The Unitary Waters Apprach: The Government\u27s Misguided Attempt to Limit the Reach of the Clean Water Act

Abstract

This Comment will, first, determine whether the government\u27s unitary waters approach is a viable interpretation of the SWA. Second, it will explore what characteristics should be considered to determine whether two water bodies are meaningfully distinct. Finally, this Comment will explore the possible consequences of applying the NPDES program to water transfers between two water bodies