Comment submitted by Daniel Zimmer

Public Comment EPA Public Hearing / Docket EPA-R05-OW-2025-2730 July 23, 2026 Midtown Center 96 W 15th St. Holland, MI Abundance & Scarcity Groundwater in Ottawa County, Michigan Despite being near Lake Michigan Ottawa County, is facing a groundwater shortage due to declining water levels in its aquifers. Many residents and businesses rely on wells tapping into underground aquifers, but these sources are being depleted faster than they can be replenished. Helicopter Groundwater Study in Ottawa County, Michigan A low-flying helicopter survey is underway in Ottawa County, Michigan, as part of a joint U.S. Geological Survey (USGS) and Michigan Department of Environment, Great Lakes, and Energy (EGLE) project to map the region’s aquifers and geology. History shows patterns of decisions made from an abundance belief system and viewpoint, that lead to scarcity. Two examples are: 1) The slaughter of Bison during the 1800's. Reducing the herd from millions to approximately 192,00 today. 2) The area of Pigeon River and Pigeon Lake was once a nesting area for Passenger Pigeons. North America once had 3 billion and today they are extinct. With Lake Michigan nearby it is difficult to envision water as a scarce commodity. Daily living, Agriculture and Industry require water. A Google search indicates that 923 to 977 thousand gallons of rainfall and snow melt water present per acre, per year in Ottawa County. Multiply that by the number of landfill acres at Consumers Energy and then multiply that by the number of similar injection wells operating nationwide. Removing water from the Eco system and the cyclical circle of life and placing it where nature never intended it to be by deep well injection will prove at some point to be a decision made in a thought stream of perceived abundance that discounted and dismissed the emerging reality of scarcity. Water Loss from Deep Well Injection Nationwide Deep well injection — primarily for disposing of oil and gas produced water — is the dominant method for handling the U.S. industry’s waste water, and it accounts for trillions of gallons of water being “lost” to disposal each year. According to the Groundwater Protection Council’s 2022 report, the U.S. oil and gas industry produces about 25.9 billion barrels of waste water annually, which equals 1.0878 trillion gallons NationofChange+1. Of this, 96% (about 24.8 billion barrels) is disposed of by injecting it deep underground into Class II injection wells under the EPA’s Underground Injection Control (UIC) program NationofChange+1. That’s roughly 1.02 trillion gallons of water being permanently removed from the surface and sent underground each year. In the Permian Basin alone, where deep and shallow disposal wells are heavily used, over 35 billion barrels (about 1.5 trillion gallons) of produced water have been injected since the shale boom began JPT. While some of this water is later reused for well stimulation, the majority remains in the subsurface, effectively removed from the water cycle. Key points: Annual disposal volume: ~1.02 trillion gallons/year nationwide via deep injection NationofChange+1. Wells involved: Over 180,000 injection wells in the U.S., with deep wells concentrated in major oil/gas basins NationofChange+1. Water type: Primarily produced water, brine, and saltwater from oil and gas extraction. Regulation: Managed under the UIC program, but critics argue oversight is inconsistent and risks to aquifers remain NRDC+1. In effect, deep well injection is the largest single source of “water loss” from the U.S. oil and gas sector, diverting trillions of gallons annually from the surface into the subsurface for disposal. To close, What is the tipping point of aquifer recharge and diminishing aquifer reserve levels that triggers cause and effect analysis into the systemic attributes of aquifer water loss? Groundwater is a matter of concern, the volume and quality thereof. Policy and protocol that does not protect and preserve water resources is a matter of concern. The powers that be that willfully ignore the systemic factors of ground water loss are negligent and complicit in the dynamics of water scarcity. Dan Zimmer 8180 156th Avenue West Olive, MI