Petition of the day

Issues: (1) Whether the Environmental Protection Agency’s Water Transfers Rule conflicts with the plain meaning of the Clear Water Act by concluding that a water transfer’s introduction of pollutants to a navigable water body is not an “addition of any pollutant to navigable waters” within the meaning of the Act; and (2) whether the EPA may justify the Water Transfers Rule on the basis of perceived costs and benefits caused by the Act’s permitting process, when it expressly declined to conduct any actual assessment of the costs or benefits of permitting.