In the 1975 case Environmental Protection Agency (EPA) et al. v. California ex rel. State Water Resources Control Board et al., the Supreme Court ruled that federal facilities are not immune from state water pollution control laws unless there is a clear congressional intent to grant such immunity. The court held that under the Federal Water Pollution Control Act, states have primary responsibility for enforcing their own water quality standards and can impose any limitations necessary to meet those standards on all polluters, including federal installations. This ruling reinforced states' rights in environmental regulation enforcement and clarified that federal agencies must comply with state regulations regarding pollution control.

In the dissenting opinion for the case of Environmental Protection Agency (EPA) et al. v. California ex rel. State Water Resources Control Board et al., Justice William O. Douglas argued that federal installations should comply with state water pollution standards unless there is a direct conflict with specific federal interests or directives, and not merely because compliance would be inconvenient or costly to the Federal Government. He contended that states have primary responsibility for preventing and controlling water pollution under The Federal Water Pollution Control Act Amendments of 1972, which was designed to restore and maintain the integrity of nation's waters by preventing point-source discharges of pollutants into them except as allowed by permits issued pursuant to National Pollutant Discharge Elimination System (NPDES). In his view, this cooperative approach between federal government and states in combating environmental degradation requires EPA’s full cooperation rather than defiance when it comes to meeting state-imposed conditions on pollutant discharge levels from federally-owned facilities.