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Water Reuse Action Plan

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U.S. Chamber of Commerce filings
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U.S. Chamber of Commerce filed 1 comment on this docket between Dec 20, 2019 and Dec 20, 2019. 38 other organizations filed here. The comment window closed 2416d ago.

What U.S. Chamber of Commerce filed (1)

Dec 20, 2019· Comment submitted by Chuck Chaitovitz, Vice President, Environmental Affairs & Sustainability, U.S. Chamber of Commerce Business Task Force on Water Policy· EPA-HQ-OW-2019-0174-0148

Dear Assistant Administrator Ross: RE: Comments on the National Water Reuse Action Plan (84 FR 48612, EPA-HQ-OW-2019-0174), from the U.S. Chamber Business Task Force on Water Policy The U.S. Chamber of Commerce Business Task Force on Water Policy, composed of member companies, state and local chambers, and trade associations, has identified policies that support water reuse and recycling innovation among its key priorities. Water reuse, especially in water scarce regions to augment water supply and as a solution for stormwater challenges, is a viable option to meet water quality and quantity needs for businesses and consumers. The task force's input into the National Water Reuse Action Plan (the draft plan) public comment period follows: 1) Make a more direct connection between the barriers to reuse, especially regulatory inconsistency, and solutions. 2) Underscore that water reuse is one tool in the water sustainability toolbox. 3) Consider potential unintended consequences of narrow water reuse. 4) Provide an explicit role for the private sector. 5) Offer additional flexibility for the private sector to meet water quality requirements. The draft plan should add MS4 permitting and off-site, alternative compliance for stormwater management to the informational materials developed for discharge permitting, including specific suggestions for flexible ways to achieve permit limits. EPA should account for variability in industrial processes and build on existing frameworks used in other industries to set appropriate standards. oThe Chamber understands that the Johnson Foundation at Wingspread is proposing to convene stakeholders on stormwater reuse issues. The business community should have at least two seats at the table. oAn important element of the fit-for-purpose discussion and potential sources of water for reuse should include specific workstreams for industrial reuse. Member companies have identified challenges they face to implement reuse projects including knowledge gaps, especially around fit-for-purpose; lack of cost information; and technology applications. Consideration should be given to developing a risk-based framework to determine the return on investment and feasibility of such reuse projects. oWe should continue treating produced water as a potentially beneficial addition to the nation's water supply. Relying on the well-regarded 2019 Ground Water Protection Council Report, the Plan meticulously highlights regulations, current practices, challenges, and research needs facing the issue of managing produced water effectively. The draft plan supports EPA completing its Study of Oil and Gas Extraction Wastewater Management, which will inform EPA's regulatory and nonregulatory approaches for the management of produced water. oThe draft plan calls for identifying and filling science and technology gaps and needs that inhibit greater consideration of off-field use of treated produced water, as well as leveraging the U.S. Department of Energy's water security grand challenge to promote technological advancements in brine management. The plan, once finalized, will play an essential role in supporting EPA's overall efforts as it considers environmentally beneficial pathways for fit-for-purpose reuse of treated produced water. Disposal via underground injection wells would likely remain a key method of disposal, which should not preclude other water management options for beneficial use of treated produced water that are fit-for-purpose, protect receiving waters and the environment, and foster innovation in conservation and protection of water resources. 6) Identify funding for technology innovation, including stormwater and green infrastructure finance needs and opportunities. . 7) Catalyze the skills and competencies of a new reuse-focused water workforce. 8) Engage international leaders to share reuse experiences. The Chamber recommends that EPA continue to cooperate with leading organizations and coun…

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Abstract

On February 27, 2019, David Ross, the U.S. Environmental Protection Agency’s (EPA’s) Assistant Administrator for Water, announced that the Agency will facilitate development of a Water Reuse Action Plan (WRAP) that will seek to better integrate federal policy and leverage the expertise of both industry and government to ensure the effective use of the Nation’s water resources. A draft of the WRAP is scheduled for release and public review in September 2019 at the Annual WateReuse Symposium in San Diego. The EPA has opened this public docket to collect input and ideas that will inform development of the WRAP. The EPA is also posting a document entitled Discussion Framework for Development of a Draft Water Reuse Action Plan (“Discussion Framework”) that provides background, context, and details on development of the WRAP. The Water Reuse Action Plan will seek to foster water reuse as an important component of integrated water resource management. The actions are part of a larger effort by the Administration to better coordinate and focus taxpayer resources on some of the Nation’s most pressing water resource challenges, including ensuring water availability and mitigating the risks posed by droughts. The EPA is working closely with the Department of the Interior, the Department of Agriculture, the Department of Energy, and other federal partners, as well as facilitating discussions among state, tribal, and water sector stakeholders and forming new partnerships to develop and deploy the plan. The EPA will not prepare a formal response to comments. Rather, this docket is intended to create an accessible forum for public input. Nonetheless, the EPA will review all comments received to help inform development of the draft Water Reuse Action Plan. Please submit comments by July 1, 2019 11:59 PM. For additional details please also visit: https://www.epa.gov/waterreuse/water-reuse-action-plan.

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Co-filers (38)

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