feature in Waterkeeper Alliance et al. v. EPA (2005). Based on that case, decided by the United States Court of Appeals for the Second Circuit, the EPA created its 2008 CAFO Rule. The rule states that the CWA specifically exempts agricultural storm water runoff from being considered a point source, but based on the court's decision in the Waterkeeper case, EPA may treat land applications of excessive amounts of manure as a point source. While in general agricultural storm water runoff from CAFOs is a nonpoint source, CAFOs may end up requiring an NPDES permit. Clean Water Action Plans There have been two "Clean Water Action Plans" offered by federal authorities that would affect NPS water pollution. They are both executive orders, not legislation from Congress. The first was issued by President Bill Clinton in 1998. The second, and more recent strategy was issued by Obama Administration in 2009. Both plans provided funding and guidance to address NPS water pollution. Coastal Zone Management Act The Coastal Zone Management Act (CZMA) was passed in 1972 and provides for the management of the nation's coast lands and the Great Lakes. When Congress reauthorized the CZMA in 1990, it identified NPS water pollution as a significant factor in the degradation of coastal waters. To address NPS water pollution in coastal areas, the 1990 amendments to the CZMA created the Coastal Zone Enhancement Grants (CZEG) Program. The states must submit information on their programs to the Secretary of Commerce and the EPA Administrator, who are in charge of approving the plan. The plan is to be implemented in conjunction with the states NPS water pollution plan under section 319 of the CWA and through changes in the overall coastal zone management program. If a state does not submit an approved program, the state may lose a percentage of the grant money provided under the CZMA and under section 319 of the CWA. The EPA is also to provide some guidance to states in developing their NPS coastal management plans through the publication of national guidelines on management measures. These management measures must be economically achievable for new and existing NPS water pollution and must reduce pollution to the greatest extent achievable through current BMPs. State & local laws States have primary responsibility for implementing NPS water pollution regulations. Both the CZMA and the CWA direct the states to draft and implement NPS plans, and