Preliminary and Final Effluent Guidelines Program Plan 15 and Supporting Documentation

Dear Assistant Administrator Fox: The U.S, Chamber of Commerce appreciates the opportunity to offer the business community's perspective regarding the Preliminary Effluent Guidelines Program Plan 15. "The Clean Water Act authorizes EPA and states to address emerging contaminants through technology-based effluent limitations using national Effluent Limitation Guidelines (ELG) and Standards or by setting technology-based effluent limits in National Pollutant Discharge Elimination System (NPDES) permits on a case-by-case basis." This science-based process is inherently complex and requires specific discharge limits based on technology-performance standards. Under the Administrative Procedure Act, the Environmental Protection Agency (EPA) has the flexibility to modify the length of the notice and comment period to address such complex issues. The Agency's interest in feedback on new cross-category wastewater pollutant concentration rankings analysis, the status of the preliminary reviews of high-ranking categories, and the capabilities of membranes for industrial wastewater treatment technologies is inherently complex and requires additional time for thoughtful evaluation. We, therefore, urge EPA to extend the comment period by 60 days. This would allow impacted industries to explore the potential costs and gather the necessary data and rationale as companies and communities grapple with public health, environmental, and funding challenges to address emerging contaminants of concern. Please feel free to contact me with questions. Thanks in advance, Chuck