Nov 14, 2014 IPAA, Western Energy Alliance, and AXPC Joint Comments to the Environmental Protection Agency on its Proposed Rule Defining Waters of the United States Under the Clean Water Act
The following comments to the proposal of April 21, 2014 by the Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (USACE), hereinafter referred to as ”the agencies”, defining the scope of waters protected under the Clean Water Act (CWA), in light of the U.S. Supreme Court cases in U.S. v. Riverside Bayview, and Solid Waste Agency of Northern Cook County v. U.S. Army Corps of Engineers (SWANCC), and Rapanos v. United States (Rapanos) (7 6 Fed. Reg. 22187, April 21, 2014 ), are submitted on behalf of the Independent Petroleum Association of America, the American Exploration & Production Council and the Western Energy Alliance. Collectively, these three groups will be referred to as ”the Associations.” The comments are also supported by the listed organizations set forth below.
