Dear Mr. Wilson:
We, the undersigned organizations (collectively, the Associations), understand the importance of responsibly managing water resources and have been working to protect clean water for decades. Consequently, we submit these comments to the U.S. Environmental Protection Agency (EPA or Agency) in response to its “Interpretive Statement on Application of the Clean Water Act National Pollutant Discharge Elimination System Program to Releases of Pollutants From a Point Source to Groundwater” (Interpretive Statement).
Many of the Associations’ members own or operate facilities throughout the country that are subject to certain requirements under the National Pollutant Discharge Elimination System (NPDES) permitting program under the Clean Water Act (CWA or Act), as well as other state and federal environmental laws governing the releases of pollutants and other substances into the environment.