State Water Control Board v. Train

559 F.2d 921, 7 ELR 20571 (1977)

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State Water Control Board v. Train

United States Court of Appeals for the Fourth Circuit
559 F.2d 921, 7 ELR 20571 (1977)

Facts

The Federal Water Pollution Control Act (FWPCA) required publicly owned sewage treatment plants to comply with the effluent discharge limits in § 301 of the FWPCA by July 1977. The FWPCA also provided federal grants to states and municipalities to cover 75 percent of the construction costs for improved, publicly owned treatment plants. However, the funding provided for these grants was insufficient, and disbursement was delayed. Many state and local governments were unable to finance construction of the treatment plants. Section 402 of the FWPCA provided that no person could discharge pollutants without a permit issued by the Environmental Protection Agency (EPA) or an EPA-approved state entity. The issuance of a permit required compliance with the effluent limits in § 301. The FWPCA set out civil and criminal penalties for discharge of effluent without a permit. The legislative history of the FWPCA showed that legislators had rejected a provision that would limit the applicability of § 301 to entities that had not received federal grants. Virginia’s State Water Control Board (board) (plaintiff) sued Russell Train (defendant), the administrator of the EPA. The board sought a declaration that publicly owned sewage treatment plants that had failed to receive federal grants were not required to comply with § 301’s effluent limits. The district court rejected the board’s request. The board appealed, arguing that Congress would not have rejected the provision limiting applicability of § 301 if legislators had known that the federal grants would be delayed.

Rule of Law

Issue

Holding and Reasoning (Russell, J.)

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