Status: The coalition took legal action to block EPA measures, bring the agency to the table to negotiate a solution to a number of problems created by uninformed rule making. Industry avoided unnecessary costs in developing standards while awaiting guidance. The inland maritime industry, proven by independent research to be the cleanest mode of transporting bulk freight, is continuing its leadership as an environmentally friendly segment of the business community.

Issue: Inland maritime businesses came under provisions of the Clean Water Act as a result of a law suit in an unrelated industry. As mobile sources of potential water pollution, marine vessels and paperwork required for associated regulation make a poor fit with the Act. Clean Water Act administrators EPA found themselves with a new industry, a rare case, and an industry they didn’t know and understand. Resulting rules displayed fundamental misunderstandings of the inland marine industry and led to more, rather than less confusion.

We led efforts to understand EPA viewpoints, those of the Congressional committees of jurisdiction and other stakeholders. Channel Design Group organized work teams that reviewed paperwork requirements, defined electronic record storage, created facility training, internal reporting and other functions. We led successful efforts to retard industry standard setting in the absence of EPA guidelines and slow legislative action in order to avoid greater mischief from radical stakeholders.