Energy extraction should be the top enforcement priority for the EPA. Existing unanswered questions regarding the environmental impact of new extraction technologies (e.g., hydraulic fracturing) provide a foundation for the enforcement of existing regulations and the development and implementation of new regulatory systems. Furthermore, the proposed expansion of extraction activities into environmentally-sensitive natural areas (e.g., ANWR) demands that existing regulations be both enforced and strengthened in order to shift resources away from potentially-harmful traditional energy extraction and toward energy production technologies with lower environmental impacts, especially renewable energy technologies that may have secondary environmental and economic benefits (e.g., offshore wind).
Municipal infrastructure should be another primary enforcement priority for the EPA. Combined sewers that remain in use today remain significant point-sources for nutrient pollution, especially around urbanized coastlines and bays (e.g., Chesapeake Bay, Delaware inland bays). While many large cities have mitigated the impact of their CSO pollution issues, many historic towns still use this damaging and difficult-to-manage infrastructure. New efforts should focus on identifying and eliminating these point-sources over the next four years. Furthermore, the same municipalities with CSO issues also have issues with combined sewer and stormwater systems, which can put undue stress and wear on local wastewater treatment facilities and redue the life and effectiveness of vital components, causing premature failure of these systems, even if they are new. EPA should focus on comprehensive strategies that give clear deadlines and paths to compliance for these municipalities, including the provision of one-time funding to eliminate these pollution sources and hazards. Other funds and resources should continue to target failing septic systems that threaten these same at-risk waterways.
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Public Comment on EPA's National Enforcement Initiatives for Fiscal Years 2014-2016
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