Comments on the Preliminary 2016 Effluent Guidelines Program Plan

Nutrient pollution from nitrogen and phosphorus runoff is one of the most pervasive water quality problems in the U.S. and there is increasing concern about their impact on drinking water.

Injecting captured carbon underground to produce more oil is promoted as a climate mitigation policy. This 2018 report exposes these oversight failures and challenges the assertion that federal subsidies for carbon used in enhanced oil recovery could ever be considered an effective climate mitigation policy.

As a known threat to drinking water sources, enhanced oil recovery is regulated by the federal Safe Drinking Water Act Underground Injection Control program. Our research has found this program to be inadequate in protecting groundwater, relying on outdated rules, and insufficient data collection and staffing levels to ensure safety.