Towards A Better Environmental Legacy

Sunday, April 14, 2019

EPA Clean Water ACT Proposal Discounts It's Own Science

The Trump appointee led EPA is proposing changes to the definition of "Waters of The US" that will eliminate large areas of aquatic habitat vital to flood control, water dependent plant and animal species, and protection of clean water. Here is my comment letter to the proposed regulation changes. Commentswill be accepted through April 15th here:

https://www.regulations.gov/document?D=EPA-HQ-OW-2018-0149-0003


It’s outrageous that our own EPA would attempt to reduce protection on something as vital and increasingly threatened as clean water. We should leave science to the scientists when it comes to protection and management of such a critical resource. Environmental science is different from business, there is no simple “one size fits all” box for every situation, no matter how much the moneyed interests from certain industries would like to convince us of this. The “surface connection” that the EPA proposal would like to put so much stock in as a sacrosanct boundary for “Waters of the US” is absolutely meaningless in terms of water quality, and in terms of the chemical, physical, and biological integrity of stream and wetland systems. Anyone who’s made coffee or tea has experienced how water flowing through something, (including soil) is affected by the substance it flows through. I would much rather have my drinking water filtered by natural soils than collected from streets and commercial and industrial parking lots. Most water dependent plants and animals don’t care whether or not the piece of water they inhabit is connected to others via surface or underground water. I am an aquatic scientist with over 30 years of experience in the field, working in the west and the southeastern US, and a study I participated in ( http://www.northinlet.sc.edu/training/media/2011/06142011isolatedwetlands/resources/seiwa_final_report.pdf ) clearly showed the importance of the connection between isolated wetlands and surrounding waters. In the west and in the southeast even perennial streams may flow underground for a distance when they encounter very porous soils or other conditions, but that does not diminish the importance of the aquatic ecosystem and the water filtering and flood buffering capacity of the section above the underground portion in any way. In the west, where rainfall is seasonal and sporadic, ephemeral streams and wetlands are vital to many species, and research conducted by the EPA itself demonstrates their importance to water quality ( https://www.epa.gov/sites/production/files/2015-03/documents/ephemeral_streams_report_final_508-kepner.pdf ). We must not let an influential few choreograph the sacrifice of a resource so vital to ourselves and to future generations for their own avaricious and short sighted interests.

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