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Petition filed to Reduce Nutrient Pollution in Ohio River

On behalf of the Mississippi River Collaborative, Sierra Club and other clients, I was one of the major drafters of a petition to U.S. EPA that was filed December 16, 2020. The petition filed under Section 4 of the Administrative Procedure Act, 5 U.S.C. § 553(e), asks that EPA use its powers under 303(c)(4)(B) and 303(d)(2) of the Clean Water Act, 33 U.S.C.§1313(c)(4)(B),(d)(2), to establish numeric standards and TMDLs that will serve to protect the designated uses of Ohio River waters for aquatic life, recreation, fish consumption and drinking water by controlling N and P pollution. EPA should adopt numeric water quality standards for N and P for all water bodies in all states in the Ohio River Basin for which numeric water quality standards controlling N and P pollution have not yet been established. At a minimum, EPA should establish protective water quality standards to control N and P pollution in the mainstem Ohio River.

Further, EPA should establish TMDLs for N and P for the Ohio River and for each Ohio River tributary that fails to meet the numeric standards that should be set by U.S. EPA.

A copy of the Sierra Club alert regarding the petition appears at

I plan to post the petition itself on this website as soon as I figure out how to do so.


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