs. Hearing, April 23, 1997. 105^th Congress, 1^st session. Washington, U.S. Govt. Print. Off., 437 p. (105-18)

----- Recent Regulatory and Judicial Developments on Wetlands. Hearing, April 29, 1997. 105^th Congress, 1^st session. Washington, U.S. Govt. Print., Off., 461 p. (105-36)

U.S. Congress. Senate. Committee on Environment and Public Works. Clean Water Act: Municipal Issues. Hearing, Dec. 13, 1995. 104th Congress, 1st session. Washington, U.S. Govt. Print. Off., 202 p. (S.Hrg. 104-518)

---- Subcommittee on Clean Air, Wetlands, Private Property, and Nuclear Safety. Wetlands Regulatory Reform Act of 1995. Hearings on S. 851, held July 19, Aug. 2, Nov. 1, 1995. 104^th Congress, 1^st session. Washington, U.S. Govt. Print. Off., 1176 p. (S.Hrg. 104-643)

----- Wetlands: Review of Regulatory Changes. Hearing, June 26, 1997. 105^th Congress, 1^st session. Washington, U.S. Govt. Print. Off., 230 p. (S.Hrg. 105-328)

FOR ADDITIONAL READING

Goplerud, C. Peter. "Water Pollution Law: Milestones from the Past and Anticipation of the Future." Natural Resources & Environment, v. 10, no. 2, Fall 1995: 7-12.

Houck, Oliver A. "TMDLs: The Resurrection of Water Quality Standards-Based Regulation Under the Clean Water Act." Environmental Law Reporter News & Analysis, v. 27, no. 7, July 1997: 10329-10344.

Knopman, Debra S. and Richard A. Smith. "20 Years of the Clean Water Act, Has U.S. Water Quality Improved?" Environment, v. 31, no. 1, January/February 1993: 16-20, 34-41.

National Academy of Sciences. National Research Council. Wetlands: Characteristics and Boundaries. National Academy Press. Washington, 1995. 268 p.

U.S. Environmental Protection Agency. National Water Quality Inventory: 1994 Report to Congress. Washington, 1995. "EPA841-R-95-005" 497 p.

---- "Clean Water Agenda, Remaking the Laws that Protect Our Water Resources." EPA Journal, v. 20, no. 1-2, summer 1994. Whole issue.

---- Office of Water. Environmental Indicators of Water Quality in the United States. Washington, 1996. "EPA841-R-96-002" 26 p.

U.S. General Accounting Office. State Revolving Funds Insufficient to Meet Wastewater Treatment Needs. (GAO/RCED-92-35) January 1992. 83 p.

---- EPA Needs to Set Priorities for Water Quality Criteria Issues. (GAO/RCED-94-117) June 1994. 10 p.

---- Many [Water Pollution] Violations Have Not Received Appropriate Enforcement Attention. (GAO/RCED-96-23) March 1996. 23 p.

---- State Revolving Fund Loans to Improve Water Quality. (GAO/RCED-97-19) December 1996. 20 p.

CRS Issue Briefs

CRS Issue Brief 89102. Water Quality: Implementing the Clean Water Act, by Claudia Copeland. (Updated regularly)

CRS Issue Brief 97014. Wetland Issues in the 105th Congress, by Jeffrey Zinn and Claudia Copeland. (Updated regularly)

CRS Reports

CRS Report 95-427. Clean Water: Summary of H.R. 961, as passed, by Claudia Copeland.

CRS Report 96-283. Reinventing the Environmental Protection Agency and EPA's Water Programs, by Claudia Copeland.

CRS Report 96-910. Clean Water Issues in the 105th Congress, by Claudia Copeland.

CRS Report 97-223. Nationwide Permits for Wetlands Projects: Permit 26 and Other Issues and Controversies, by Claudia Copeland.

CRS Report 98-150. The Clean Water Action Plan: Background and Early Implementation, by Claudia Copeland.

CRS Report 98-451. Animal Waste Management and the Environment: Background for Current Issues, by Claudia Copeland and Jeffrey Zinn.

CRS Report 98-745. Clean Water Action Plan: Budgetary Initiatives, by Claudia Copeland.