Comment submitted by National Ground Water Association (NGWA)

Summary: The National Ground Water Association (NGWA) opposes several provisions of the proposed rule that they believe weaken groundwater protections, specifically regarding the relocation of points of compliance, the deferral of closure requirements for legacy units, and the lack of mandatory mitigation in closure plans. They argue that these changes could delay the detection of contamination, reduce the stringency of cleanup, and fail to adequately protect adjacent groundwater users.