Revised Definition of Waters of the United States
Docket Number: EPA-HQ-OW-2018-0149 FRL-9988-15-OW
March 4, 2019
The Honorable Andrew Wheeler, Administrator
U.S. Environmental Protection Agency
Office of the Administrator: 1101A
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Administrator Wheeler:
We are strongly opposed to the changes to the definition of the “Waters of the United States”, currently being proposed by the U.S. Environmental Protection Agency. As members of the Choose Clean Water Coalition, we are committed to maintaining and restoring clean water to the rivers and streams throughout the Chesapeake Bay region and we rely on the Clean Water Act as the foundation of restoration and protection efforts.
The proposed changes regarding the definition of the “Waters of the United States” would be, by far, the biggest step backwards on clean water in our region since the Clean Water Act became law nearly a half century ago. And this is all occurring while EPA’s leadership has been very vocal by taking every opportunity to talk about its new mission statement, “EPA is returning to its core mission of protecting human health and the environment.” The proposed changes to the Clean Water Act contradict this basic core mission of EPA.
Approximately 11 million people (nearly two out of three) in the Chesapeake Bay watershed get their drinking water directly from the 147,149 miles of rivers and streams flowing into Chesapeake Bay. All of these rivers and streams are dependent on high quality water from the 56,689 miles of intermittent and ephemeral streams in their headwater areas, so we are extremely troubled at the proposal’s plan to remove all Clean Water Act protections for ephemeral streams and its suggestion that the final rule might also eliminate protections for intermittent streams.
Removing protections for intermittent and headwater streams throughout our region not only impacts our surface drinking water sources, but also threatens key habitat for shrinking populations of eastern brook trout. Protections would also be removed from valuable wetlands throughout our region that are critical for mitigating flooding and providing habitat for numerous species of fish and waterfowl. These wetlands are the primary reason that the Chesapeake is home to more than 1 million migratory geese, ducks and swans every winter. This great and critical part of the Atlantic Flyway would collapse if these critical wetland areas are lost.
The Chesapeake Bay Program partnership, coordinated by EPA, came together in 1983 to work to restore clean water to the 64,000 square mile watershed in Delaware, Maryland, New York, Pennsylvania, Virginia, West Virginia, and the District of Columbia. Promulgating this rule to weaken the Clean Water Act and rollback protections would be a blow for the progress made in the Chesapeake Bay watershed in recent years.
On January 16, 2019, at your confirmation hearing in the U.S. Senate you stated, “There is no more important responsibility than protecting human health and the environment. It is a responsibility I take very seriously.” We urge you to abide by these words and to stop this attempt to weaken the Clean Water Act endangering human health and the environment in the Chesapeake region and nationwide.
Sincerely,
Action Together Northeastern Pennsylvania
American Chestnut Land Trust
American Rivers
Anacostia Riverkeeper
Anacostia Watershed Society
Annapolis Green
Arundel Rivers Federation
Audubon Maryland/DC
Audubon Naturalist Society
Audubon Society of Northern Virginia
Back Creek Conservancy
Baltimore Tree Trust
Blue Heron Environmental Network
Blue Ridge Watershed Coalition
Blue Water Baltimore
Butternut Valley Alliance
Cacapon Institute
Capital Region Land Conservancy
Catskill Mountainkeeper
Center for Progressive Reform
Chapman Forest Foundation
Chemung River Friends
Chesapeake Bay Foundation
Chesapeake Climate Action Network
Chesapeake Conservancy
Chesapeake Wildlife Heritage
Clean Fairfax
Clean Water Action
Clean Water Linganore
Coalition for Smarter Growth
Conservation Voters of Pennsylvania
DC Environmental Network
Delaware Nature Society
Earth Conservation Corps
Earthworks
Earth Forum of Howard County
Eastern Pennsylvania Coalition for Abandoned Mine Reclamation
Eastern Shore Land Conservancy
Elizabeth River Project
Environmental Integrity Project
Environmental Justice Center of Chestnut Hill United Church
Environmental Working Group
Experience Learning
Float Fishermen of Virginia
Friends of Accotink Creek
Friends of Frederick County
Friends of Herring Run Park
Friends of Little Hunting Creek
Friends of Lower Beaverdam Creek
Friends of Quincy Run
Friends of Sligo Creek
Friends of the Bohemia
Friends of the Cacapon River
Friends of Dyke Marsh
Friends of the Middle River
Friends of the Nanticoke River
Friends of the North Fork of the Shenandoah River
Friends of the Rappahannock
Friends of St. Clements Bay
Goose Creek Association
Interfaith Partners for the Chesapeake
James River Association
Lackawanna River Conservation Association
Lancaster Farmland Trust
Little Falls Watershed Alliance
Lower Susquehanna Riverkeeper
Lynnhaven River NOW
Maryland Conservation Council
Maryland Environmental Health Network
Maryland League of Conservation Voters
Maryland Native Plant Society
Maryland Nonprofits
Maryland Science Center
Mattawoman Watershed Society
Mid-Atlantic Council Trout Unlimited
Middle Susquehanna Riverkeeper
Muddy Branch Alliance
National Aquarium
National Parks Conservation Association
National Wildlife Federation
Natural Resources Defense Council
Nature Abounds
NeighborSpace of Baltimore County
New York League of Conservation Voters
New York State Council of Trout Unlimited
Neighbors of the Northwest Branch
Otsego County Conservation Association
Otsego Land Trust
Partnership for Smarter Growth
Patapsco Heritage Greenway
Patuxent Tidewater Land Trust
PennEnvironment
PennFuture
Pennsylvania Council of Churches
Pennsylvania Council of Trout Unlimited
Piedmont Environmental Council
Potomac Conservancy
Potomac Riverkeeper
Potomac Riverkeeper Network
Potomac Valley Audubon Society
Queen Anne’s Conservation Association
Preservation Maryland
Rachel Carson Council
Restore America’s Estuaries
Rappahannock League for Environmental Protection
Richmond Audubon Society
Rivanna Conservation Alliance
Rock Creek Conservancy
St. Mary's River Watershed Association
Savage River Watershed Association
Severn River Association
Shenandoah Riverkeeper Shenandoah Valley Network
ShoreRivers
Sidney Center Improvement Group
Sierra Club – Maryland Chapter
Sleepy Creek Watershed Association
Southeast Rural Community Assistance Project
Southern Environmental Law Center
Southern Maryland Audubon Society
SouthWings
Susquehanna Heritage
Talbot Preservation Alliance
The Downstream Project
Transition Howard County
Trash Free Maryland
Trout Unlimited
Upper Potomac Riverkeeper
Virginia Association of Biological Farming
Virginia Conservation Network
Virginia League of Conservation Voters
Warm Springs Watershed Association
Waterfront Partnership of Baltimore, Inc.
Waterkeepers Chesapeake
West Virginia Citizen Action Group
West Virginia Environmental Council
West Virginia Highlands Conservancy
West Virginia Rivers Coalition
Wetlands Watch
Wicomico Environmental Trust