This comment letter response contains two parts:   

(1) The original submittal from the commenter.

(2) A data base printout of EPA’s response to each point raised by the commenter.

Notes about the response letters:

• The response letters were generated by a data base used to track the content of all public

comment submittals and ensure that the Agency responds to each. Each comment letter

was assigned a Letter ID that corresponds to the last four digits of the docket number of the

original comment (as posted on www.regulations.gov).

• Each response letter includes: comment text; an EPA‐assigned comment code; and an

individual response. These are described and explained below.  

• The data base contains Comment text from the letters submitted by commenters.  

Many hard copy letters were scanned into electronic format for inclusion in the data

base. As a result, there may be some typographical errors attributable to optical

character recognition issues.  However, all original submittals were reviewed in the

process of drafting responses to ensure that the comment content was understood and

appropriately addressed.

• The content of each comment letter was divided into topic areas and assigned a unique

Comment ID.  Additionally, one or more Comment Codes (i.e., unique topic area ID) was

assigned to each discrete point raised by a commenter. This information was added to

the data base. To inform final rulemaking decisions, all comments and information

received on a given topic were reviewed by technical experts in each rule area (e.g., on

construction requirements).  

• Following decisions on the final rule requirements, Individual responses were drafted

by topic area to ensure completeness and consistency of the responses with the final

rule and other responses to similar comments.  Each discrete point made by a

commenter was given a unique response.

• Upon completion of comment responses, all information was entered into the data base.

Each letter response is a compilation of each comment and its individual response,

compiled in the order of the original comment letter.  As a result of this process, there is

repetition in the response text.  The Agency believes this approach ensures completeness

and attention to each comment letter that was submitted.   

• All comments in a topic area were reviewed, evaluated, and responded to concurrently.  

Responses on each topic area are compiled and are also available in the rulemaking docket.
CCS is a bad idea to start with and is a waste of resources that should be invested in renewables 

and efficiency instead. But to allow injection above the lowest underground source of drinking 

water is INSANE, why would anyone in his/her right mind think that's an acceptable thing to do? 

For crying out loud, DON'T ALLOW THIS!!!!!!!!!!!! 

Liability should be retained by generators and operators. Doesn't the fact that they're so eager to 

divest themselves of liability give you a clue as to how safe they think it is? It is high time the 

costs associated with coal-fired electricity stopped being subsidized with taxpayer dollars!! 
Letter ID: 0335  

Commenter: Anonymous9  

   

Letter ID: 0335 Comment ID: 28213 Letter Lines: 17 to 18  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: CCS is a bad idea to start with and is a waste of resources that should be  

invested in renewables and efficiency instead. But to allow injection above the  

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.  

Letter ID: 0335 Comment ID: 28214 Letter Lines: 18 to 21  

Comment Code: 3220 3.2.2. Comments in Opposition to the Approach  

Comment: invested in renewables and efficiency instead. But to allow injection above the  

lowest underground source of drinking water is INSANE, why would anyone in  

his/her right mind think that's an acceptable thing to do? For crying out loud,  

DON'T ALLOW THIS!!!!!!!!!!!!  

Individual Response: EPA agrees that USDW protection is the highest priority and clarifies that the

purpose of the GS regulation is to ensure that GS, where deployed, is conducted in a manner that

protects USDWs. Incentivizing the use of GS or other renewable energy resources and technologies is

outside the scope of this rulemaking and the UIC Program’s authority under the SDWA. EPA disagrees

that finalization of the GS rule is premature. For additional information regarding the data on which EPA

based the final GS rule, see the preamble to the final GS rule.

EPA acknowledges the commenter's concerns about USDW protection and clarifies that the mission of

the UIC Program is to protect USDWs from endangerment. Based on an evaluation of comments on the

proposed injection depth requirements and the waiver process discussed in the NODA, and concerns

about USDW protection, EPA believes that there are situations where injection into non‐USDW

formations above the lowermost USDW can be performed in a manner that protects USDWs. The final

GS rule at §146.95 establishes a process by which owners or operators can seek a waiver of the Class VI

injection depth requirements. The waiver approach establishes requirements for extensive site‐specific

information related to injecting above or between USDWs that the owner or operator must submit and
the Director must consider, in consultation with PWSS Directors, to ensure that water supplies in the

area and all USDWs are protected.  

Furthermore, owners or operators granted injection depth waivers are subject to additional

requirements at §146.95(f), which include: modified construction requirements and requirements to

monitor above and below the injection zone in order to ensure protection of USDWs underlying and

overlying the injection zone during both well operation and the post‐injection site care period.  

Letter ID: 0335 Comment ID: 28215 Letter Lines: 23 to 26  

Comment Code: 5200 5.4. Comments on the Proposed Financial Responsibility Requirements (146.85)  

Comment: Liability should be retained by generators and operators. Doesn't the fact that  

they're so eager to divest themselves of liability give you a clue as to how  

safe they think it is? It is high time the costs associated with coal‐fired  

electricity stopped being subsidized with taxpayer dollars!!  

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.  

Letter ID: 0335 Comment ID: 28216 Letter Lines: 25 to 26  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: safe they think it is? It is high time the costs associated with coal‐fired  

electricity stopped being subsidized with taxpayer dollars!!  

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.