Comments: POTW ELG Rule
On behalf of the undersigned organizations, Clean Water Action and the Environmental Integrity Project (EIP), (collectively, Commenters) appreciate this opportunity to submit comments on the Environmental Protection Agency’s (EPA or Agency) proposed Effluent Limitations Guidelines and Standards for the Oil and Gas Extraction Point Source Category, 80 Fed. Reg. 18,557 (hereafter Proposed Rule). Commenters strongly support EPA’s efforts to prevent discharge of unconventional oil and gas (UOG) wastewater to publicly owned treatments works (POTWs). The proposed rule would close a potentially harmful gap in the regulation of UOG discharges by requiring a zero-discharge effluent limitation for new and existing UOG sources. This rule is necessary to prevent UOG facilities from discharging untreatable and harmful wastewater to POTWs. EPA has made the correct decision by proposing a zero-discharge limitation and should maintain this position for the purpose of protecting human and environmental health.
Download the full comments below.