Providing High Level Input as an Experienced Stakeholder
CWAC’s primary concern is to represent clients with public interest water issues. As we build our client base, we believe it is important to participate in stakeholder meetings and other environmental advocacy meetings. Because our attorney was a fundamental presence in the background of many of the most pressing water issues in New Jersey, we can provide insight and suggestions that otherwise would be absent.
For example, at the Spring 2019 Surface Water Quality Standards Stakeholder Meeting, we provided context for EPA’s thinking on the new Recreational Water Quality Criteria, the regulations that protect swimmer’s health, that no one else present was privy to, our attorney helped negotiate the Criteria with EPA in 2012. At the same meeting, we forcefully opposed Clean Water Act variances, which would allow permittees to not follow the law, because our knowledge of § 303 of the Act allowed us to demonstrate that neither New Jersey DEP nor EPA could waive that section’s specific legal requirements. In this way CWAC helps set the boundaries of debate and assists the broader community in clean water advocacy, even without a specific client.