Comments
Draft National Water Program 2012 Strategy: Response to Climate Change:
EPA-HQ-OW-2011-0943
Submitted by: National Ground Water Association
Contact: Christine Reimer, NGWA Government Affairs, 601 Dempsey Road,
Westerville, OH 43081, 800.551.7379, ext 560, creimer@ngwa.org
Developing scientifically based strategies for sustainable use of our nation’s groundwater
resources is essential to the United States’ need to address the growing demands of an increasing
population and to prepare for the effects of climate change. The National Ground Water
Association, whose membership includes the country’s eminent groundwater scientists, strongly
encourages policymakers to include the importance of assessing, protecting and developing longterm strategies for one our most critical resources – groundwater, as a key component of these
initiatives. NGWA supports U.S. EPA’s efforts in drafting and seeking comments on its Draft
National Water Program 2012 Strategy: Response to Climate Change as a part of an overall
federal response.
NGWA offers the following specific comments as relates to the 2012 draft document:
Overall:
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To improve document readability and audience outreach the executive summary should
be enhanced to include additional diagrams and quotes from the text. A Frequently
Asked Questions document would be beneficial.
Informing the public of the challenges humanity faces with climate change impacts to the
hydrologic cycle is mentioned in a few areas of the document, such as page 32, Strategic
Action 11. There is a need to balance economic growth with a responsible approach to
natural resource consumption. This reconciliation can partly be achieved through public
outreach programs.
Page 1 and Page 12, Section C: The document should include a scientific analysis of the
evidence to climate change.
Page 27, Goal 2, Strategic Action 5 and Page 88, Goal 19D:
• These sections need to mention the nexus among artificial groundwater recharge and
conservation, reuse and water quality protection. Groundwater banking is an
underutilized mechanism in which artificial recharge is directly linked to responsible
reuse and market based allocation.
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The document should also make clear that aquifer storage and recovery is one technique
for managed aquifer recharge Managed aquifer recharge replenishes groundwater
supplies by capturing available water (during wet periods, during periods of low demand,
or water that would be lost otherwise) and storing it in underground reservoirs called
aquifers. ASR is one technique, among others, to convey and store this water
underground, in this case through wells for later recovery through the same well or a
nearby production well.
The Association also recommends that managed aquifer recharge projects be included as
eligible water infrastructure projects for federal financial support.
Page 34, Goal 5, Strategic Action 14: Action to update delineations, assessments or protection
plans may not happen without federal funding to the states or local government.
Page 45, Goal 10, Strategic Action 27: This section needs to mention the potential for sea water
intrusion into groundwater as a consequence of rising sea levels.
Page 48, Sections D and E:
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These sections lay out a multi-pronged approach to working with Tribal, State and Local
governments in mitigating climate change impacts to water supply. However, this section
falls short of providing the mechanics on how the Federal government will work
cooperatively with these entities’ established regulatory networks. The authors may want
to consider including hypothetical decision process diagrams/case studies to the report.
The regional collaborations mentioned on page 81 are a good start.
Strategic Action 32 may not happen without federal funding to the states or local
government.
The National Ground Water Association is a not-for-profit professional society and trade
association for the groundwater industry. NGWA is the largest organization of groundwater
professionals in the world. Our members from all 50 states and 72 countries include some of the
leading public and private sector groundwater scientists, engineers, water well contractors,
manufacturers, and suppliers of groundwater related products and services. The Association’s
vision is to be the leading community of groundwater professionals that promotes the responsible
development, use and management of groundwater resources.