to pollution management. As noted in the order, a single polluter may simultaneously degrade a local environment's air, water, and land. President Nixon noted that a single government entity should be monitoring and mitigating pollution and considering all effects. As relevant to CAFO regulation, the EPA became the main federal authority on CAFO pollution monitoring and mitigation. Congress passed the CWA in 1972 when it reworked the Federal Water Pollution Control Amendments. It specifically defines CAFOs as point source polluters and required operations managers and/or owners to obtain NPDES permits in order to legally discharge wastewater from its facilities. Initial regulations (1970s) The EPA began regulating water pollution discharges from CAFOs following passage of the 1972 CWA. ELGs for feedlot operations were promulgated in 1974, placing emphasis on best available technology in the industry at the time. In 1976 EPA began requiring all CAFOs to be first defined as AFOs. From that point, if the specific AFO met the appropriate criteria, it would then be classified as a CAFO and subject to appropriate regulation. That same year, EPA defined livestock and poultry CAFO facilities and established a specialized permitting program. NPDES permit procedures for CAFOs were also promulgated in 1976. Prior to 1976, size had been the main defining criteria of CAFOs. However, after the 1976 regulations came into effect, the EPA stipulated some exceptions. Operations that were identified as particularly harmful to federal waterways could be classified as CAFOs, even if the facilities' sizes fall under AFOs standards. Additionally, some CAFOs were not required to apply for wastewater discharge permits if they met the two major operational-based exemptions. The first exception applied to operations that discharge wastewater only during a 25-year, 24-hour storm event. (The operation only discharges during a 24-hour rainfall period that occurs once every 25 years or more on average.) The second exception was when operations apply animal waste onto agricultural land. Developments in the 1990s In 1989, the Natural Resources Defense Council and Public Citizen filed a lawsuit against the EPA (and Administrator of the EPA, William Reilly). The plaintiffs claimed the EPA had not complied with the CWA with respect to CAFOs. The lawsuit, Natural Resources Defense Council v. Reilly (D.D.C. 1991), resulted in a court order mandating the EPA update its regulations. They did so in what would become the 2003 Final Rule. In 1995, the EPA released a "Guide Manual on NPDES