WQBELWater Quality-Based Effluent Limits
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The 2013 VGP called for much more relaxed monitoring of WQBELs, and
narrative WQBELs rather than numeric WQBELs, and (3) adopting monitoring
and reporting requirements for WQBELs and TBELs that were inadequate to
capriciously by adopting narrative WQBELs rather than numeric WQBELs.
decision to look no further than the NAS report and set narrative WQBELs
monitoring requirements for WQBELs. (151) The court held that the
monitoring requirements for WQBELs were arbitrary and capricious because
found that whether the vessel was actually in compliance with the WQBELs
for WQBELs. (155) The court denied the petition for review of the
The EPA claimed that the narrative WQBELs set forth in the 2013 VGP