July 1, 2019
Assistant Administrator Office of Water U.S. Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington DC 20460
Submitted online (Docket Number: EPA-HQ-OW-2019-0174)
Re: Input on Development of the Draft National Water Reuse Action Plan
Program that Sacrifices Underground Drinking Waterfor Oil and Gas Injection Raises Questions
The aquifer exemption program in the Safe Drinking Water Act (SDWA) Underground Injection Control (UIC) program allows certain oil and gas and mining activity to occur in groundwater that would otherwise be protected as a potential drinking water source.
August 24, 2018
The Honorable Andrew Wheeler
U.S. Environmental Protection Agency Acting Administrator
1200 Pennsylvania Ave NW Washington DC 20460
RE: Docket ID No. EPA–HQ–OLEM–2018–0024 Clean Water Act Hazardous Substances Discharge Prevention Action
Dear Acting Administrator Wheeler,
On behalf of the undersigned 187 organizations and our millions of members and supporters across the country, we oppose the Trump administration’s attempt to repeal the 2015 Clean Water Rule and urge the U.S. Environmental Protection Agency and U.S. Army Corps of Engineers to withdraw this proposed repeal.
There were plenty of signs before 2017 started that the year would be one wild ride. We braced for the worst and were surprised only by the ferocity and relentless pace of attacks on our water and health coming out of the Trump Administration and Congress. Yet, outside of the political sphere, Americans remain unified in their support of clean water. Almost without exception, a solid majority of people in all demographic groups, in all parts of the country, regardless of party affiliation, care about our water and want to see it protected, now and for future generations.
Since the passage of the Clean Water Act in 1972 the United States has made great progress in cleaning up industrial chemicals and sewage pollution, but has failed to significantly reduce run-off of nutrient pollution into our nation’s rivers, lakes, and bays. Nutrient pollution refers to nitrogen and phosphorus, which are essential life elements that have enabled agriculture production in the United States to thrive, but at a huge cost to water quality.
Oversight Failures in the Section 45Q Tax Credit for Enhanced Oil Recovery
After decades of scientific analysis and international negotiations, reducing carbon emissions is now a global imperative. U.S. Congress, for its part, recognized the potential for carbon capture and storage (CCS) technology to reduce emissions and provided a tax incentive for companies that capture carbon dioxide (CO2) from various industrial practices and store it underground.
CO2-EOR presents risks to groundwater, the surface environment, and the health of communities living near oil fields.
Americans should understand the goal of the oil and gas industry: drill, extract, and burn all the oil and gas resources it can acquire. The business plan is to burn it all.