MLPA Comments on WOTUS


October 31, 2017

Re: Definition of “Waters of the United States” Preproposal Outreach Comments; EPA-HQ-OW-2017-0480; submitted via

The Missouri Limestone Producers Association (MLPA) supports EPA’s decision to withdraw the 2015 Waters of the United States Rule (80 FR 37054) which was an expansive and overreaching proposal in an area not previously regulated by the EPA. The 2015 rule would have cost aggregates operators millions of dollars in increased costs, increased the cost of public infrastructure projects and would have resulted in little to no environmental benefit. 

As EPA develops a new rule, we ask that the rule clearly exclude operations such as sand and gravel pits and stone quarries, wastewater systems and conveyances, and ditches. Areas that are not connected to navigable waters should not be considered a Waters of the U.S.

The MLPA is the statewide service organization for 47 companies engaged in the production of crushed stone aggregate for commercial, residential, agricultural and infrastructure needs.  The total amount of crushed stone produced in Missouri is nearly 70 million tons, representing a value of about $550 million. MLPA also represents 113 companies that provide products and services to our industry.

We applaud EPA’s withdrawal of the 2015 WOTUS rule, request that any new proposed rule provides operational clarity and certainty, particularly excluding aggregate pits and quarries, water treatment systems, dry stream beds and isolated waters.




Morgan Mundell
Missouri Limestone Producers Association
P.O. Box 1725, Jefferson City, MO 65102
Phone: (573) 635-0208