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 ( 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.

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