Garrett Jansma
- Indexed articles, last 90 days
- 5
- Latest publication
- Jul 27, 2026
- Outlet visibility, for natlawreview.com
- Top 1M sites
- Earliest in this view
- Jul 6, 2026
Latest articles
El Niño Is Coming- What California Industrial Facilities Need to Know About Stormwater Compliance (opens the original)
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In the middle of a dry California summer, stormwater runoff feels like the furthest thing from anyone’s mind. Yet for industrial facilities under the IGP, now is the time to prepare for what’s shaping up to be a wet El Niño year. According to NOAA’s Climate Prediction Center, El Niño is strengthening and, in NOAA’s assessment, carries a 97% chance of persisting through early spring 2027, with an 81% probability of a very strong event during October through December 2026. Southern California typi
Did CCSF Actually Change Anything? Why Citizen-Suit Plaintiffs Appear to be Enforcing Receiving Water Violations as if the Supreme Court Never Ruled, and What Comes Next (opens the original)
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In March 2025, the Supreme Court handed industrial dischargers what looked like a landmark victory. In City and County of San Francisco v. EPA, the Court held that “end-result” provisions in NPDES permits (provisions that make a permittee responsible for the quality of its receiving waters rather than spelling out what the permittee must do) exceed EPA’s authority under the Clean Water Act. The decision reversed the Ninth Circuit, rejected decades of EPA permitting practice, and appeared to pull
The 60-Day Notice- What It Is, What It Means, and What to Do When You Get One (opens the original)
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If you operate an industrial facility in California, there is a letter you never want to receive but increasingly might. It is called a “60-Day Notice of Violation and Intent to File Suit,” and it is the opening move in a citizen enforcement action under Section 505 of the Clean Water Act. A 60-Day Notice (sometimes called a Notice of Intent or “NOI”) is a formal letter from an environmental organization or individual notifying your company that it has violated the Clean Water Act at, and that t
The Environmental Plaintiffs: A Guide to the Organizations Filing Stormwater Citizen Suits in California (opens the original)
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If you operate an industrial facility in California, it helps to know who might be on the other side of a 60-Day Notice. Stormwater citizen suits are not filed by government agencies; they are brought by private environmental organizations using the citizen enforcement provision of the Clean Water Act, 33 U.S.C. § 1365. In California, a relatively small number of organizations and their counsel account for the majority of these cases. The most visible plaintiffs in California stormwater enforcem
Strict Liability Under the CWA: What It Means for Industrial Stormwater Dischargers (opens the original)
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If you are an industrial facility operator in California, there is a legal reality about the Clean Water Act that catches many facility operators off guard: liability under the CWA is strict. That means your good faith, your reasonable efforts, and your lack of intent to pollute are all irrelevant to the question of whether you violated the law. The Clean Water Act prohibits the discharge of any pollutant from a point source into waters of the United States unless authorized by an NPDES permit.
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