Approved at the Sunday WWALS board meeting and filed last night via regulations.gov as PDF.

April 15, 2019

U.S. Environmental Protection Agency
EPA Docket Center
Office of Water Docket
Mail Code 28221T
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Re: Docket ID No. EPA-HQ-OW-2018-0149,
       Revised Definition of Waters of United States

To Whom it May Concern:

WWALS Watershed Coalition, Inc. (WWALS), also known as Suwannee Riverkeeper, submits the following comments on the United States Environmental Protection Agency (“EPA”) and Department of Defense, Department of the Army, Corps of Engineers (“Corps”) proposed rule entitled “Revised Definition of Waters of United States,” 84 Federal Register 4154-01 (February 14, 2019) (hereinafter “Proposed Rule”).

In addition to supporting the comments of Waterkeeper Alliance and the Southern Environmental Law Center (SELC), WWALS adds these comments on groundwater.

The Proposed Rule’s categorical exclusion of groundwater makes no sense here above the Floridan Aquifer where surface water and groundwater constantly interchange, and pollutants travelling through groundwater are a frequent source of health, environmental, and economic problems.

2019-04-15–WWALS-to-EPA-0001

This proposed exclusion of groundwater is called out repeatedly in the Proposed Rule, starting with this: