Thank you for accepting the following comments from Earthworks on the Environmental Protection Agency’s (EPA) Study of Oil and Gas Extraction Wastewater Management Under the Clean Water Act (CWA), No. EPA-821-R19-001, herein after referred to as the “Draft Study.”
Earthworks is a nonprofit organization with 48,000 members nationwide dedicated to protecting communities and the environment from the adverse impacts of mineral and energy development while promoting sustainable solutions.
We appreciate your efforts to study a very important issue – how to manage produced wastewater from the oil and gas industry – holistically. As evidenced by the data gaps noted in the Draft Study, an holistic assessment of wastewater management is impossible until the oil and gas industry discloses and characterizes all chemicals and wastes in oil and gas exploration and production. All stakeholders noted concern with the unknown chemical constituencies of the produced water waste stream.
