The working materials in the NRDC Document Bank are listed in reverse chronological order. For additional policy materials including reports and issue papers, see the Issues section of the main NRDC site.
NRDC et al, Comments on Underground Injection Permits proposed in Lochgelly, West Virginia
Comments on draft Underground Injection Control permits, issued to Danny E Webb Construction, Inc. by West Virginia Department of Environmental Protection, Office of Oil and Gas. The comments were submitted by: NRDC, Eight Rivers Council, Brad Keenan, Ohio Valley Environmental Coalition, Plateau Action Network, West Virginia Citizen Action Group, and West Virginia Surface Owners' Rights Organization.
- wat_15043001a.pdf (Comment Letter)
- wat_15043001b.pdf (Comment Letter Appendices 1-9)
- wat_15043001c.pdf (Comment Letter Appendix 10 Part 1)
- wat_15043001d.pdf (Comment Letter Appendix 10 Part 2)
- wat_15043001e.pdf (Comment Letter Appendix 10 Part 3)
- wat_15043001f.pdf (Comment Letter Appendices 11-18)
NRDC Request for Proposals for Actuarial Analysis of a Federal Crop Insurance Program §508(h) Pilot Cover Crop Endorsement
NRDC is requesting proposals from qualified and experienced contractors to assist in the development of a §508(h) pilot crop insurance program, which would offer actuarially sound crop insurance discounts to producers whose appropriate use of cover crops puts them at a lower risk for crop loss.
Natural v NYSDEC Supplemental Brief for Petitioners – Appellants
NRDC's opening brief and reply brief filed in the New York Court of Appeals, in a challenge to New York's statewide permit for municipal stormwater pollution ("Small MS4 General Permit").
Natural v NYSDEC Brief for Petitioners – Appellants
NRDC's opening brief and reply brief filed in the New York Court of Appeals, in a challenge to New York's statewide permit for municipal stormwater pollution ("Small MS4 General Permit").
Water Audits & Water Loss Control for Drinking Water Utilities: Costs and Benefits
This document, prepared by NRDC on 4/2/15, provides a summary of available information on the financial costs of, and savings realized through, drinking water utilities’ performance of water loss audits.
NRDC Request for Proposal for Technical Consultant to Develop Methodology for Cost and Effectiveness Analysis of Water Efficient Practices
NRDC is seeking an experienced technical consultant to develop a methodology and draft regulatory language for evaluating and selecting projects and activities eligible for Clean Water State Revolving Fund financing that maximize the potential for water and energy conservation. Please see the attached RFP for additional details. NRDC's total budget for this project is $20k, and proposals are due by 5pm PDT on Friday, March 20. Please forward this to any colleagues that review RFPs and/or might have an interest in submitting a proposal.
Deadline for proposals extended to 5pm PDT on Tuesday, March 24, 2015.
Freedom of Information Law Request to NY State DEC re: SPDES General Permit for Stormwater Discharges from Municipal Separate Storm Sewer Systems (MS4s) – Permit No. GP-0-10-002
In 2014, NRDC formally requested records concerning implementation of New York&'s statewide permit for stormwater discharges from urban and suburban storm sewer systems. This ZIP file contains the request letters and the NY State Department of Environmental Conservation's response letters, along with all agency records provided in response to the request.
- wat_15022001a.zip ZIP File (165 MB)
Philadelphia Water Department Operations and Maintenance Agreement for Stormwater Management Practices
Template for the Philadelphia Water Department Operations and Maintenance Agreement for Stormwater Management Practices.
Petition for a Writ of Mandamus
Environmental Defense Center and Natural Resources Defense Council's petition for a writ of mandamus against the Environmental Protection Agency, filed in the Ninth Circuit Court of Appeals on December 18, 2014.
State Water Loss Narratives
State specific information on water loss reporting data for NRDC’s Water Loss webpage.
- wat_14111801a.pdf Georgia
- wat_14111801b.pdf Hawaii
- wat_14111801c.pdf Kentucky
- wat_14111801d.pdf Massachusetts
- wat_14111801e.pdf New York
- wat_14111801f.pdf Oregon
- wat_14111801g.pdf Tennessee
- wat_14111801i.pdf Washington
- wat_14111801j.pdf California
- wat_14111801m.pdf Maryland
- wat_14111801n.pdf Ohio
- wat_14111801o.pdf Pennsylvania
- wat_14111801s.pdf Rhode Island
- wat_14111801u.pdf Virginia
- wat_14111801w.pdf Michigan
- wat_14111801x.pdf Minnesota
- wat_14111801y.pdf New Jersey
- wat_14111801z.pdf Wisconsin
- wat_14111801aa.pdf Catawba Wateree Watershed Management Group (CWWMG)
- wat_14111801ab.pdf DC Water
- wat_14111801ah.pdf South Carolina
- wat_14111801ai.pdf Texas
- wat_14111801ac.pdf Delaware River Basin Commission (DRBC)
- wat_14111801ad.pdf Delaware
- wat_14111801aj.pdf West Virginia
- wat_14111801ak.pdf Indiana
- wat_14111801ae.pdf Southwest Florida Water Management District (SWFWMD)
- wat_14111801af.pdf Las Vegas Valley Water District
- wat_14111801al.pdf New Hampshire
- wat_14111801am.pdf North Carolina
- wat_14111801an.pdf Illinois updated
- wat_14111801ag.pdf Orange County, Florida
- wat_14111801ao.pdf Philadelphia
- wat_14111801ap.pdf Georgia updated
- wat_14111801aq.pdf Arizona updated
- wat_14111801ar.pdf City of Ashville Water Audit 2014
Austin Water Loss Audit 2012
Austin Water Utility’s 2012 AWWA Water Loss Audit for NRDC’s Water Loss webpage.
NRDC comments for Proposed Clean Water Protection Rule
NRDC's comments on the Environmental Protection Agency’s (EPA) and U.S. Army Corps of Engineers’ (the Corps) proposed rule, “Definition of ‘Waters of the United States’ Under the Clean Water Act.”
Wetter or Not: Actions to Ease the Current Drought and Prepare for the Next
California is in the third year of a severe drought. Our state’s climate is characterized by extreme variability alternating between prolonged droughts and major floods, a situation that is predicted to worsen as climate change progresses. Yet, we fail to manage our state’s finite water resources to prepare for increasing exposure to more severe and prolonged droughts. All of these recommendations respond to the drought. All would also set the stage for a more reliable long-term water supply, a more resilient economy, and a healthier environment.
Brewers for Clean Water Comment Letter
In November of 2014, 32 of the nation's most beloved craft brewers sent a letter to the USEPA in support of the Clean Water Protection Rule, which brings streams, wetlands and headwaters back under the Clean Water Act.
NRDC Scientist Sign On Letter US Forest Service Groundwater Directive
We are asking support from scientists for the development of sustainable groundwater management principles and practices on National Forests and Grasslands. NRDC recently highlighted the importance of high quality, abundant groundwater from National Forests and the threats it faces. Proper groundwater management on our National Forests would help maintain a clean source of drinking water and a sustainable supply of water to keep forests healthy, wetlands wet, and streams flowing.
NRDC Coalition Scoping Comments re HSR, Aug 2014
Scoping Comments from NRDC and community allies regarding Burbank to Los Angeles EIR/EIS and Palmdale to Burbank EIR/EIS
Comments on USFS Groundwater Directive, NRDC et al, 9-3-14
Comment letter on the U.S. Forest Service's proposed Groundwater Directive, published in the Federal Register on May 6, 2014 at 79 Fed. Reg. 25,815. These comments are submitted by the Natural Resources Defense Council on behalf of numerous NGOs.
"Water Loss Hazard Mitigation Act" Draft Legislation
A draft amendment to the federal Safe Drinking Water Act to establish a national clearinghouse of water main breaks and to encourage states to establish hazard classification systems for large water mains.
Group Comments on the Draft National Beach Guidance and Required Performance Criteria for Grants
NRDC, Clean Ocean Action, Hackensack Riverkeeper, Heal the Bay, NY/NJ Baykeeper, Riverkeeper, and Waterkeeper Alliance comments to U.S.EPA (May 28, 2014).
Westlands BDCP DWR Workshop Presentation 11-20-13
Powerpoint presentation on BDCP given by Westlands Water District at DWR workshop on November 20, 2013.
American Farm Bureau Federation July 14 letter in response to NRDC’s Jon Devine’s debate challenge about the Clean Water Protection Rule.
In a letter dated July 14, American Farm Bureau Federation senior counsel Danielle Quist responded to NRDC’s Jon Devine’s debate challenge about the Clean Water Protection Rule, essentially declining Devine’s request.
NRDC Letter to Senior Counsel Danielle Quist at the American Farm Bureau Federation in response to the Farm Bureau’s refusal to a public debate the Clean Water Protection Rule, dated July 15, 2014.
Following the Farm Bureau’s refusal to debate NRDC Senior Attorney Jon Devine about the Clean Water Protection Rule, Devine responded to the Farm Bureau’s senior counsel that debate would benefit public understanding, which the Farm Bureau claims to support (July 15, 2014).
Letter to American Farm Bureau Federation President Robert Stallman from NRDC Senior Attorney Jon Devine, dated July 10.
In response to unfounded attacks by the Farm Bureau against the Clean Water Protection Rule, NRDC Senior Attorney Jon Devine invited Farm Bureau President Robert Stallman to a public debate about the rule.
May 2014 Poll on Latinos’ Opinions About Federal Clean Water Protections
Results of a May 2014 poll on Latinos’ opinions about federal clean water protections in Colorado, Illinois, Florida, and New Mexico commissioned by NRDC.
- wat_14061801a.pdf Colorado Survey Results
- wat_14061801b.pdf Florida Survey Results
- wat_14061801c.pdf Illinois Survey Results
- wat_14061801d.pdf New Mexico Survey Results
IMO Guidelines for the Reduction of Underwater Noise
Guidelines from the International Maritime Organization for the reduction of underwater noise from commercial shipping, to address adverse impacts on marine life.
09-17661 - United States Court of Appeals for the Ninth Circuit Opinion regarding Central Valley Project water contracts
A unanimous eleven judge-panel of the U.S. Ninth Circuit Court of Appeals today overturned the federal government’s renewal of more than 100 water supply contracts for diversions from the Bay-Delta ecosystem in 2004 and 2005. The court sided with the Natural Resources Defense Council (NRDC), California Trout, San Francisco Baykeeper, Friends of the River, and The Bay Institute, concluding that renewal of these water supply contracts by the Bureau of Reclamation violated the Endangered Species Act. NRDC and Earthjustice represented the environmental groups (April 16, 2014).
March 3, 2014 letter from conservation groups to S. 2016 cosponsors
Comments on California Emergency Drought Relief Act of 2014 (S. 2016) (March 3, 2014).
Emergency Drought Relief Act of 2014 (S. 2198): Concerns Over Revised California Drought Bill
Conservation group letter in response to Emergency Drought Relief Act of 2014 (S. 2198): Concerns Over Revised California Drought Bill (April 14, 2014).
New Jersey Flood Map Comments
Comments to FEMA regarding proposed flood maps for New Jersey and the omission of sea level rise and other climate impacts. These are the first updated maps for New Jersey, post Hurricane Sandy.
Joint Comments on Commercial Clothes Washer Framework Document for 2015 Efficiency Standards, Oct 2012
Letter from NRDC and Appliance Standards Awareness Project to DOE, Docket No. EERE-2012-BT-STD-0020, Oct 12, 2012, urging DOE to reestablish a single product class and improve the valuation of carbon emission reductions.
The Garden Club of America Letter, February 20, 2014
The Garden Club of America letter to President Obama on the “Waters of the U.S.” rulemaking, February 20, 2014.
U.S. Ninth Circuit Court of Appeals opinion determining a federal plan of protection for California’s vital Delta ecosystem; Delta smelt biop ruling, Case #11-15871
The U.S. Ninth Circuit Court of Appeals ruled to uphold a federal plan of protection for California’s vital Delta ecosystem. The court sided with the Natural Resources Defense Council (NRDC) and the federal government in its determination that protections for the threatened delta smelt – a bellwether species that indicates the health of the vital San Francisco Bay-Delta estuary – are fully justified and necessary to restore the health of this largest estuary on the west coast of the Americas (March 13, 2014).
Protect our waters from oil spills – Oppose H.R. 311
On March 11, 2014, NRDC sent a letter to the House of Representatives opposing H.R. 311. This bill would decrease the oversight of oil storage and safeguards against spills at locations around the country for one class of facilities without showing that they are safer than other facilities with the same volume of oil.
New York City Flood Map Comments
Comments to FEMA and the City of New York regarding proposed flood maps for New York City and the omission of sea level rise and other climate impacts. These are the first updated maps for New York City Post Hurricane Sandy and the first substantive update of the maps since 1983.
Comments on California Emergency Drought Relief Act of 2014 (S. 2016) Letter, March 3, 2014.
Conservation Group Coalition letter to Senators Feinstein, Boxer, Wyden, and Merkley on the California Emergency Drought Relief Act of 2014 (S. 2016).
NRDC Drought Recommendations to the CA State Water Resources Control Board, February 26, 2014
Recommendations to the CA State Water Resources Control Board on immediate and long-term actions the Water Boards and other state agencies should be taking statewide in response to the drought. NRDC outlines nineteen recommendations for agricultural and urban water use and efficiency, water recycling, stormwater capture, graywater, and state water management.
California Drought Poll by FM3, February 2014
Fairbank, Maslin, Maullin, Metz & Associates (FM3) conducted a poll on behalf of the Natural Resources Defense Council to ascertain California voters’ views on the record-breaking drought California is experiencing. The poll found that California voters are more concerned about the drought than any other major issue and an overwhelming majority favor strategies to stretch local water supplies, including recycling, rainwater harvesting and efficiency measures, as the top solution to California’s water woes.
Water System Loss Control Study – California
Prepared for Southern California Edison by Water Systems Optimization, Inc, for submission to the California Public Utilities Commission, December, 2009, estimating annual losses of 870,000 acre-feet, of which 350,000 acre-feet are economically recoverable.
Water Delivery System Efficiencies
New York State Comptroller H. Carl McCall's assessment of water loss audit and reporting practices, rates of water loss, and water conservation programs, at eight drinking water utilities in New York State (April 2002).
NRDC-UA Joint UPC Proposal on Hot Water Piping Insulation
Joint proposal filed by NRDC and the United Association (UA) to require hot water piping insulation in the 2015 Uniform Plumbing Code (UPC)
Brewers Applaud Clean Water Actions
Brewers for Clean Water member breweries applaud two important steps recently taken by the Obama Administration to provide safeguards for the water sources on which the breweries -- and the communities in which they operate -- depend.
Green Infrastructure In New Jersey – The Current State of Implementation
NRDC summary of the current state of green infrastructure implementation in New Jersey, with examples of policies, programs, and practices implemented in other communities across the country that could serve as models for cost-effective efforts to reduce stormwater pollution, sewage overflows, and flooding in New Jersey.
LA River Ecosystem Restoration Study Public Comments
Public comments on the US Army Corps of Engineers Los Angeles River Ecosystem Restoration Integrated Feasibility Report.
Memorandum on Water Savings Associated with Reduced Toxic Discharge Requirements for Power Plants
Memo from NRDC to the Environmental Protection Agency, Sept 20, 2013 discussing the potential water savings associated with EPA’s proposed effluent limitations guidelines for steam electric power plants, and addressing EPA’s incomplete analysis of benefits of reduced surface water withdrawals resulting from the proposed regulations.
Comments to EPA on Proposed Effluent Limitation Guidelines for Steam Electric Power Plants
Comments submitted on Sept 20, 2013 by Earthjustice, Sierra Club, Environmental Integrity Project, and NRDC to the Environmental Protection Agency objecting to EPA’s rationale for selecting four “preferred” regulatory options and urging EPA to select either of two more stringent options to reduce toxic discharges and unnecessary water use in the final rule.
New Science On Impacts of Navy Sonar
A letter to the California Coastal Commission that details recent scientific studies, which confirm the harmful impacts of Navy sonar training and testing on Southern California marine mammals.
NRDC comments on Miami-Dade County Consent Decree
NRDC submitted comments calling for EPA and Miami-Dade County to ensure that climate change impacts were factored into the design and operations of any sewage infrastructure improvements that were agreed to as part of a settlement on long-standing violations of the Clean Water Act.
Saving Energy and Water through State Programs for Clothes Washer Replacement in the Great Lakes Region
June 2013 whitepaper authored by American Council for an Energy-Efficient Economy (ACEEE) and NRDC on efforts to develop a statewide program for implementation in the Great Lakes states to save energy and water through clothes washer replacement.
Notice of Intent to Sue EPA for Failure to Protect Beachgoers from Water Pollution
The Environmental Protection Agency has failed to meet its legal responsibility to adopt water quality criteria that address the health threat posed by pollution at U.S. beaches, according to a notice of intent to sue filed by a coalition of local and national organizations concerned about beach water quality. The groups filing the notice are Clean Ocean Action, Hackensack Riverkeeper, Heal the Bay, Natural Resources Defense Council, NY/NJ Baykeeper, Riverkeeper and Waterkeeper Alliance.
NRDC v. Jewell Settlement Agreement
The agreement filed in federal district court today, in the case of NRDC v. Jewell.
Letter to President Obama from Craft Breweries on Clean Water Act Guidance
June 12, 2013 letter to President Obama signed by 20 U.S. craft breweries calling for guidelines that clarify the variety of bodies of water protected under the Clean Water Act, including streams and wetlands.
Letter to U.S. Army Corps of Engineers Colonel Robert J. Ruch Opposing Surplus Water Agreements for Withdrawals from Lake Sakakawea
Letter to U.S. Army Corps of Engineers Colonel Robert J. Ruch opposing to the decision by the U.S. Army Corps of Engineers (“Corps”) to sign surplus water agreements authorizing withdrawals from Lake Sakakawea for oil and gas activities in North Dakota.
NRDC Comments on North Carolina’s State Mitigation Plan update
NRDC’s public comments on North Carolina’s State Mitigation Plan (SHMP). Because the state was unwilling to share a copy of North Carolina’s draft 2013 update, NRDC reviewed North Carolina’s 2010 SHMP. Based on this review, we have developed recommendations for FEMA’s consideration regarding its approval of North Carolina’s 2013 SHMP.
NRDC opposes an extension of the State Mitigation Plan submission requirements
NRDC public comments opposing the extension of State Mitigation Plan submission requirements from three years to five years, because the extension is not accompanied by requirements to ensure the quality of the State Mitigation Plans increases to compensate for less frequent updates.
Inaccurate Water Meters Hide Leaks, NRDC and Utilities Propose Stronger Accuracy Standards
Letter to American Water Works Assoc. from NRDC, Austin Water Utility, San Antonio Water Systems, and American Water (NYSE: AWK), the nation's largest publicly traded water company, March 26, 2013.
Proposals to Revise Standards for Shower Mixing Valves
Two proposals filed in March 2013 by NRDC to the product standard for shower mixing valves jointly maintained by the American Society of Sanitary Engineers, the American Society of Mechanical Engineers, and the Canadian Standards Association to better maintain the thermal protection of shower mixing valves when high efficiency showerheads are installed.
Plumbing Code Proposals to Save Water in New Buildings
Thirteen water-saving proposals filed in January 2013 by NRDC with the International Association of Plumbing and Mechanical Officials for the 2015 Uniform Plumbing Code, used by California, Oregon and other states as the plumbing code for new buildings.
Energy Code Proposals to Save Hot Water in New Homes
Six energy- and water-saving proposals filed in January 2013 by NRDC with the International Code Council for the 2015 International Energy Conservation Code, used by over 30 states as the energy code for new buildings.
Plumbing Code Proposals for New Single-Family Homes
Five water-saving proposals filed in January 2013 by NRDC with the International Code Council for the 2015 International Residential Code, used by over 30 states as the building code for new single-family homes
Greening Vacant Lots: Planning and Implementation Strategies
A report prepared as part of the NatLab collaboration, an effort among Natural Resources Defense Council, The Nature Conservancy, and EKO Asset Management Partners, which presents case studies showing how 10 U.S. cities are planning, administering, financing and implementing programs to convert vacant lots to green spaces that combine recreational use and stormwater management.
CEO Green Group Pebble Mine Letter (July 23)
A coalition letter from various green groups to EPA in support of its Draft Watershed Assessment’s findings that large-scale mining would cause irreparable harm to the Bristol Bay watershed.
Environmental Entrepreneurs letter to EPA re Watershed Assessment
A letter from E2 to EPA in support of its Draft Watershed Assessment’s findings that large-scale mining would cause irreparable harm to the Bristol Bay watershed.
NRDC Cover Letter re EPA Watershed Assessment Comments (July 23 2012)
NRDC’s cover letter associated with our comments on EPA’s Draft Watershed Assessment of Bristol Bay and the potential impacts of large-scale mining there, particularly the Pebble Mine.
Comments on Navy’s Training and Testing Plans for Atlantic Coast and Gulf of Mexico
NRDC and other conservation organizations sent a letter to the U.S. Navy commenting on its Draft Environmental Impact Statement (DEIS) for training and testing activities along the Atlantic Coast and in the Gulf of Mexico from January 2014 to January 2019. During that period, the Navy predicts nearly 19 million instances of whale and dolphin “take” (behavioral impacts, harassment, injury), including more than 2.25 million instances of temporary hearing loss, more than 10,000 instances of permanent hearing loss, and more than 800 deaths. The letter urges the Navy to revise its DEIS, exploring additional alternatives and mitigation measure that would lessen the harm from the Navy’s activities to whales, dolphins, and other marine wildlife.
Comments on Navy’s Training and Testing Plans for Hawaii and Southern California
NRDC and other conservation organizations sent a letter to the U.S. Navy commenting on its Draft Environmental Impact Statement (DEIS) for training and testing activities in Hawaii and Southern California from January 2014 to January 2019. During that period, the Navy predicts more than 14 million instances of whale and dolphin “take” (behavioral impacts, harassment, injury), including almost 3 million instances of temporary hearing loss, more than 5,000 instances of permanent hearing loss, and 1,000 deaths. The letter urges the Navy to revise its DEIS, exploring additional alternatives and mitigation measure that would lessen the harm from the Navy’s activities to whales, dolphins, and other marine wildlife.
Letter to NYSDEC Commissioner Joe Martens on the need for SEQRA Review for Liquified Petroleum Gas (Propane) Fracturing
State Environmental Quality Review Act Requires Additional Comprehensive Environmental Review Before Permitting Liquified Petroleum Gas (Propane) Fracturing.
Letter on EPA's proposed emissions standards for natural gas production and transmission
Letter on controlling dangerous air pollution from natural gas "fracking," from NRDC and other organizations to Valerie Jarrett, Senior Advisor to President Obama, April 9, 2012. This letter responds to attacks on EPA's pending air pollution standards for natural gas fracking wells and other oil and gas operations.
Legal brief regarding the proposed Pebble Mine in Alaska
Brief on Behalf of the Natural Resources Defense Council in Support of Petitions to the U.S. Environmental Protection Agency for Action Regarding the Proposed Pebble Mine Under Section 404(c) of the Federal Water Pollution Control Act.
Mississippi River Pollution Legal Documents
On behalf of the Mississippi River Collaborative and a coalition of environmental groups, NRDC filed two suits against the USEPA related to dual pollution threats plaguing the Mississippi River. The suits seek action from the agency on nitrogen and phosphorus pollution, which stimulates excessive growth of algae, kick-starting the “Dead Zone” that forms in the Gulf of Mexico annually.
Lautenberg-Pallone Letter on EPA Recreational Water Quality Criteria
Senator Frank Launteberg (D – NJ) and Congressman Frank Pallone (D – NJ) urge EPA for a stronger recreational water quality criteria to adequately protect public health.
Volumetric Pricing for Sanitary Sewer Service in the State of California
This white paper seeks to quantify the effect of shifting residential sewer service billing from collections based on fixed charges to a billing system based on the volume of water consumption.
Dimock petition over water deliveries
A petition from residents of Dimock, PA, over clean water deliveries from Cabot Oil & Gas that were ceased with state permission.
Letter to PA DEP re: Dimock water deliveries
A letter from NRDC to the Pennsylvania Department of Environmental Protection regarding deliveries of safe drinking water to residents of Dimock, PA, after they were ceased.
First Amended Nitrogen Consent Judgment
Citizen Groups reach legal settlement with NYC and State to clean up Jamaica Bay
Metropolitan Water Reclamation District Suit 05-03-11
NRDC, Prairie Rivers Network and Sierra Club filed suit against the Metropolitan Water Reclamation District over a plume of water pollution impacts that stretches from Chicago to the Gulf of Mexico. The complaint is available online.
Report of the IUCN/NRDC Workshop to Identify Areas of Ecological and Biological Significance or Vulnerability in the Arctic Marine Environment
Prepared by Lisa Speer and Thomas L. Laughlin, November 2-4, 2010. This report presents the findings of an international workshop held at the Scripps Institution of Oceanography in November, 2010 to identify ecologically important and/or vulnerable areas in the Arctic marine environment that should be considered for protection as the ice melts and industrial activity surges in this fragile ocean.
Group letter to Gov Cuomo, 3/29/11
41-group sign-on letter calling on Cuomo not to rush out revised environmental impact statement
Metropolitan Water Reclamation District Suit 03-01-11
NRDC, Prairie Rivers Network and Sierra Club filed a 60-day letter notifying the Metropolitan Water Reclamation District of intent to sue over a plume of water pollution impacts that stretch from Chicago to the Gulf of Mexico. The final Notice and its attachments (which include correspondences related to the issue and a photo of algae mats on Chicago waterways) are available online.
Letter from NY State Department of Environmental Conservation to Robert Sussman, EPA (12/2/10)
A letter from the deputy chief of New York state's environmental agency, calling on EPA to adopt strong standards for Phase 2 of the Hudson River PCB cleanup.
Letter from NRDC, et al. to Robert Sussman, EPA (12/1/10)
A letter from NRDC and its coalition partners, calling on EPA to adopt strong standards for Phase 2 of the Hudson River PCB cleanup.
Draft Hudson River PCBs Phase 2 cleanup standards – GE mark-up of EPA draft (11/17/10)
This is a document obtained from EPA under the Freedom of Information Act, reflected GE's proposals, as of mid-November 2010, for cleanup standards for the final phase of the Hudson River PCBs cleanup.
NRDC & Other Group Comment Letter to California State Water Board on Proposed Amendment to Once-Through Cooling Policy, November 19, 2010
Comments of NRDC and 21 other groups to California State Water Board OTC Policy Amendment, November 19, 2010
PCB Coalition Letter to Lisa Jackson re: Hudson River PCBs Superfund Site
Follow-up letter to the October 8, 2010 letter, in which we urged EPA to reject GE's request to retain, for another year, the right to abandon the historic cleanup of the Hudson River under EPA's 2006 settlement with GE. We also emphasize that EPA must also ensure the Phase 2 of the cleanup proceeds to completion using sound science, and in compliance with the 2002 Record of Decision.
2010 Report: U.S. Implementation of the Water for the Poor Act
Billions of people lack access to clean water and safe sanitation which has catastrophic consequences for human health and well-being. Diarrhea caused by unsafe water and sanitation kills more children under 5 per year than HIV/AIDS, malaria, and measles combined. The good news is that we have the tools to solve this global crisis. In 2005 the Water for the Poor Act took a historic step calling for bold U.S. action to bring clean water and sanitation to the world. This November 2010 report provides a comprehensive assessment of the steps the U.S. government still needs to take to protect human health and the environment.
Re-Envisioning the Chicago River Technical Document and Appendix
NRDC commissioned an engineering evaluation of the Chicago Area Waterway System to evaluate if and where physical barriers could be erected to impede the movement of Asian carp and other invasive species while also addressing flooding and other issues associated with the aging water system. This document is the technical analysis conducted in partnership with Shaw Environmental.
Petition to DC Water to Reexamine the Long Term Control Plan for Combined Sewer Overflows
In 2010, NRDC joined with other DC-area advocates to petition the District of Columbia Water and Sewer Authority to reexamine the District's Long Term Control Plan, which sets out a schedule for the construction of huge underground tunnels to capture and prevent combined sewer overflows. The petition asked DC Water to examine how green infrastructure could be used to (1) ensure that required pollution reductions would be achieved in light of climate change impacts and expected increases in extreme storm events, (2) update the design for the Potomac and Rock Creek tunnels, and (3) obtain environmental and economic benefits that are not available through the use of hard infrastructure alone. Since the petition was filed, DC Water has proposed to modify its plan to incorporate more green infrastructure, though its proposal would entail project delays of several years beyond the current schedule. This proposal will be reviewed by the U.S. EPA, the courts, and the public.
Nutrient Guide for the States of the Mississippi River
A "how to" guide for citizen water advocates to use in fighting Mississippi River nutrient pollution from wastewater treatment plants.
NRDC and Gulf Coast Community Letter to Department of Labor
Letter requests U.S. Department of Labor to take specific steps to protect the health of fishermen and workers working in oil-contaminated areas post BP oil spill.
The Economic Value of Florida's Ocean Resources
Florida’s economic health depends on functioning and resilient ocean and coastal ecosystems. But our marine resources must be protected and rebuilt so that they can continue to provide the services we depend on well into the future.
Statement Before the New York City Water Board, May 7, 2010
Statement from Eric Goldstein, New York City Environment Director (NRDC), before the New York City Water Board on increased water rate proposals.
The Economic Value of the Gulf of Mexico's Ocean Resources
The Gulf of Mexico’s economic health depends on functioning and resilient ocean and coastal ecosystems. But these marine resources are threatened by the growing Deepwater Horizon oil slick. Our marine resources must be protected so that they can continue to provide the services we depend on well into the future.
NRDC Comments on the Draft Proposed Outer Continental Shelf (OCS) Oil and Gas Leasing Program, 2010-2015, (January, 2009)
This letter from September 21, 2009, to the Minerals Management Service (MMS) of the Department of Interior (the Department, Interior, or DOI), comments on the Draft Proposed Outer Continental Shelf (OCS) Oil and Gas Leasing Program, 2010-2015.
Letter to EPA Regional Administrator Judith Enck, March 4, 2010
Letter to EPA Regional Administrator Judith Enck, calling on the agency to ensure that the total maximum daily load (TMDL) under development for discharges of pathogens to New York/New Jersey Harbor protects public health and the environment.
Rebuilding U.S. Fisheries
Efforts to protect and rebuild America’s ocean fish populations are working. Rebounding fish populations create jobs, support coastal economies, repair damaged marine ecosystems, provide increased recreational fishing opportunities and bring back fresh, local seafood. The benefits of ending overfishing and rebuilding depleted fish populations are far-reaching, and the cost of further delay would be significant.
Protecting the Great Lakes: Keeping ballast water pollution out of New York
NRDC argued on behalf of New York’s aggressive new state law to keep invasive species out of the Great Lakes by putting limitations on the dumping of ballast water from cargo ships. The Appellate Division of the Supreme Court of New York in Albany sided with NRDC and NWF when they intervened in the Port of Oswego Authority vs. Grainis case.
Letter to EPA concerning Everglades mining, dated August 10, 2009
The Natural Resources Defense Council ("NRDC"), the Sierra Club, and the National Parks Conservation Association ("NPCA") write concerning proposed limestone mining in what mining companies have dubbed the "Lake Belt" area of Miami Dade County.
Asian Carp Comments
NRDC and a consortium of NGOs submitted these comments to the Army Corps of Engineers regarding efforts to keep invasive Asian carp out of the Great Lakes. The groups feel that the electric barrier that is the sole barrier has already been proven insufficient and more aggressive measures (outlined in the document) need to be taken.
Photos of Ghost Fleet
Photos taken during January 2009 NRDC inspection of Ghost Fleet
- wat_09111705a.pdf Photo rusty deck of Ghost Fleet ship
- wat_09111705b.pdf Photo of paint flaking off hull of Ghost Fleet ship
- wat_09111705c.pdf Photo of large pieces of paint flaking off hull of Ghost Fleet ship
Plaintiffs' Reply in Support of Motion for Partial Summary Judgment of Liability
Submitted by Michael Wall to U.S. District Court for the Eastern District of California in Arc Ecology, et al. v. United States Maritime Administration, et al., Case No. 2:07-cv-2320, Oct. 10, 2009
Plaintiffs' Brief In Opposition to Defendants’ Motion for Partial Summary Judgment
Submitted by Michael Wall to U.S. District Court for the Eastern District of California in Arc Ecology, et al. v. United States Maritime Administration, et al., Case No. 2:07-cv-2320, Sept. 29, 2009
Plaintiffs' Opening Brief in Support of Motion for Partial Summary Judgment of Liability
Submitted by Michael Wall to U.S. District Court for the Eastern District of California in Arc Ecology, et al. v. United States Maritime Administration, et al., Case No. 2:07-cv-2320, Sept. 15, 2009
Support Letter for SB1 7x, as Introduced on October 23, 2009
A package of water policy bills that represents the most ambitious and comprehensive approach to state water management in more than a quarter century
Letter in support of the FRAC Act to regulate hydraulic fracturing under the Safe Drinking Water Act , signed by 160 national, regional, state, and local organizations
A September, 2009 letter signed by 160 national, regional, state and local organizations, including conservation, faith, sportsmen and community organizations, urging members of Congress to co-sponsor S. 1215/ H.R. 2766, the Fracturing Responsibility and Awareness of Chemicals (FRAC) Act. This important legislation would repeal an exemption in the Safe Drinking Water Act (SDWA) for an oil and gas technique called hydraulic fracturing. It would also require public disclosure of the chemicals used in hydraulic fracturing fluids.
Letter to Army Corps of Engineers Regarding Nationwide Permit for Gregory Canyon Landfill
Joining a diverse coalition of advocates for Native American rights, clean drinking water, and habitat preservation, the Natural Resources Defense Council (NRDC) sent a letter to the U.S. Army Corps of Engineers on September 10, 2009 urging the Corps to reject a request to fast-track its review of a proposed landfill on the banks of the San Luis Rey River. The landfill applicant, Gregory Canyon Ltd., has requested that the Corps forgo full environmental review of a massive 308-acre landfill in unspoiled Gregory Canyon in San Diego County.
The Atlantic Coast's Ancient Submarine Canyons and Seamounts
Nestled into the Atlantic Coast’s continental shelf are a series of deep submarine canyons and soaring seamounts, resembling the canyons and mountains of the American West.
These unique habitats provide critical natural refuges for a diversity of marine life, from colorful deep sea corals to giant sperm whales. Relatively undisturbed for thousands of years, these sanctuaries are now in danger of irreversible damage from advanced fishing technologies and renewed oil and gas exploration.
Investigations of the Feasibility and Benefits of Low-Impact Site Design Practices (LID) for Ventura County and the San Francisco Bay Area
These two analysis were written by Richard R. Horner for NRDC.
NY State Ballast Water Challenge Decision
The New York State Supreme Court, Albany County, dismissed a challenge to permit conditions issued by the New York State Department of Environmental Conservation under the Clean Water Act to control discharges of invasive species from ocean-going vessels into the freshwater ecosystems of the Great Lakes. Shipping interests had argued that the State’s restrictions were both illegal under state law and unconstitutional, largely because they were more strict than those in U.S. EPA’s nationwide Clean Water Act general permit. This decision affirms New York’s decision to join California and Michigan as leaders in setting high standards to regulate biological pollution in vessels’ ballast water. Our litigation challenging U.S. EPA’s general permit, which was issued in the final days of the previous Administration, remains pending in the D.C. Circuit Court of Appeals.
NRDC Comment Letter to the Navy on the Draft Environmental Impact Statement/ Overseas Environmental Impact Statement for the Northwest Training Range Complex
This is a comment letter to the Navy regarding its Draft Environmental Impact Statement for the Northwest Training Range Complex, which encompasses waters off Washington, Oregon and northern California. In sum, the Navy's environmental analysis falls far short of what federal law requires: the Navy fails to explain potential environmental and cumulative impacts, to analyze all reasonable alternatives, and to delineate measures that may actually mitigate harm.
Congressional Letter to Donald C. Winter, Secretary of the Navy dated February 13, 2009
Letter sent by six of the seven Oregon delegates to the Navy requesting an extension of the public comment period for the Navy’s Northwest Training Range Complex. The letter also chastises the Navy for misrepresenting its obligations under a recent settlement agreement with NRDC.
NRDC Asks the Navy to Extend the Public Comment Period for the NW Training Range Complex
The public's opportunity to comment on the NWTRC Draft Environmental Impact Statement has been frustrated by numerous naval web site issues, preventing the public from providing feedback on the NW Training Range Complex.
January 20, 2009 Letter to Michael Payne, National Marine Fisheries Service
NRDC’s final comments regarding the U.S. Navy’s request for authorization to take marine mammals incidental to construction of and training activities in an Undersea Warfare Training Range (“USWTR”) proposed off the coast of northeastern Florida. The letter urges NMFS to deny the Navy’s request because of the proposed site’s proximity to North Atlantic right whale critical habitat and calving grounds. Siting USWTR next to this critical habitat could affect the survival of this critically endangered species.
NRDC Keyport Range Complex Extension Comment Letter
This letter summarizes NRDC's response to a massive naval extension proposed of the Keyport Range Complex in Washington state. The proposed expansion would extend the Quinault Underwater Tracking Range site over 1700 square nautical miles in the Olympic Coast National Marine Sanctuary, a region of extraordinary biological diversity that provides habitat or migratory area for 29 species of marine mammals including eight threatened or endangered species of whales such as the highly endangered Southern Resident killer whales, otters and pinnipeds. NRDC believes the Navy fails to consider a variety of other options, alternatives, and common sense mitigation measures -- some employed by other navies -- that would reduce the impacts.
NRDC's Brief for Respondents in US Supreme Court Sonar Case
On September 8, 2008, NRDC filed its brief in response to the Navy's appeal to the U.S. Supreme Court. The Navy has asked the Court to vacate the preliminary injunction issued and affirmed by the lower federal courts with respect to the Navy's two-year program of sonar training exercises off the Southern California coast.
Federal Appellate Court Upholds Decision to Keep Water Safe From Construction Pollution
Opinion and court order issued by the U.S. Court of Appeals for the Ninth Circuit, affirming the decision from the lower court that EPA has a mandatory duty to set technology-based standards to control water pollution from the construction and development industry.
Testimony of Mae Wu on Bottled Water, September 10, 2008
NRDC Attorney Mae Wu testifies before a Senate subcommittee that the bottled water that millions of Americans drink each day is allowed to contain more toxic chemicals than tap water. Wu calls for testing bottled water and labels that would let the public know what they're actually drinking. September 10, 2008.
UPDATE: July 2013
We are pleased to report recent regulatory action based on NRDC’s advocacy. Since the publication date, the FDA has agreed to more stringently regulate bottled water safety to NRDC’s standards. Our two main recommendations, to test for and ban water sources contaminated with E. coli and to regulate the level of di(2-ethylhexyl)phthalate (DEHP) consistent with EPA regulations, are now in place.
Final Settlement Agreement Outlining U.S. Navy's Use of LFA Sonar in Pacific Ocean, 2008
NRDC v Gutierrez outlines the specific longitude and latitude of the Western Pacific and Hawaii regions permissable for Low Frequency Active (LFA) sonar tests and training exercises conducted by the U.S. Navy. The U.S. Navy is required by federal law to apply for renewal of their LFA permit every five years. NRDC made a similar agreement with the Navy during the 2002 permit process and engaged in negotiations in March and May of 2008 regarding the 2007 permit process.
Hunt's Point Sewage Facility Map
NRDC filed a lawsuit on behalf of Mothers on the Move, a Bronx community group who seek remedy for the foul odors emanating from two sewage facilities in the New York borough's Hunt Point district. The two facilities and the locations of each plaintiff's home are highlighted in the map above. Also shown is the location of Barretto Point Park, the district's main public greenspace, which is sandwiched between the two sewage facilities.
A Common Vision for Environmentally Sustainable Seafood
By identifying a clear and consistent vision for sustainable seafood, NRDC and other members of the Conservation Alliance for Seafood Solutions seek to ensure a long-lasting seafood supply and preserve the health of ocean and freshwater ecosystems.
- wat_08050801a.pdf Common Vision
- wat_08050801b.pdf Frequently Asked Questions
- wat_08050801c.pdf Seafood Facts for North America
- wat_08050801d.pdf Key Impacts of Commonly Farmed Fish
Ninth Circuit Opinion
Appellate Court upholds protections for marine mammals in training with high intensity sonar.
Court Order Granting Preliminary Injunction in LFA Sonar Lawsuit
Opinion and court order, issued by the U.S. District Court for the Northern District of California, granting in part a motion by NRDC and other plaintiffs for a preliminary injunction limiting the U.S. Navy's peacetime use of low frequency sonar, known as Surveillance Towed Array Sensor System ("SURTASS") Low Frequency Active ("LFA"), for training, testing and routine operations.
Court Order Denying Presidential Waivers on Sonar
February 4, 2008 court order reaffirms an injunction issued early in January, requiring the Navy to reduce harm to whales and other marine mammals from sonar training.
Memorandum of Points and Authorities in Opposition to Application to Vacate Preliminary Injunction or to Partially Stay Pending Appeal
Brief filed January 22, 2008 in response to the Bush administration's attempt to exempt the Navy from the National Environmental Policy Act and the Coastal Zone Management Act.
Order for Temporary Partial Stay in NRDC v Winter
Two-page order by Judge Florence-Marie Cooper temporarily staying part of her own injunction requiring the Navy to protect whales from high-intensity sonar during upcoming training exercises in Southern California waters.
Order in NRDC v Winter
This January 16, 2008 order from the Ninth Circuit Court of Appeals sends the Navy's sonar appeal back to the trial court where the injunction originated.
Sonar Injunction in SOCAL Naval Exercises
This January 3, 2008 injunction by a federal district court acting on remand from the Ninth Circuit Court of Appeals, orders the Navy to implement a series of mitigation measures to protect marine mammals from harm caused by mid-frequency sonar, which the Nanvy plans to use during nearly a dozen exercises scheduled off of Southern California in the coming months.
NRDC Policy Statement on the Cosco Busan Oil Spill in San Francisco Bay
The November 7 oil spill in San Francisco Bay is a tragic reminder of the fragility of our coastal ecosystems as well as the risks of relying on fossil fuels. This Novemebr 17, 2007 statement contains NRDC's recommendations for oil spills in California.
Court Order from the Ninth Circuit Court of Appeals Limiting Sonar Use Off Southern California
The federal appeals court ordered the U.S. Navy not to use a dangerous form of high-intensity sonar in its future training exercises off Southern California until serious questions over likely harm to marine mammals can be resolved.
The 35th Anniversary of the Clean Water Act: Successes and Future Challenges
Testimony of Peter Lehner, Executive Director, Natural Resources Defense Council, before the Transportation and Infrastructure Committee, House of Representatives on October 18, 2007.
Growing Cooler: The Evidence on Urban Development and Climate Change
Meeting the growing demand for conveniently located homes in walkable neighborhoods could significantly reduce the growth in the number of miles Americans drive, shrinking the nation's carbon footprint while giving people more housing choices, according to a team of leading urban planning researchers. In a comprehensive review of dozens of studies, published by the Urban Land Institute, the researchers conclude that urban development is both a key contributor to climate change and an essential factor in combating it.
NRDC v. Johnson, Order Granting Motion for Judgment on the Pleadings
Court order ruling in NRDC's favor that EPA has failed to published new or revised water quality criteria by the October 2005 deadline established in the BEACH Act.
Suit Against the U.S. Navy's Rim of the Pacific (RIMPAC) Training Exercise in Hawaii
Filed June 28, 2006 in U.S. District Court against The U.S. Navy and National Marine Fisheries Service
The U.S. Navy's Rim of the Pacific (RIMPAC) Training Exercise Poses Significant Danger to Hawaii's Environment and Marine Life
Letter to NMFS Re: Proposed Incidental Take Authorization for the U.S. Navy's Rim of the Pacific (RIMPAC) Training Exercise, May 24, 2006
Trash Impairs the Anacostia Watershed, 24 Groups Ask Maryland Authorities to Take Action
Letter to Maryland Department of the Environment, March 1, 2006
Time to Demonstrate Commitment to a Coordinated, Comprehensive National Ocean Policy
This September 17, 2004, letter from NRDC executive director Frances Beinecke to President Bush urges the president to act quickly on the U.S. Commission on Ocean Policy's call to restore our nation's ocean health.