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.

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