Deregulation and Clean Water

I received an email notice from Forester Network the other day letting me know that a much shortened comment period (30 day instead of the typical 90 day) had begun for proposed changes to definitions in the Clean Water Act. ( http://foresternetwork.com/daily/soil/erosion-control/waters-of-the-us-nows-our-chance-to-be-heard/?mqsc=E3902550&utm_source=WhatCountsEmail&utm_medium=Forester%20FullForester%20Daily%20Newsletter&utm_campaign=FDN-08072017-Waste )

This was the first shot I was aware of in a key battle against environmental regulation in a field I am very familiar with, streams and wetlands. My adrenaline was pumping and in my haste to fire back against deregulation proponents I skimmed the article and went straight to the link ( https://www.regulations.gov/comment?D=EPA-HQ-OW-2017-0203-0001 ) where I typed with fury against the promised assault on clean water and the environment. In short time I pressed send and felt the release of knowing I had done something to let the government know that some people realize there are more important things than short term profit My first letter read "I am a scientist with an M.S. in Conservation Biology and over 20 years of experience working in streams and wetlands in positions with employers including a utlity district/water provider, various environmental consultants performing stream and wetland and fisheries work, a major university as a wetland and water quality researcher, and a local government as an environmental specialist. In all of these positions I have spent countless hours in field work covering many acres and miles of stream and wetlands throughout California, in Massachusttes, and in 6 southeastern states, with an eye towards the ecology and water quality effects of and to these systems. My research and field observations has led me to the undeniable conclusion that the only way to safeguard our water supply now and for future generations is to protect what is still left from further degradation. Protecting large wetland and river systems is of course important, but we cannot underestimate the vital utility of even the smallest headwater stream and wetland systems that probably far outnumber large rivers in miles of stream. These are the true sources of our clean water, the first filters that will shape the chemical, physical, and biological integrity of a stream system. To cut these off is like cutting off our fingers and expecting the arm to still perform all the critical functions of the missing digits. We cannot allow short term profit and interests to override vital protections of our water supply for our society, current and future. What is lost now will be impossible to replace in the future. The current Clean Water Rule, with its current definition of Waters of the US, is something determined by very knowledgable scientists who have studied and deliberated this for many years, and, as I would trust a doctor to cure my illness or a mechanic to fix my engine, I trust much more with a decision so critical to our future than politicians, bureaucrats, and developers with obvious agendas and biases."

It was only that night when I read the article and the docket more carefully that I realized that in my haste to respond I missed the mark on responding to what is being challenged in this proposed regulation change, definitions of waters of the US. I slept on it and in the morning another comment letter came quickly from my fingers "I have spent many years as a consultant, regulator, and researcher performing lab and field work in streams and wetlands throughout the southeastern US and in California. My studies have invariably demonstrated the importance of peripheral aquatic systems such as headwater stream systems, including intermittent and sometimes ephemeral streams, and fringing wetlands, including floodplain and so-called "isolated wetlands" to flood control and pollution filtration. One study I participated in, entitled "Hydrologic Connectivity, Water Quality Function, and Biocriteria of Coastal Plain Geographically Isolated Wetlands" ( https://ncdenr.s3.amazonaws.com/s3fs-public/Water%20Quality/Surface%20Water%20Protection/PDU/Grant%20Final%20Reports/IWC%20Final%20Report%20vs02-19-2013-FINAL.pdf ) clearly demonstrates that the "significant nexus via surface connection" is a human construct and not a true scientific demarcation when it comes to calculating pollution removal from a stream system. To truly protect our most important resource, clean water, for future generations we should expand, not contract the definition of waters of the US to include these so-called isolated wetlands, which are, in fact, critically linked to surface waters."

The comment period ends on August 28th. Please write even the shortest note to show support for maintaining the current definitions of "Waters of the US"