Advocacy

Advocacy in Action

Note: We aim to include all of our advocacy actions (that include documentation) but that is never quite doable! The Actions, and especially the Media section of this page will continually be updated as time permits!  To really follow along, please be sure you are receiving our biweekly emails – quick sign up at THIS LINK.

 

 

2024 Action Items

 

4.8.24- Comments of North Carolina Communities on Listing of Specific PFAS as Hazardous Constituents under the Resource Conservation and Recovery Act

Read Comments of North Carolina Communities on Listing of Specific PFAS as Hazardous Constituents under the Resource Conservation and Recovery Act Here

3.7.24- NC-based Organizations Urge Swift Finalization of PFAS Drinking Water Standards- Letter to President Biden

Read NC-based Organizations Urge Swift Finalization of PFAS Drinking Water Standards – Letter to President Biden Here

2.26.24- Environmental Law & Policy Clinic comments on the General Services Administration (GSA) Acquisition Regulation for Reduction of Single-Use Plastic Packaging

Read ELPC comments on GSA Acquisition Regulation for Reduction of Single-Use Plastic Packaging Here

12.7.23- Farewell to Foam Act Bill Intorduced to Congress

12.7.23- Read the Farewell to Foam Act Bill Introduced to Congress Here

2023 Action Items

 

8.11.23- Final Comments on EPA's ANPRM: Addressing PFAS in the Environment, Docket EPA-HQ-OLEM-2022-0922

Read SELC’s final comments on EPA’s proposal to list additional PFAS as hazardous substances under CERCLA here

5.31.23- Letter to center environmental justice in the finalization of Proposed PFAS National Primary Drinking Water Regulation

Read letter to EPA to center environmental justice in the finalization of its Proposed Per- and Polyfluoroalkyl Substances National Primary Drinking Water Regulation here

5.30.23- Exemptions to Toxic Substances Control Act significant new use notification requirements for inactive PFAS

Read Exemptions to Toxic Substances Control Act significant new use notification requirements for inactive PFAS here

5.30.23- EPA's proposal to regulate PFAS in drinking water

Read Letter supporting EPA’s Drinking Water Standards for PFAS here

3.16.23- Comments on EPA’s proposed National Enforcement and Compliance Initiatives

Read SELC’s comments on EPA’s proposed National Enforcement and Compliance Initiatives here SELC Comments

2.13.23- SELC Comments Regarding Lear Corporation

Read Southern Environmental Law Center Comments Regarding Lear
Corporation, NPDES Permit NC0002305 here

1.13.23-Dana Sargent Second Declaration RE: Chemours Challenge GENX Health Advisory-ONLY Shnitzler Enclosure Inc.

Read CFRW Exec. Director Dana Sargent’s declaration proving to the court that CFRW has vested interest in Chemours’ challenge to the GenX Health Advisory level of 10 ppt.  Good news: the court agreed with our declaration and granted us, and partners, intervention in the case! This is the shorter version of the declaration with all enclosures removed except for the strong community letter from Port City Java business owner Steve Schnitzler Here

2022 Action Items

11.4.22 - PFOS/PFOA/CERCLA Comment Letter

Read the PFOS/PFOA/CERCLA Comment Letter submitted by NC Conservation Network, Clean Cape Fear, Cape Fear River Watch, and NC Sierra Club.

10.10.22 - Comments on Draft National Pollutant Discharge Elimination System Permit NC0002861

Read SELC’s comments, on behalf of CFRW, regarding Draft National Pollutant Discharge Elimination System Permit NC0002861.

6.24.22 - Dana Sargent Comments - Chemours' Draft NPDES Permit No. NC0090042

Check CFRW Executive Director Dana Sargent’s comments on Chemours’ draft NPDES Permit No. NC0090042.

6.24.22 - Supplemental comments on the draft permit for Chemours Outfall 004 (No. NC0090042)

Check our ours and North Carolina Sierra Club’s supplemental comments on Chemours’ draft NPDES Permit No. NC0090042, submitted on behalf of the Southern Environmental Law Center.

5.2.22 - Cape Fear River Watch Comments on Chemours’ draft NPDES Permit No. NC0090042

Check our our comments on Chemours’ draft NPDES Permit No. NC0090042, submitted on behalf of the Southern Environmental Law Center.

3.8.22 - SELC and Cape Fear River Watch Comments on Chemours Four Counties Sampling Plans

In response to a request from the Dpt. of Environmental Quality, Chemours submitted a groundwater sampling plan to test for PFAS in wells of New Hanover, Brunswick, Pender and Columbus Counties. It was wholly inadequate. This week, Southern Environmental Law Center submitted comments on behalf of Cape Fear River Watch noting, “The company’s plan aims to reduce risk to the company rather than the public and should be rejected.”  Read the full comment letter here. 

2021 Action Items

12.2.21 - Concerns About PFAS Testing Strategy and Importance of North Carolina Testing Petition

We signed onto this letter along with more than 100 leaders in environmental and human health across the country. The letter was initiated by the petitioners (including Cape Fear River Watch, NC Black Alliance, Toxic Free NC, Clean Cape Fear, the Center for Environmental Health and Democracy Green) requesting EPA, under TSCA, require Chemours fund toxicity and epidemiological studies on 54 PFAS. 

12.2.21 - Letter to DEQ with updated recommendations on PFAS action.

This letter was submitted to NCDEQ by 10 North Carolina environmental organizations with updated recommendations regarding next steps to be taken relative to PFAS action. 

12.1.21 - Comments on Proposed Permanent Wetland Rules

These comments were submitted by SELC on behalf of American Rivers, Cape Fear River Watch, Carolina Wetlands Association, Catawba Riverkeeper, Coastal Carolina Riverwatch, Dan River Basin Association, Dan Riverkeeper, Good Stewards of Rockingham, Haw River Assembly, MountainTrue, Neuse Riverkeeper, North Carolina Coastal Federation, North Carolina Conservation Network, North Carolina Sierra Club, North Carolina Wildlife Federation, Pamlico-Tar Riverkeeper, Sound Rivers, Waterkeepers Carolina, Winyah Rivers Alliance, and Yadkin Riverkeeper.

11.18.21 - Additional Support for TSCA Section 21 Petition for Testing of Chemours PFAS

Read our letter (along with Center for Environmental Health, Clean Cape Fear, and Toxic Free NC) to EPA Administrator Michael Regan, Re: Additional Support for TSCA Section 21 Petition for Testing of Chemours PFAS

9.27.21 - Comments to the EPA on its proposed reporting and recordkeeping rule for PFAS under Section 8(a)(7) of the TSCA.

Read our comments to the Environmental Protection Agency (EPA) on its proposed reporting and recordkeeping rule for Per- and Polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA).

9.2.21 - Request for Recommendations on Defining “Waters of the United States”

The SELC filed these comments on behalf of CFRW and 84 other organizations to support the Biden administration in restoring strong clean water protections.

8.3.21 - Comments on the 2021 Triennial Review of North Carolina’s Water Quality Standards

We signed on to this letter commenting on the triennial review of North Carolina surface water quality standards.

5.14.21 - Comments Letter on EPA's ANPR for Clean Water Act Effluent Limitations Guidelines and Standards

Read our comments on the United States Environmental Protection Agency’s Advanced Notice of Proposed Rulemaking: Clean
Water Act Effluent Limitations Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category.

6.23.21 - Letter on Analytical Testing Requirements under TSCA

We signed on to this letter about the Development and Submission of Analytical Methods under Toxic Substances Control Act Sections 4 and 8.

3.21 - NCCN's Concerns With Directed Biogas Projects in North Carolina

We endorsed this position paper from North Carolina Conservation Network that outlines their concerns with directed biogas projects in North Carolina. 

3.16.21 - Comments Letter on Groundwater Standards

Read our comments in response to the proposal by the Environmental Management Commission (EMC) to replace an obsolete temporary standard of 2,000 parts per trillion (ppt) for Perfluorooctanoic acid (PFOA), and a default limit of perfluorooctane sulfonate (PFOS) at the
Practical Quantitation Limit (PQL) with a standard of 70 ppt for the sum of PFOS and PFOA.

2.3.21 - Request for Executive Order on Wood Pellet Industry Impacts

This letter was submitted by 28 North Carolina environmental organizations urging Governor Cooper to take executive action to study and
address the environmental and community impacts of the wood pellet industry on the state.

2020 Action Items

12.10.20 - Comments of Public Health. Environmental and Environmental Justice Groups on EPA’s Draft Supplemental Analysis to the Draft Risk Evaluation for 1,4-Dioxane under Section 6(b) of TSCA

Read the full comments here.

11.16.20 - Public Comments - DAQ Hearing on Grady Road Biogas Permit

Click here to read our Riverkeeper Kemp Burdette’s comments on the Grady Road Biogas permit at the Division of Air Quality hearing. 

10.5.20 - Public Comments - NC Science Advisory Board Meeting

Click here to read our Executive Director Dana Sargent’s comments on PFAS regulation at the NC Science Advisory Board Meeting.

10.2.20 - Comments on Corps' Proposal for Year Round Dredging at NC Ports

Read our comments regarding the Corps’ proposal to remove dredging windows at Wilmington Harbor and Morehead City Harbor, submitted on our behalf by the SELC.

8.17.20 - Comments on Chemours' Outfall 003, SELC on behalf of CFRW

https://documentcloud.adobe.com/link/track?uri=urn:aaid:scds:US:6f90c7c7-6061-4dd5-8fb7-8a963c43b7aa

8.13.20 - Chemours Consent Order Next Steps

On behalf of Cape Fear River Watch, the Southern Environmental Law Center today reached agreement on the details of next steps under a consent order with the N.C. Department of Environmental Quality and Chemours that requires the company to stop 99 percent of GenX and other PFAS water pollution from its site into the Cape Fear River, the source of drinking water for Wilmington, Brunswick County, and Pender County. A public comment period will be held on the agreement before it is submitted to the Bladen County Superior Court for approval. If approved by the court, this agreement will be enforceable and amend the consent order the parties finalized in February 2019

7.24.20 - Comments on T.Z. Osborne WWTP Special Order by Consent

Greensboro’s T.Z. Osborne Wastewater Treatment Plant treats wastewater from industrial facilities that use or produce 1,4-dioxane,  but they have not been removing the 1,4-dioxane from the wastewater, instead discharging it directly into the Cape Fear River Basin. Because drinking water utilities cannot remove 1,4-dioxane with conventional treatment, downstream communities are forced to drink water contaminated by Greensboro’s pollution. The U.S. Department of Health and Human Services states that “1,4-dioxane is reasonably anticipated to be a human carcinogen based on sufficient evidence of carcinogenicity from studies in experimental animals.”

A Special Order by Consent (SOC) proposed by the City of Greensboro and DEQ would allow the City to continue dumping 1,4-dioxane into the drinking water of downstream residents, which is an unacceptable practice that must be discontinued. This document contains the comments submitted by the Southern Environmental Law Center on the draft SOC on behalf of Cape Fear River Watch, Haw River Assembly, North Carolina Conservation Network, Center for Environmental Health, North Carolina Coastal Federation, and the North Carolina Chapter of the Sierra Club.

4.2.20 - Comments on Chemours’ Corrective Action Plan

Chemours’ Fayetteville Works plant knowingly contaminated more than 70 square miles, hundreds of drinking water wells, and the river that provides water for more than 300,000 North Carolinians with dangerous chemicals. They then made an astonishing argument—that it should be excused from the clear requirements of the state’s groundwater rules because the harm it caused was too vast. Read our comments on the Corrective Action Plan submitted on our behalf by the Southern Environmental Law Center.

7.28.20 - Lawsuit against Trump Administration's Rollback of NEPA

The Trump Administration’s changes to NEPA – often called the “Magna Carta of environmental laws” – will reduce the public input that has guided major projects for decades, further diminish the voices of communities that have long suffered environmental injustices, and mask the full extent of polluting projects. The SELC filed a lawsuit against the Trump Administration on behalf of 17 environmental organizations, including Cape Fear River Watch. The lawsuit accuses the government of racing through an industry-friendly rewrite of the National Environmental Policy Act by “cutting corners” and discarding decades of rule-making policies that ensure major legal changes are done fairly and transparently. Read the full complaint here

2019 Action Items

12.5.19 - Comments on Draft NPDES Permit

NC DEQ released a Draft National Pollutant Discharge Elimination System Permit to Brunswick County on October 31, 2019. The permit would allow Brunswick County’s Northwest Water Treatment Plant to discharge the PFAS removed from their drinking water into the Cape Fear. The draft permit contained two key problems: 1) Brunswick County did not disclose their planned PFAS discharge, so the public had no means of assessing the amount of PFAS that would be discharged by the county or evaluating the potential threat from the chemicals, and 2) DEQ apparently failed to evaluate alternative methods of treatment or disposal of Brunswick County’s discharge that would remove PFAS.

These comments were submitted by the SELC on behalf of Cape Fear River Watch, Clean Cape Fear, Center for Environmental Health, Haw River Assembly, North Carolina Coastal Federation, North Carolina Conservation Network, Toxic Free NC, and the Cape Fear Group of the Sierra Club.

10.11.19 - Statement for the Wilmington Harbor Navigation Improvement Project

Read these comments, submitted by SELC on behalf of Cape Fear River Watch and others, about the Wilmington Harbor Navigation Improvement Project.

2.26.19 - Chemours Consent Order

Cape Fear River Watch sued the NC Dept. of Environmental Quality (DEQ) for not taking swifter and stronger action, and we sued the polluter, Chemours for violations of the Clean Water Act and the Toxic Substances Control Act. The result was a Consent Order, signed February 26, 2019 by Cape Fear River Watch, NC DEQ and Chemours, which requires the company clean up its site, its emissions and its discharge at an accelerated pace.

With your help, Clean Water is possible.

Cape Fear River Watch  |  617 Surry Street  |  Wilmington, NC 28401  |  Phone: 910.762.5606