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.
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