Number: 1991-09
WHEREAS, clean water is critical to maintaining vital ecosystems and preserving the quality of life; and
WHEREAS, reauthorization of the Clean Water Act is currently pending before Congress; and
WHEREAS, reauthorization of the Clean Water Act presents an opportunity to enact toxics use reduction and pollution prevention principles which will enhance effectiveness of the Clean Water Act in controlling and, ultimately, eliminating non-point source and point source pollution; and
WHEREAS, the U. S. Environmental Protection Agency and many states allow polluters to dilute their effluents instead of treating and removing the pollutants they discharge; and
WHEREAS, discharges of toxics and contaminants are currently degrading high-quality waters and the existing water pollution control program does not ensure prohibitions against future degradation; and
WHEREAS, diffuse, non-point sources of water pollutants such as contaminated runoff from the nation’s highways and from both rural and urban lands is responsible for over half of the pollutants found in the nation’s waters; and
WHEREAS, one-fourth of this nation’s surface waters are derived from groundwater and these resources are not protected by an integrated and comprehensive pollution prevention program; and
WHEREAS, excessive water use contributes unnecessary inflows to overtaxed sewage treatment plants, depletes natural flows of rivers and streams, and leads to the construction of new and unnecessary dams and diversion of the nation’s waterways; and
WHEREAS, many sewage treatment systems accept storm water from combined sewers which results in massive dumping of untreated sewage, during and after heavy rainfall, into the waterways; and
WHEREAS, judicial confusion over the interpretation of Section 401 of the Clean Water Act has inappropriately limited the ability of state water quality agencies to ensure that state water quality standards will be maintained; and
WHEREAS, more than 50% of this nation’s original wetlands have been destroyed and several hundred thousand acres of wetlands are being lost each year, causing severe loss of public values such as fish and wildlife production, flood control, groundwater recharge and water quality improvement; and
WHEREAS, the limited scope and absence of vigorous implementation of the nation’s sole wetlands regulatory program, Section 404 of the Clean Water Act, contributes to the nation’s failure to stem this tide of wetlands loss and to achieve a goal of no-net-loss of wetlands; and
WHEREAS, a number of special interest groups advocate exempting certain states, such as Alaska, from the Clean Water Act §404 program based on factors such as “abundant” and “low value” wetlands; and
WHEREAS, failure of §404 implementing agencies to strictly adhere to the §404(b)(1) mitigation guidelines, especially the water dependency and reasonable prudent alternative tests, continues to cause a loss of wetlands by non-water dependent activities, such as golf course construction, for which upland alternatives are available;
NOW, THEREFORE, BE IT RESOLVED that the National Wildlife Federation in annual meeting assembled March 21-24, 1991, in Memphis, Tennessee, urges the United States Congress to promptly reauthorize the Clean Water Act and to prevent contamination and ensure conservation of this nation’s water resources, and maintain vital ecosystems; and
BE IT FURTHER RESOLVED that the Clean Water Act’s zero discharge mandate should be reaffirmed and implemented by integrating toxics use reduction and pollution prevention, prohibiting pollution dilution as a substitute for treatment, immediately prohibiting discharges of highly toxic and persistent bioaccumulative pollutants and eliminating other barriers to achieving the highest water quality; and
BE IT FURTHER RESOLVED that the National Wildlife Federation calls upon Congress to require the U. S. Environmental Protection Agency to forcefully implement an anti-degradation policy which would strengthen existing pollution control requirements where minimum water quality standards exist or have been achieved, maintain and protect existing water uses and the level of water quality necessary to protect these existing uses and to prohibit degradation of any waters, particularly, outstanding national resource waters; and
BE IT FURTHER RESOLVED that Congress mandate full and adequate treatment of all combined sewage overflows; and
BE IT FURTHER RESOLVED that Congress clarify the authority of the U. S. Environmental Protection Agency under the Clean Water Act to protect groundwater and require implementation of a federal groundwater protection program; and
BE IT FURTHER RESOLVED that Congress adopt new measures to promote and require water conservation measures at national, state and local levels to achieve beneficial reductions in water use; and
BE IT FURTHER RESOLVED that Congress clarify the authority of state water quality agencies under Section 401 of the Clean Water Act to deny or condition state certification of federal licenses and permits that may affect the chemical, physical or biological integrity of state waters; and
BE IT FURTHER RESOLVED that Congress address the unacceptably high level of wetlands loss in this nation and amend and strengthen Section 404 of the Clean Water Act to : (1) establish an explicit goal of no-net-loss of wetlands; (2) expand the list of regulated activities which destroy wetlands to include activities such as drainage, excavation and inundation; (3) provide the U. S. Environmental Protection Agency with lead responsibility for administering the Section 404 program; (4) reform general permit procedures to enhance wetlands protection; (5) apply fully to all 50 states and all U. S. territories and commonwealths and be based on the values and functions of wetlands ; and (6) require mitigation sequencing, especially for non-water dependent activities, such as golf course construction, which sets the highest priority on avoiding wetlands loss.