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Kingsfield · Research · Environmental & ESG

Is it illegal to discharge a pollutant into navigable waters without a permit under the Clean Water Act?

Published 2026-06-23 · U.S. federal law

The Clean Water Act prohibits the discharge of any pollutant by any person into navigable waters except in compliance with the Act, principally through an NPDES permit under 33 U.S.C. § 1342.

The answer

The prohibition

33 U.S.C. § 1311(a) makes the discharge of any pollutant by any person unlawful except as in compliance with that section and other listed sections of the Act. The prohibition is the structural baseline of the CWA: discharge is forbidden unless an exception authorizes it.

The permit exception

The principal lawful path is a permit. Section 1342 authorizes the Administrator to issue an NPDES permit for the discharge of any pollutant, notwithstanding the section 1311 prohibition, on conditions that the discharge will meet applicable requirements.

The judged input

What the AI drafted

Submitted to the judge

This is an excerpt from a draft environmental-compliance memo — the kind of work product a lawyer generates with a legal-AI drafting tool, then has to stand behind. Kingsfield does not write it; it rules on the citations the model put in it. This draft cites three authorities; one of them is wrong.

AI draft excerpt — environmental-compliance memo
The Company discharges process wastewater to a navigable water and must confirm its coverage before continuing operations. Under 33 U.S.C. § 1311(a), the discharge of any pollutant by any person is unlawful except in compliance with the Act. The lawful path is an NPDES permit, which 33 U.S.C. § 1342 authorizes the Administrator to issue notwithstanding the section 1311 prohibition. The baseline prohibition on unpermitted discharges is set by the citizen-suit provision at 33 U.S.C. § 1365.

The judge ruled on every citation as the draft used it — it accepted 33 U.S.C. § 1311(a) and 33 U.S.C. § 1342 and rejected 33 U.S.C. § 1365. Here is why.

The verdict

How Kingsfield ruled

Ruled 2026-06-23

Each citation in the draft above was submitted to the Kingsfield judge and ruled against the primary-law corpus — Accept, Reject, or Inconclusive, per citation. These are live verdicts, not editorial. Each card shows the claim the draft made and the verbatim authority the verdict was rendered against.

Accept33 U.S.C. § 1311(a)

The draft claimed: Except as in compliance with that section and other listed sections of the Act, the discharge of any pollutant by any person is unlawful.

“§ 1311(a) Except as in compliance with this section and sections 1312, 1316, 1317, 1328, 1342, and 1344 of this title, the discharge of any pollutant by any person shall be unlawful.”

Cite found; proposition supported by the cited text.

Accept33 U.S.C. § 1342

The draft claimed: The Administrator may issue a permit for the discharge of any pollutant, notwithstanding section 1311, upon condition that the discharge will meet applicable requirements of the Act.

“§ 1342 At any time after the promulgation of the guidelines required by subsection (i)(2) of section 1314 of this title , the Governor of each State desiring to administer its own permit program for discharges into navigable waters within its jurisdiction may submit to the Administrator a full and complete description of the program it proposes to…”

Cite found; proposition supported by the cited text.

Reject33 U.S.C. § 1365

The draft claimed: Section 1365 is the provision that prohibits the unpermitted discharge of a pollutant into navigable waters.

Cite found, but the cited text does not support the claim. 33 U.S.C. 1365 is the CWA citizen-suit provision, authorizing private civil actions against violators; the substantive prohibition on discharging a pollutant is at 33 U.S.C. 1311(a). Regenerate with the correct authority.

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Kingsfield rules on every citation, quote, and proposition your AI produces, against the primary law we cover. Accept, Reject, or Inconclusive, per citation, with a signed Audit Capsule.

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This page is legal information, not legal advice, and does not create an attorney-client relationship. The draft shown is an illustration of a typical AI answer; verdicts reflect the cited authority in the Kingsfield corpus as of the ruling date shown above.

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v0.9.4 · 2026.05.26kingsfield.ai