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The American Farm Bureau Federation (AFBF) is a voluntary general farm organization formed in 1919 to protect, promote, and represent American farms’ business, economic, social, and educational interests. It represents more than 6.2 million-member families through member organizations, some located in the 64,000-square mile Chesapeake Bay watershed. The Environmental Protection Agency (EPA) is the federal agency charged with the administration, and enforcement of the Clean Water Act, 33 USC § 1251, et seq., in accordance with the delegations from Congress contained in that statute.
On December 29, 2010, the EPA promulgated the Chesapeake Bay Final Total Maximum Daily Load for Nitrogen, Phosphorous, and Sediment (TMDL). Shortly thereafter, on January 10, 2011, the AFBF sued the EPA, challenging the EPA’s establishment of the Chesapeake Bay TMDL and asking the court to vacate the TMDL. The AFBF alleged that: (1) the EPA lacked authority under the Clean Water Act to promulgate the TMDL; (2) the TMDL is ultra vires; (3) the TMDL is arbitrary and capricious; and (4) the EPA failed to provide adequate public notice and comment, in violation of the APA.
Using the material from Unit 4 and the provided federal district court opinion, explain each of the four arguments the AFBF made in support of its lawsuit challenging the Chesapeake Bay TMDL and whether you find those arguments persuasive. Please limit your essay to 800 – 1200 words.
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