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May 21, 2018 Scott Wilson Office of Wastewater Management, Water

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May 21, 2018 Scott Wilson Office of Wastewater Management, Water May 21, 2018 Scott Wilson Office of Wastewater Management, Water Permits Division (MC4203M) United States Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460 Submitted electronically – http://www.regulations.gov Subject: CASQA Comment Letter – Docket ID: EPA-HQ-OW-2018-0063; FRL-9973-41-OW EPA Clean Water Act Coverage of “Discharges of Pollutants” via Direct Hydrologic Connection to Surface Water Dear Mr. Wilson: The California Stormwater Quality Association (CASQA)1 is writing to provide comment to the United States Environmental Protection Agency (EPA) regarding the Clean Water Act (“CWA” or “Act”) and whether point source discharges that reach jurisdictional surface waters (i.e. “waters of the United States”) through groundwater or other subsurface flow with a direct hydrologic connection to the jurisdictional surface waters may be subject to regulation under the CWA (hereinafter, “Request for Comments”).2 CASQA is the country’s largest professional, non-profit association dedicated to the advancement of stormwater quality through education, collaboration, regulatory review, and scientific assessment. CASQA’s municipal members are subject to regulation of their municipal separate storm sewer systems (MS4s)3 through the CWA’s National Pollutant Discharge Elimination System (NPDES) stormwater permitting program. Additionally, CASQA’s industrial members, must ensure their onsite retention and/or discharges comply with MS4 permit standards. In California, such permits are issued either by the Regional Water Quality Control Boards (Regional Water Boards) or the State Water Resources Control Board (State Water Board), and ultimately approved by EPA Region 9. The State Water Board has determined that stormwater is both a resource and an asset – one that should not be treated as a waste product.4 To this end, there has been a recent push to require MS4 NPDES permittees to capture and infiltrate 1 CASQA is a professional member association dedicated to the advancement of stormwater quality management through collaboration, education, implementation guidance, regulatory review, and scientific assessment. CASQA is comprised of stormwater quality management organizations and individuals, including cities, counties, special districts, industries, and consulting firms throughout California. Our hundreds of municipal members provide stormwater quality management services to more than 23 million people through the construction, operation, and maintenance of MS4s. 2 Clean Water Act Coverage of “Discharges of Pollutants” via a Direct Hydrologic Connection to Surface Water, 83 Fed. Reg. 7,126 (proposed Feb. 20, 2018). 3 An MS4 is generally a conveyance, or system of conveyances, that is used or designed to collect stormwater owned or operated by a state or other local agency, e.g. town city, parish, or district, that is also not a combined sewer system or part of a publicly owned treatment works. 40 C.F.R. § 122.26(b)(8) (2017). 4 See Cal. Water Code, § 10561; State Water Board, Waste Discharge Requirements (WDRs) for Storm Water Discharges from MS4s (General Permit), Order No. 2013-0001-DWQ (Feb. 5, 2013), p. 5. CASQA Comments on CWA Coverage of “Discharges of Pollutants” via Direct Hydrologic Connection to Surface Water stormwater into groundwater to achieve pollutant reduction and hydromodification mitigation (or control),5 as well as to enhance groundwater reserves.6 Accordingly, the Request for Comments raises concerns for CASQA and its constituent members. First and foremost, the regulation of discharges to groundwater is not clearly within the ambit of the CWA’s text or history, and an action in such direction is, therefore, beyond the scope of EPA’s NPDES program and rulemaking authority thereunder. CASQA believes that regulation of discharges to groundwater should remain an issue best addressed at the state and local level to ensure that factors specific to each state and even groundwater basin, such as physiography, hydrology, and hydraulic landscape, are properly considered and reflected in the states’ and local agencies’ regulations and policies. To the extent EPA makes a policy change in response to the Request for Comments, CASQA encourages EPA to expressly exempt stormwater infiltration and discharges to groundwater from any application thereto. A departure from current EPA policy will have substantial impacts on MS4 Permittees, as well as water districts, municipalities, developers, and owner/operators of industrial facilities, all of whose stormwater discharges are tied to MS4 permits. More specifically, a change in policy would subvert these entities’ capabilities of meeting state-specific goals, such as stormwater infiltration for pollutant mitigation and water supply augmentation, as well as disrupt states’ stormwater management and groundwater recharge initiatives. REQUESTED COMMENT TOPIC 1: EPA seeks comment on whether subjecting pollutant discharges from point sources that reach jurisdictional surface waters via groundwater or other subsurface flow that has a direct hydrologic connection to the jurisdictional surface water to CWA permitting is consistent with the text, structure, and purposes of the CWA. If EPA has the authority to permit such releases, EPA seeks comment on whether those releases would be better addressed through other federal authorities as opposed to the NPDES permit program. Comment 1.1: The Regulation of Discharges to Groundwater – No Matter the Connection to a Jurisdictional Surface Water – is a Matter that Should Be Addressed at the State Level. The importance of the CWA cannot be overstated. It plays a critical role in restoring and maintaining the chemical, physical, and biological integrity of the Nation’s waters; nevertheless, its jurisdiction is not boundless. Neither the text nor the legislative history of the CWA provide authority for EPA to regulate discharges of pollutants from point sources that reach surface waters through groundwater. For such authority to exist, Congress would need to weigh in and ultimately amend the CWA. Past and even recent court decisions addressing the discharge to groundwater issue have created uncertainty, with some Courts of Appeal holding that discharges to groundwater that eventually reach navigable waters are not regulated by the CWA because groundwater is not “a water of the U.S[,]”7 while other Courts of Appeal have held 5 State Water Board, Waste Discharge Requirements for MS4s Discharges within the Coastal Watersheds of Los Angeles County, except those Discharges Originating from the City of Long Beach MS4s, Order No. R4-2012-0175 (Nov. 8, 2012) (as amended by R4-2012-0175-A01; Order No. R4-2010-0108; Order No. R9-2013-0001 as amended by Order Nos. R9-2015-0001 and R9-2015-0100; Order No. R2-2015-0049). 6 Cal. Water Code, § 10561(e); see also State Water Board’s Strategy to Optimize Resource Management of Storm Water (STORMS): https://www.waterboards.ca.gov/water_issues/programs/stormwater/storms/ (last visited Apr. 25, 2018); State Water Board’s Policy for Water Quality Control for Recycled Water (Recycled Water Policy): https://www.waterboards.ca.gov/water_issues/programs/water_recycling_policy/docs/rwp_revtoc.pdf (last visited on Apr. 25, 2018); CASQA Vision and Strategic Actions for Managing Stormwater in the 21st Century: https://www.casqa.org/sites/default/files/library/other/vision_and_strategic_actions_for_managing_stormwater_in_the_21st_cent ury_2017_version_11.pdf (last visited Apr. 25, 2018). 7 See Vill. of Oconomowoc Lake v. Dayton Hudson Corp., 24 F.3d 962 (7th Cir. 1994) (holding that federal government does not have authority pursuant to the CWA over artificial ponds that drain into groundwater); see also Rice v. Harken Expl. Co., 250 F.3d 264 (5th Cir. 2001). May 21, 2018 2 CASQA Comments on CWA Coverage of “Discharges of Pollutants” via Direct Hydrologic Connection to Surface Water that such discharges are regulable based upon their connectivity to jurisdictional surface waters.8 These cases elucidate the intricacies of the issue and illustrate that its resolution is best left to Congress. Indeed, the distinction among them lies in the perspective from which the court examined the issue: whether the CWA regulates the discharge of pollutants to groundwater, versus whether indirect discharges to groundwater confer liability under the CWA because the discharges come from a point source and reach a jurisdictional surface water through a direct connection to groundwater. No matter the perspective, the same issue remains – regulation of discharges to groundwater. Courts parsing out whether the discharge comes from a point source, then travels through groundwater before reaching the surface water, or goes directly from the point source to groundwater is, in the context of the CWA’s NPDES statutory authority, irrelevant. Either scenario produces the same effect of regulating which pollutants and in what quantity may be discharged to groundwater. EPA adopting – through a rulemaking or policy change – a position that results in regulation of discharges to groundwater with a direct hydrologic connection to a jurisdictional surface water is, effectively, an illegal backdoor expansion of the authority of the CWA. The CWA’s text and legislative history support CASQA’s position. While CWA jurisdiction is broad, Congress did not authorize regulation over all waters. Use of the phrase “waters of the U.S.” to serve as the jurisdictional bounds of the CWA indicates that its reach is necessarily a subset of water generally;
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