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ARA Co-Signed Comments to EPA on Unnecessary Regulations

Jul 26 2022

ARA co-signed comments sent to the U.S. Environmental Protection Agency (EPA) raising concerns about the impact on small businesses from the proposed rule regarding the Clean Water Act Hazardous Substance Worst Case Discharge Planning Regulations.

While ARA and the undersigned organizations share goals with EPA to prevent chemical accidents and practice environmental stewardship, we raise concerns over this rule's cost-benefit, applicability, unclear definitions, substantial harm criteria determinations, facility response plan requirements, and more. 

Recognizing the local, state, and federal measures already in place to prevent discharges, the undersigned organizations encourage the EPA to reconsider the extensive new requirements in this proposal that will be extremely burdensome while providing minimal benefit.

Read more in the comments below. 

COMMENTS

ARA also filed comments to the EPA directly to elaborate on how this rule would create duplicative burdens and unnecessarily increase costs for ag retail facilities. Read ARA's comments below. 

ARA COMMENTS