Comment Letter: EPA should engage in meaningful collaboration with states before finalizing the Maui Decision guidance and/or a future rule making. Meaningful collaboration includes early engagement, reviewing draft products, identifying… Read More »
Letters
Final ACWA Comment Letter Criminal Negligence Standard Proposal
ACWA would like to express support for the Environmental Protection Agency’s (EPA) recent proposed rule clarifying that “state or tribal programs approved pursuant to CWA Sections 402 and 404 are not required to include the same criminal intent standard that is applicable to EPA under Section 309 of the CWA.”
ACWA Comments on Proposal To Reissue and Modify Nationwide Permits
The NWPS are an important part of the regulatory system and enable efficient and effective regulatory review of construction and development activities that have a minimal individual and cumulative adverse environmental impacts. NWPS are permits used by the U.S. Army Corps of Engineers (USACE) to permit a wide range of activities that, upon incorporation of identified conditions and mitigation measures, have been determined to result in minimal adverse effects to the environment. NWPS
are useful for project applicants and states because they streamline the permitting processes necessary for approval. However, the states have several concerns, such as the water quality certification process, removal of the 300 linear foot limit for loss of stream bed and pre-construction notice requirements (PCN) with the changes outlined in the proposal and offer the
following comments.
EPA Governors Letter on WOTUS Meetings
A letter from EPA informing Governors of the opportunity for engagement meetings on the revised Waters of the U.S. proposal.
ECOS, ACWA, ASWM Letter to Congressional Leaders on Sec. 401 Authority
The Environmental Council of the States (ECOS), the Association of Clean Water Administrators (ACWA), and the Association of State Wetland Managers (ASWM) urge Congress to preserve states’ ability to protect water quality under Section 401 of the Clean Water Act. Our members believe that Section 401 is an important tool states can use to protect their waters for the benefit of their citizens.
ACWA Comments on Numeric Nutrient Criteria for Lakes and Reservoirs (LNNC)
ACWA and ASDWA’s substantive comments on the “Draft Ambient Water Quality Criteria Recommendations for Lakes and Reservoirs of the Conterminous United States: Information Supporting the Development of Numeric Nutrient Criteria” (Draft LNNC)
Final ACWA Comment Letter EPA Guidance Rule
ACWA comment letter on EPA’s proposed rule to establish administrative requirements and procedures guidance documents determined to be significant.
ACWA Letter on COVID-19
ACWA letter to EPA concerning COVID-19-related issues faced by state, interstate, and territorial clean water programs, and a potential strategy to leverage lessons learned going forward in the context of both COVID-19 and future disease outbreaks.
GAO Request to Study HABS
A letter from Congress requesting the Government Accountability Office (GAO) investigate the federal government’s response to harmful algal blooms (HABs). The letter asks GAO to investigate the federal government’s response… Read More »
Coalition Letters Supporting USGS Streamgage Networks & Modernization
ACWA joined a broad coalition of groups supporting USGS streamgage networks and modernization efforts. These vital networks, managed within the USGS Groundwater and Streamflow Information Program, provide critical and life-saving… Read More »
H.R. 6201, the Families First Coronavirus Response Act Coalition Letter
A letter to Congressional leadership as they work on a COVID-19 relief package urging them to fix a potential flaw in the legislation. H.R. 6201, the Families First Coronavirus Response… Read More »
Association Comment Letters on Listing PFAS in the Toxics Release Inventory
In February 2020, ACWA jointly submitted comments with ASDWA and ECOS in response to EPA’s ANPRM, “Addition of Certain Per- and Polyfluoroalkyl Substances; Community Right-to-Know Toxic Chemical Release Reporting (Docket… Read More »
