Letter Asking the Trump Administration to Withdraw Its WOTUS Proposal

The Honorable Andrew Wheeler
Acting Administrator Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, DC 20460

The Honorable R.D. James Assistant Secretary of the Army (Civil Works) Army Corps of Engineers 108 Army Pentagon
Washington, DC 20310

Attention: Docket ID No. EPA-HQ-OW-2018-0149

Dear Mr. Wheeler and Mr. James:

On behalf of our millions of customers, members, and supporters, we ask that you keep the value of our water and the business it generates in mind and withdraw your proposal to eliminate federal protection for waterways across the country.

We rely on clean water for our livelihoods and enjoyment. Our companies and organizations represent Americans who enjoy hiking, swimming, fishing, and paddling; visiting our national parks and other public lands; drinking beer and going to restaurants; and many other activities when we go outside. Access to clean water is vital for the safety, well-being and success of our communities, businesses, economy and nation.

Right now, our nation needs more clean water protections that safeguard our waters, not less. We need a Clean Water Act that protects all wetlands and streams our companies and customers rely on. The science has never been clearer in showing why it’s so important to all our waters. Small headwater and ephemeral streams feed rivers and lakes with the water Americans drink. Wetlands stop flooding by soaking up excess water, prevent algal blooms by filtering pollutants like nitrogen and phosphorus, and provide homes for fish, birds and other wildlife. By keeping these upriver waters clean and clear, downriver waters are protected from the pollution that doesn’t aggregate upstream.

Even with current protections, our waters are still impaired. Aging water infrastructure leads to sewer overflows contaminating near-shore areas along the nation’s coasts impacting tourism dollars. Agricultural runoff leads to water quality problems as the nutrients and fertilizers that help farmers grow our food also feed toxic algae outbreaks. Industrial and commercial development not properly designed and situated destroys wetlands and other small streams leading to the loss of important habitat and greater risk of floods, which in turn will upset our local economies.

Instead of confronting these problems, the U.S. EPA and Army Corps now propose to establish the narrowest definition of federally protected waters in the history of the Clean Water Act. This proposal—for the first time—eliminates at least 18 percent of streams and 51 percent of wetlands from federal protection. This means thousands of miles of streams, roughly half of the nation’s wetlands, and other critical water bodies would no longer be guaranteed protection under the Clean Water Act’s pollution control, prevention, and clean-up programs.

We depend on these waters. The proposal’s effect on water quality threatens the water we use to drink, work, and play. The craft brewing industry contributed $76.2 billion to the U.S. economy in 2017, more than 500,000 jobs. An Outdoor Industry Association report shows that consumers spend $887 billion annually on outdoor recreation; over $175 billion on fishing, kayaking, rafting, canoeing, and scuba diving and other water sports alone. The clean water economy supports many other American economic sectors including manufacturing, hotels, restaurants and retail trade. Our members and customers visit local retailers to buy canoes, apparel, and outdoor gear. Domestic and international families pay for river guides and outfitters, lift tickets, and entrance fees. They rent cars, book hotel rooms, go to restaurants, and stock up on groceries, beer, and souvenirs.

We have serious concerns with the impacts the proposal could have on these benefits and ways of life. To ensure more protection not less, this proposal should meet the following principles:

• Ensure clean water protections extend to all streams and adjacent wetlands and other waterbodies that science shows to be ecologically or economically important for our outdoor way of life.

• Recognize that the health of larger water bodies depends on the health of smaller waters by grounding any changes to federal policy in sound wetland and stream science.

• Incorporate the work done to develop the Clean Water Rule, finalized in 2015, and consider that work as a starting point for determining future changes.

• Do not rely on legal interpretations that include only “relatively permanent waters” and wetlands with a “continuous surface connection” to those waters as these will limit the scope of the Clean Water Act.

• Ensure an inclusive, transparent, and robust public process equal to that of the 2015 rulemaking.

This new rule meets none of these. We ask you to ask you to withdraw your proposal.

Clean water benefits us all. We rely on it for drinking, our health, and for recreational activities. It is good for businesses, providing for many jobs and building our economy. We hope you keep this in mind and withdraw this rule and protect American’s access to safe, clean water.

Sincerely,

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