FWQC Comments on Draft EPA-USGS Technical Report Jun 17, 2016 Comment Letters Agency: U.S. Environmental Protection Agency Subject: Comments of Federal Water Quality Coalition on Draft EPA-USGS Technical Report: Protecting Aquatic Life from Effects of Hydrologic Alteration, Docket ID No. EPA-HQ-OW-2015-0335 Letter excerpt: FWQC member entities or their members own and operate facilitates located throughout the country. Those facilities operation pursuant to permits that impose control requirements with respect to wastewater discharges. The flow targets and other regulatory actions recommended in the Draft Report would impose new control requirements, and substantial compliance costs, for the operations of FWQC members. The FWQC therefore has a direct interest in the topics covered in the Draft Report. We have serious concerns regarding the Draft Report, as well as concerning the actions of EPA and USGS in conceiving and developing the Draft Report. As in initial matter, we are concerned with how the document is being characterized by the agencies. It is described as a “Technical Report,” but that is simply not accurate. The document delves extensively into policy and legal issues. It gives strong direction to States as to regulatory actions that they should be taking, and it details the legal basis that the Agency contends provides authority for States to take these action, under the Clean Water Act. That is not just a “Technical Report.” Download FWQC’s comment letter
