Comments

GWPC COMMENTS

The GWPC publishes and submits comments on policy positions for a variety of topics when necessary. Filter and search for previously published GWPC comments below.

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07/2023

State of Louisiana Underground Injection Control Program, Class VI Program Revision Application

The Ground Water Protection Council (GWPC) appreciates the opportunity to provide input on the State of Louisiana’s primacy revision application to U.S. Environmental Protection Agency (EPA) for jurisdiction of the Underground Injection Control (UIC) Class VI injection well program. The GWPC is the association of state agencies administering the UIC Program in the United States. GWPC is the national member association for state UIC Class VI regulatory programs. GWPC has worked closely with the state on programmatic topics over many years as it implemented its current UIC Program. The Louisiana Department of Natural Resources (LDNR) has effectively administered the State of Louisiana’s Program for UIC Well Classes I – V since EPA granted the state primacy in March 1982.
06/2023

Addressing PFAS in the Environment, Advance Notice of Proposed Rulemaking

The Ground Water Protection Council (GWPC) appreciates the opportunity to provide comments and feedback to the U.S. Environmental Protection Agency (EPA) on the Advance Notice of Proposed Rulemaking on Potential Future Designations of Per- and Polyfluoroalkyl Substances (PFAS) as CERCLA Hazardous Substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). GWPC’s comments on the advance notice of proposed rulemaking under CERCLA express the concerns of our state agency members, including anticipated impacts to UIC programs and facilities as well as groundwater quality concerns regarding potential future designation, or designations, of categories of PFAS as hazardous substances.
06/2023

Per- and Polyfluoroalkyl Substances (PFAS) Proposed PFAS National Primary Drinking Water Regulation for Six PFAS

The Ground Water Protection Council (GWPC) appreciates the opportunity to provide comments and feedback to the U.S. Environmental Protection Agency (EPA) on the proposed National Primary Drinking Water Regulation (NPDWR) for six PFAS. The GWPC comments on the proposed rulemaking express the concerns of its state agency members, including anticipated impacts to UIC programs and facilities as well as groundwater quality concerns.
03/2023

Joint Letter to EPA – Lack of Groundwater-Protective Guidance for Stormwater Grant Implementation of Underserved Communities

Joint letter from the GWPC and the National Ground Water Association to U.S. EPA addressing concerns about the neglect of groundwater-protective steps in the US EPA Grant Implementation document on the Sewer Overflow and Stormwater Reuse Municipal Grants program.
09/2022

Comments on the 2022 update to the Hazard Mitigation Assistance (HMA) Program and Policy Guide (formerly 2015 HMA Guidance and Addendum), Docket ID FEMA-2022-0023

The Ground Water Protection Council (GWPC) appreciates the opportunity to provide comments and feedback to the Federal Emergency Management Agency (FEMA) on the 2022 update to the Hazard Mitigation Assistance (HMA) Program and Policy Guide, Document—Federal Register Citation: 87 FR 52016, Page: 52016-52018, Docket ID FEMA-2022-0023. GWPC notes that some types of Aquifer Storage and Recovery (ASR) projects discussed in the guide, would be regulated under the Safe Drinking Water Act UIC Program as Class V injection wells. Our comments are intended to broadly address the ASR related sections of Hazard Mitigation Assistance Program and Policy Guide Hazard Mitigation Grant Program, Hazard Mitigation Grant Program Post Fire, Building Resilient Infrastructure and Communities, and Flood Mitigation Assistance August 2022 – Draft, the FEMA Fact Sheet on Climate Resilient Mitigation Activities Aquifer Storage and Recovery, and the Information for Hazard Mitigation Assistance Reviews JOB AID: AQUIFER STORAGE AND RECOVERY. These comments do not necessarily reflect the individual GWPC member state positions or their concerns.
07/2022

Comments on Proposed Clean Water Act Hazardous Substance Worst Case Discharge Planning Regulations

The Ground Water Protection Council (www.gwpc.org) appreciates the opportunity to provide comments and feedback to the Environmental Protection Agency (EPA) on the proposed changes to 40 CFR Parts 118 and 300. The following comments are intended to broadly address this proposed rule interpretation, but do not necessarily reflect the individual GWPC member state positions or all of their concerns.
01/2021

Comments on EPA Applying the Supreme Court’s County of Maui v. Hawaii Wildlife Fund Decision in the Clean Water Act Section 402 National Pollutant Discharge Elimination System Permit Program

The Ground Water Protection Council (GWPC) provided comments and feedback to the Environmental Protection Agency (EPA) regarding their draft memorandum which will provide guidance to the regulated community and permitting authorities on applying the recent decision of the United States Supreme Court in County of Maui v. Hawaii Wildlife Fund, 140 S. Ct. 1462 (2020), in the Clean Water Act Section 402 National Pollutant Discharge Elimination System (NPDES) permit program for point source discharges that travel through groundwater before reaching waters of the United States. GWPC recognizes that groundwater is not and has never been a jurisdictional water under the definition of waters of the United States. States have full authority over their groundwater resources. Many of our member agencies protect groundwater quality and resources utilizing both federal and state authorities that are outside the regulatory jurisdiction of the CWA.
10/2020

Joint Comments on the USEPA on the Proposed 2020 Financial Capability Assessment for Clean Water Act (CWA) Obligations

The Ground Water Protection Council and the National Ground Water Association jointly provided comments and feedback on the USEPA on the Proposed 2020 Financial Capability Assessment for Clean Water Act (CWA) Obligations. We support funding for communities needing assistance in managing their water resources and for stormwater reuse that may be used as a source of recharge for aquifers as well as supporting the environment. Assessing the financial capability of communities is fundamental to providing financial assistance for adequate needed infrastructure.
02/2019

ASDWA and GWPC Comments on 2018 Farm Bill Implementation (USDA-2019-0001) Federal Register Notice 2/14/19, 84 FR 4041, 2018 Farm Bill Implementation Listening Session

GWPC and ASDWA are the professional associations that represent the collective interests of the nation's state drinking water and ground water programs responsible for implementation of Federal Safe Drinking Water Act regulations and voluntary source water and wellhead protection programs and actions. Our comments address implementation of Farm Bill Section 2503(d), Source Water Protection Through Targeting of Agricultural Practices.
01/2019

Agency Information Collection Activities; Proposals, Submissions, and Approvals: EPA Strategic Plan Information on Source Water Protection

The Association of State Drinking Water Administrators (ASDWA) and the Ground Water Protection Council (GWPC) are pleased to submit the following comments on the proposed Information Collection Request (ICR) on EPA ICR No. 1816.07 (OMB Control No. 2040-0197) for “Agency Information Collection Activities; Proposals, Submissions, and Approvals: EPA Strategic Plan Information on Source Water Protection.” ASDWA and GWPC are the professional associations that represent the collective interests of the nation's state drinking water and ground water programs responsible for implementation of Federal Safe Drinking Water Act regulations and voluntary source water and wellhead protection programs and actions. Collectively, the members of our organizations are responsible for reporting on this EPA strategic plan measure and will be most impacted by this ICR. The following comments are intended to broadly address the proposed rule, but they do not necessarily reflect the concerns of individual states.
05/2018

Comments on 40 CFR Part 122 [EPA–HQ–OW–2018–0063; FRL–9973–41–OW] Clean Water Act Coverage of ‘‘Discharges of Pollutants’’ via a Direct Hydrologic Connection to Surface Water

The Ground Water Protection Council (www.gwpc.org) provided comments and feedback to the EPA regarding the Agency review and potential revisions or clarification to its previous statements concerning the applicability of the CWA NPDES permit program to pollutant discharges from point sources that reach jurisdictional surface waters via groundwater or other subsurface flow that has a direct hydrologic connection to a jurisdictional surface water. The following comments are intended to broadly address this request, but they do not necessarily reflect all of the concerns of individual states.
08/2017

Comments on EPA’s Draft National Water Program Guidance 2018-2019, Publication Number 800D17001

The Ground Water Protection Council (GWPC) provided comments on the draft National Water Program Guidance for 2018-2019.
11/2014

Comments on proposed rule defining Waters of the United States protected under the Clean Water Act (79FR22188)

The Ground Water Protection Council (GWPC) provided comments on the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (Corps) proposed rules defining the scope of waters protected under the Clean Water Act (CWA).
08/2014

Comments on Proposed USDA Forest Service Directive on Groundwater Resource Management

GWPC recognizes the emphasis in this document on working with states. We feel that collaboration and cooperation with the States is necessary for US Forest Service (USFS) to achieve the vision, goals, strategies, and actions set out within the Groundwater Directive for UIC activities. Recognizing that USFS is not authorized to implement the UIC program under the Safe Drinking Water Act and thus does not have the regulatory authority necessary to carry out some of the provision of the directive, our specific comments provide information on how and when USFS can work within the existing UIC regulatory framework administered by US Environment Protection Agency (USEPA) and the delegated states to ensure all applicable UIC authorizations and permits have been issued by the appropriate regulatory authority.