U.S. Supreme Court Hears Arguments over WOTUS Challenge

By Emily Taylor, Porter Wright Morris & Arthur LLP

On October 11, 2017, the United States Supreme Court heard oral arguments on whether challenges to the Obama administration’s Waters of the United States (WOTUS) rule must be brought in a district court or a court of appeals. The case before the Supreme Court is an appeal from industry of the decision from the U.S. Court of Appeals for the Sixth Circuit that circuit courts, not district courts, have jurisdiction to decide the merits of the WOTUS rule. Section 509 of the Clean Water Act provides that the circuit courts have jurisdiction over challenges regarding “any effluent limitation or other limitation” and issues related to permit approvals and/or denials. See 33 U.S.C. 1369(b). All other challenges are to be heard in the district courts.

Historically, parties opposed to the WOTUS rule have argued that jurisdiction should properly be had in the district courts; however, the Trump administration’s recent proposed rule to rescind the WOTUS rule has complicated that position. If the Supreme Court were to reverse the Sixth Circuit’s decision and hold that jurisdiction is proper in the district courts before the Trump administration can successfully rescind the rule, then most likely the Sixth Circuit’s current stay of the rule would dissolve, and the rule would go into effect as is until either judicial, administrative, or other legislative action takes on the rule.

As to possible forthcoming administrative actions, President Trump’s February 28, 2017 Executive Order directed the EPA Administrator and Assistant Secretary of the Army for Civil Works to review the WOTUS rule. The order also specifically directed the agencies in their review to “consider” interpreting the definition of the term “navigable waters” in a “manner consistent” with the late Justice Scalia’s opinion in Rapanos v. United States (2006). In Rapanos, Justice Scalia defined the phrase “waters of the United States” as “includ[ing] only those relatively permanent, standing or continuously flowing bodies of water ‘forming geographic features’ that are described in ordinary parlance as ‘streams[,] . . . oceans, rivers, [and] lakes.’” Scalia made clear he did not believe the term included “channels through which water flows intermittently or ephemerally, or channels that periodically provide drainage for rainfall.” The President’s directive to the Agencies to rely on Justice Scalia’s definition from Rapanos, however, will have to overcome the Agencies’ historical reliance on Justice Kennedy’s opinion from Rapanos. Justice Kennedy wrote in his opinion that the definition of “navigable water” had already been established in an earlier case, Solid Waste Agency of Northern Cook County v. U.S. Army Corps of Engineers (2001) (SWANCC), as whether a water possessed a “significant nexus” to water that were “navigable in fact or could reasonably be made so.”

The difference between the Scalia and Kennedy opinions form Rapanos is significant as to the merits of the case because they offer different limits on the types of waters the EPA and Army Corps may regulate under the Clean Water Act. Parties opposed to the new definition of “waters of the United States” prefer Scalia’s more limited view, thus decreasing regulatory reach. Proponents of the rule, however, argue that Kennedy’s interpretation aligns much closer with the goal of the Clean Water Act, in that allowing the agencies to regulate more types of waters allows them to fulfill the Act’s purpose, “to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.”

Accordingly, on March 6, 2017 EPA Administrator Scott Pruitt and Assistant Secretary of the Army for Civil Works Douglas Lamont published a joint notice on the agencies’ “Intention to Review and Rescind or Revise the Clean Water Rule.” On April 3, 2017, EPA Administrator Scott Pruitt put forth a two-step plan to rescind and replace the Waters of the United States Rule: “1) an initial rulemaking to rescind the 2015 rule and reinstate the regulatory approach that, except for a brief two-month period prior the 6th Circuit stay of that rule, has been the law in place since 1986 … and 2) promulgation of a revised definition of water of the U.S. consistent with direction in the February 28, 2017 [Executive Order].” On May 2, 2017, the EPA and Army Corps of Engineers filed a proposed regulation, “Definition of Waters of the United States – Recodification of Preexisting Rules,” with the Office of Information and Regulatory Affairs (OIRA) to begin step one of the process, rescinding the rule. On May 5, 2017, Administrator Pruitt signed a recusal statement removing himself from working on the Clean Water Rule, due to conflicts created by his previous position as the Oklahoma Attorney General in which he sued the EPA regarding the rule.

On June 27, 2017, Administrator Pruitt signed the proposed rule that would repeal the WOTUS rule. The proposed rule was accompanied only by a brief economic analysis maintaining the WOTUS rule’s previously calculated implementation costs, but reducing the benefits by 85 to 90 percent such that the benefits no longer outweighed the costs. Public comments were due by September 27, 2017. The EPA received over 190,000 comments on the proposed repeal of the rule.

As to possible forthcoming legislative actions, on September 14, 2017 the United States House of Representatives passed H.R. 3344,which would “[a]uthorize[] the Environmental Protection Agency and the Army Corps of Engineers to withdraw the Waters of the United States rule without regard to any provision of statute or regulation that establishes a requirement for withdrawal. (This provision applies to the final rule issued by the two agencies on June 29, 2015, and titled “Clean Water Rule: Definition of ‘Waters of the United States.'” The rule revised regulations defining the scope of waters protected and regulated under the Clean Water Act.).” Section 431 of the bill would effectively allow the EPA to rescind the WOTUS rule without notice-and-comment rulemaking, allowing the agency to side-step the task of addressing the 190,000 comments received on the proposed repeal.

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  258. The Zune concentrates on being a Portable Media Player. Not a web browser. Not a game machine. Maybe in the future it’ll do even better in those areas, but for now it’s a fantastic way to organize and listen to your music and videos, and is without peer in that regard. The iPod’s strengths are its web browsing and apps. If those sound more compelling, perhaps it is your best choice.

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  263. The Zune concentrates on being a Portable Media Player. Not a web browser. Not a game machine. Maybe in the future it’ll do even better in those areas, but for now it’s a fantastic way to organize and listen to your music and videos, and is without peer in that regard. The iPod’s strengths are its web browsing and apps. If those sound more compelling, perhaps it is your best choice.

  264. Hands down, Apple’s app store wins by a mile. It’s a huge selection of all sorts of apps vs a rather sad selection of a handful for Zune. Microsoft has plans, especially in the realm of games, but I’m not sure I’d want to bet on the future if this aspect is important to you. The iPod is a much better choice in that case.

  265. Between me and my husband we’ve owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I’ve settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.

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  267. I’ll gear this review to 2 types of people: current Zune owners who are considering an upgrade, and people trying to decide between a Zune and an iPod. (There are other players worth considering out there, like the Sony Walkman X, but I hope this gives you enough info to make an informed decision of the Zune vs players other than the iPod line as well.)

  268. Between me and my husband we’ve owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I’ve settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.

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  270. Apple now has Rhapsody as an app, which is a great start, but it is currently hampered by the inability to store locally on your iPod, and has a dismal 64kbps bit rate. If this changes, then it will somewhat negate this advantage for the Zune, but the 10 songs per month will still be a big plus in Zune Pass’ favor.

  271. This is getting a bit more subjective, but I much prefer the Zune Marketplace. The interface is colorful, has more flair, and some cool features like ‘Mixview’ that let you quickly see related albums, songs, or other users related to what you’re listening to. Clicking on one of those will center on that item, and another set of “neighbors” will come into view, allowing you to navigate around exploring by similar artists, songs, or users. Speaking of users, the Zune “Social” is also great fun, letting you find others with shared tastes and becoming friends with them. You then can listen to a playlist created based on an amalgamation of what all your friends are listening to, which is also enjoyable. Those concerned with privacy will be relieved to know you can prevent the public from seeing your personal listening habits if you so choose.

  272. Apple now has Rhapsody as an app, which is a great start, but it is currently hampered by the inability to store locally on your iPod, and has a dismal 64kbps bit rate. If this changes, then it will somewhat negate this advantage for the Zune, but the 10 songs per month will still be a big plus in Zune Pass’ favor.

  273. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It’s very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.

  274. Hands down, Apple’s app store wins by a mile. It’s a huge selection of all sorts of apps vs a rather sad selection of a handful for Zune. Microsoft has plans, especially in the realm of games, but I’m not sure I’d want to bet on the future if this aspect is important to you. The iPod is a much better choice in that case.

  275. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It’s very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.

  276. The new Zune browser is surprisingly good, but not as good as the iPod’s. It works well, but isn’t as fast as Safari, and has a clunkier interface. If you occasionally plan on using the web browser that’s not an issue, but if you’re planning to browse the web alot from your PMP then the iPod’s larger screen and better browser may be important.

  277. I’ll gear this review to 2 types of people: current Zune owners who are considering an upgrade, and people trying to decide between a Zune and an iPod. (There are other players worth considering out there, like the Sony Walkman X, but I hope this gives you enough info to make an informed decision of the Zune vs players other than the iPod line as well.)

  278. Hands down, Apple’s app store wins by a mile. It’s a huge selection of all sorts of apps vs a rather sad selection of a handful for Zune. Microsoft has plans, especially in the realm of games, but I’m not sure I’d want to bet on the future if this aspect is important to you. The iPod is a much better choice in that case.

  279. You actually make it seem so easy with your presentation but I find this matter to be actually something which I think I would never understand. It seems too complicated and extremely broad for me. I’m looking forward for your next post, I’ll try to get the hang of it!

  280. Hands down, Apple’s app store wins by a mile. It’s a huge selection of all sorts of apps vs a rather sad selection of a handful for Zune. Microsoft has plans, especially in the realm of games, but I’m not sure I’d want to bet on the future if this aspect is important to you. The iPod is a much better choice in that case.

  281. This is getting a bit more subjective, but I much prefer the Zune Marketplace. The interface is colorful, has more flair, and some cool features like ‘Mixview’ that let you quickly see related albums, songs, or other users related to what you’re listening to. Clicking on one of those will center on that item, and another set of “neighbors” will come into view, allowing you to navigate around exploring by similar artists, songs, or users. Speaking of users, the Zune “Social” is also great fun, letting you find others with shared tastes and becoming friends with them. You then can listen to a playlist created based on an amalgamation of what all your friends are listening to, which is also enjoyable. Those concerned with privacy will be relieved to know you can prevent the public from seeing your personal listening habits if you so choose.

  282. If you’re still on the fence: grab your favorite earphones, head down to a Best Buy and ask to plug them into a Zune then an iPod and see which one sounds better to you, and which interface makes you smile more. Then you’ll know which is right for you.

  283. Apple now has Rhapsody as an app, which is a great start, but it is currently hampered by the inability to store locally on your iPod, and has a dismal 64kbps bit rate. If this changes, then it will somewhat negate this advantage for the Zune, but the 10 songs per month will still be a big plus in Zune Pass’ favor.

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