Carriage of Conditionally Permitted Shale Gas Extraction Waste Water in Bulk

November 26, 2013 U.S. Coast Guard Department of Transportation West Building Ground Floor, Room W12-140 1200 New Jersey Ave, SE Washington, DC 20590-0001 RE: Carriage of Conditionally Permitted Shale gas Extraction Waste water in Bulk, Docket ID No. USCG-2013-0915 Dear Sir or Madam, The American Water Works Association (AWWA) is an international, nonprofit, scientific and educational society dedicated to providing total water solutions assuring the effective management of water. Founded in 1881, the Association is the largest organization of water supply professionals in the world. Our membership includes more than 4,000 utilities that supply roughly 80 percent of the nation's drinking water and treat almost half of the nation's wastewater. Our 50,000-plus total membership represents the full spectrum of the water community: public water and wastewater systems, environmental advocates, scientists, academicians, and others who hold a genuine interest in water, our most important resource. AWWA unites the diverse water community to advance public health, safety, the economy, and the environment. Although AWWA does not take a view directly on whether hydraulic fracturing wastewater should or should not be classified as "listed cargo", we do believe that the following safeguards are imperative (in addition to all safeguards that exist for moving materials by barge in general) for the practice of moving shale gas extraction waste water (SGEWW), and how they are addressed should be noted in the policy letter and/or supporting documentation: - The nature of the materials transported should be readily available in order to inform cleanup and notification procedures should a spill occur. - An appropriate emergency response plan should be in place at all times, to assure that should any spill occur (for example, while moving waste from land to the barge) that appropriate containment and cleanup procedures are begun immediately. - In the event of a spill, drinking water facilities downstream of the spill location should be informed of the nature, volume, and contents (even if those contents include proprietary information) of the materials spilled, as well as the remediation efforts underway, so proper treatment and precautionary measures can be taken to protect public health. Thank you for the opportunity to comment on this important proposed policy letter. If you have any questions regarding this correspondence or if AWWA can be of assistance in some other way, please contact me or Adam Carpenter at (202) 326-6126 or acarpenter@awwa.org. Best regards, Thomas W. Curtis Deputy Executive Director