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EPANonrulemakingEPA-HQ-OW-2019-0166

Interpretive Statement on Application of the Clean Water Act National Pollutant Discharge Elimination System Program to Releases of Pollutants from a Point Source to Groundwater

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National Rural Electric Cooperative Association filings
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National Rural Electric Cooperative Association filed 1 comment on this docket between Jun 17, 2019 and Jun 17, 2019. 45 other organizations filed here. The comment window closed 2608d ago.

What National Rural Electric Cooperative Association filed (1)

Jun 17, 2019· Comment submitted by Dorothy Allen Kellogg, Regulatory Environmental Director, Water and Waste Issues, National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OW-2019-0166-0228

NRECA agrees with and supports EPAs conclusion that the CWA excludes from the NPDES program all releases of pollutants from a point source to groundwater, regardless of a hydrologic connection between the groundwater and jurisdictional surface water. Responding the agencys request for public input regarding what may be needed to provide further clarity and regulatory certainty on the issue NRECA recommends the agency: 1.Socialize broadly the Interpretive Statement by sending copies directly to all EPA Regions and states and posting the Interpretive Statement prominently on the agencys website; 2.Revise statements regarding the relationship between the Coal Combustion Residual (CCR) Rule and CWA NPDES permit requirement to align with the Interpretive Statement; and 3.Initiate public notice-and-comment rulemaking to amend the NPDES regulations to reflect the Interpretative Statement, taking into account Supreme Court proceedings.

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Abstract

The Environmental Protection Agency (EPA) has issued an Interpretative Statement that sets forth the EPA’s interpretation of the Clean Water Act (CWA), National Pollutant Discharge Elimination System (NPDES) permit program’s applicability to releases of pollutants from a point source to groundwater that subsequently migrate or are conveyed by groundwater to jurisdictional surface waters. This Interpretative Statement reflects the EPA’s consideration of the public comments received in response to its February 20, 2018 Federal Register notice. Concurrently with issuing its interpretation of the CWA, the EPA is soliciting additional public input regarding what may be needed to provide further clarity and regulatory certainty on this issue.

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Co-filers (45)

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