Jun 7, 2019 Joint Comments on Groundwater Interpretive Statement
Re: Comments of the American Petroleum Institute, the American Exploration & Production Council, the Association of Oil Pipe Lines, the Independent Petroleum Association of America, the Domestic Energy Producers Alliance, and the Marcellus Shale Coalition in Response to the Environmental Protection Agency’s Request for Comments on the Interpretative Statement on Application of the Clean Water Act Discharge Elimination System Program to Releases of Pollutants From a Point Source to Groundwater; EPA-HQ-OW-2019-0166.
Dear Sir/Madam:
This letter provides comments from the American Petroleum Institute (“API”), Association of Oil Pipe Lines (“AOPL”), American Exploration & Production Council (“AXPC”), Independent Petroleum Association of America (“IPAA”), Domestic Energy Producers Alliance (“DEPA”), and the Marcellus Shale Coalition (“MSC”) (collectively, “the Associations”), responding to the Environmental Protection Agency’s (“EPA’s” or “The Agency’s”) Request for Comments on the Interpretative Statement on Application of the Clean Water Act (“CWA” or “the Act”) Discharge Elimination System Program to Releases of Pollutants From a Point Source to Groundwater (“Interpretative Statement”).1 The Associations appreciate both EPA’s efforts to provide long overdue clarification on the scope of the CWA’s National Pollution Discharge Elimination System (“NPDES”) program and the Agency’s commitment to pursue that clarity through transparent
stakeholder engagement.
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