Reply to ADEM's response to EPA Petition

On January 14, 2010, Petitioners representing 14 organizations and hundreds of citizens of the State of Alabama submitted a petition to the Administrator of the United States Environment Protection Agency for to remove the authority of the Alabama Department of Environmental Management over the state's water pollution permitting program because it does not comply with the requirements of the Clean Water Act.

The Alabama Department of Environmental Management filed a response to the Petition on April 8, 2010. The Department’s response purports to address each of the 26 grounds presented in the Petition. In reality, ADEM’s response serves only to obfuscate and misdirect rather than provide a serious discussion of the numerous, well-documented deficiencies that the Petition identifies in the State’s NPDES program. Petitioners submit this reply as an attempt to clarify any confusion created by ADEM’s response as well as to address the Department’s unfounded allegations of impropriety and deceit.

• Read the cover letter
• Read the reply to ADEM's response
• View the exhibits

• Exhibit A-3.pdf

• Exhibit B-59.pdf

• Exhibit B-60.pdf

• Exhibit B-61.pdf

• Exhibit B-62.pdf

• Exhibit B-63.pdf

• Exhibit B-64.pdf

• Exhibit B-65.pdf

• Exhibit B-66.pdf

• Exhibit B-67.pdf

• Exhibit B-68.pdf

• Exhibit B-69.pdf

• Exhibit B-70.pdf

• Exhibit B-71.pdf

• Exhibit B-72.pdf

• Exhibit B-73.pdf

• Exhibit B-74.pdf

• Exhibit B-75.pdf

• Exhibit B-76.pdf

• Exhibit B-77.pdf

• Exhibit B-78.pdf

• Exhibit B-79.pdf

• Exhibit B-80.pdf

• Exhibit B-81.pdf

• Exhibit B-82.pdf

• Exhibit B-83.pdf

• Exhibit B-84.pdf

• Exhibit B-85.pdf

• Exhibit B-86.pdf

• Exhibit B-87.pdf

• Exhibit B-88.pdf

• Exhibit B-89.pdf

• Exhibit B-90.pdf

• Exhibit B-91.pdf

• Exhibit B-92.pdf

• Exhibit B-93.pdf

• Exhibit B-94.pdf

• Exhibit B-95.pdf

• Exhibit E-2.pdf

• Exhibit G-10.pdf

• Exhibit G-11.pdf

• Exhibit I-58.pdf

• Exhibit J-6.pdf

• Exhibit J-7.pdf

• Exhibit K-6.pdf

• Exhibit K-7.pdf

• Exhibit K-8.pdf

• Exhibit K-9.pdf

• Exhibit K-10.pdf

• Exhibit K-11.pdf

• Exhibit K-12.pdf

• Exhibit K-13.pdf

• Exhibit L-6.pdf

• Exhibit L-7.pdf

• Exhibit L-8.pdf

• Exhibit L-9.pdf

• Exhibit P-1.pdf

• Exhibit P-2.pdf

• Exhibit S-9.pdf

• Exhibit S-10.pdf

• Exhibit S-11.pdf

• Exhibit S-12.pdf

• Exhibit Z-1.pdf