When Two Entities Discharge Through The Same Storm Sewer, Each Entity Is Responsible Only For Its Own Discharge.
September 2012
An amicus brief submitted to the U.S. Supreme Court for the Los Angeles County Flood Control District case.

Dry Land Is Not A “Water Of The United States” Regulated By The Clean Water Act.
December 2005
An amicus brief submitted to the U.S. Supreme Court for the Rapanos and Carabell cases.

Why The Consideration Of Economics Required By The California Porter-Cologne Act Is Consistent With The Federal Clean Water Act.
April 2004
An amicus brief submitted to the California Supreme Court for the City of Burbank case.

The Clean Water Act At Thirty: A Failure After All These Years?
Fall 2003
An article published in the American Bar Association journal Natural Resources & Environment.

Resolving Problems With Regulatory Detection Limits.
July 2002
Comments submitted to EPA in response to a proposed regulation on minimum detection limits (“MDLs”).

Problems With Ecoregional Nutrient Criteria For The Arid West.
May 2001
Comments submitted to EPA on recommended nutrient criteria for the Arid West

Resolving Problems With The TMDL Program.
January 2000
Comments submitted to EPA in response to a proposed regulation on TMDLs.

Resolving Problems With Water-Quality Standards.
January 1999
Comments submitted to EPA in response to an advance notice of proposed rulemaking.

When Natural Conditions Prevent Attainment.
August 1991
Comments submitted to EPA in response to draft guidance on modifying water-quality standards.