Jun 27, 2019 API, AXPC, IPAA and DEPA Comments on EPA Development of a Draft Water Reuse Action Plan
In considering viable options and opportunities for water reuse, we encourage EPA to consider ways to provide maximum flexibility, certainty, and clarity to the existing regulatory and permitting frameworks applicable to the management of water from all industries (including the oil and natural gas industry). Variability among multi-jurisdictional bodies that regulate water quality and water reuse can result in complex jurisdictional interplays that place inconsistent regulatory burdens upon companies. While respecting that some variation is a natural consequence of cooperative federalism, the draft WRAP should work towards identifying and removing barriers within the federal government’s control that discourage and disincentivize the reuse, recycling, and fit-for-treatment uses of water. We support EPA working with various stakeholders, including the oil and gas sector, to better understand the current regulatory framework as well as the data and knowledge base that is in place.
Below, we provide specific comments following the Discussion Framework’s format on a section by- section basis for your consideration. Based on our extensive experience, we highlight issues, challenges, and recommendations with particular focus on the upstream areas of the oil and gas sector.