Comments on U.S. EPA Clean Water Act Coverage of “Discharges of Pollutants” May 30, 2018 Comment Letters Agency: U.S. Environmental Protection Agency Subject: U.S. Environmental Protection Agency Request for Comment on Clean Water Act Coverage of “Discharges of Pollutants” via a Direct Hydrologic Connection to Surface Water, Docket ID No. EPA-HQ-OW-2018-0063 Letter excerpt: ACWA appreciates this opportunity to comment on “Clean Water Act Coverage of ‘Discharges of Pollutants’ via a Direct Hydrological Connection to Surface Waters” (EPA-HQ-OW-2018-0063). Regulatory clarity is sorely lacking in the groundwater context. ACWA urges EPA to engage in stakeholder outreach and conduct a formal notice-and-comment rulemaking process. ACWA requests EPA clarify that water re-use facilities, stormwater management basins, groundwater recharge basins, constructed wetlands and similar water and wastewater infrastructure do not require NPDES permits for their potential subsurface connection to “waters of the United States.” These projects pose no threat to the nation’s waters and provide significant environmental benefits. Requiring additional NPDES permits for these projects would significantly hamper water management in the western United States. Download comment letter
