Best practices in voicing opposition of proposed repeal of the Waters of the US Clean Water Rule
Posted 02 August 2017 - 05:59 PM
American Society of Ichthyologists and Herpetologists
This is the first communication from the ASIH Conservation Committee via the Society's email blast encouraging individual comments to the Federal Register.
The rule to repeal the 2015 Waters of the United States (WOTUS) Clean Water Rule (CWR) was filed on July 27 in the Federal Register. Comments on the proposed rule to repeal are due by August 28.
The EPA proposed to rescind the 2015 Clean Water Rule in two steps, initially reverting to pre-2015 regulations, then replacing the existing and long-standing federal Clean Water Act regulation with a new Rule.
Here are some suggestions for comment:
State that you are writing to oppose the proposal to repeal the rule.
Provide brief detail.
a. EPA and the U.S. Army Corps of Engineers adopted WOTUS to clarify longstanding confusion over which water bodies were protected under the Clean Water Act. The rule was developed using the best available science and with robust engagement of stakeholders. More than 1,000 peer-reviewed, published, scientific studies support the rule.
b. The new EPA and USACOE economic analysis used to justify the repeal of the rule is flawed. The new Administrations cost-benefit analysis omits the long-recognized value of ecosystem services provided by wetlands. While methods to quantify the value of wetlands may have changed, there is significant research that conclusively demonstrates that society values the benefits of wetlands even more than in the past. (The new EPA Economic Analysis pertaining to the Clean Water Rule is available here. https://www.epa.gov/..._step1_rule.pdf You can also learn more.)http://sws.org/image...Updated7.17.pdf
c. Freshwater and marine wetlands provide many services that promote human well-being and are critically important to aquatic resources and the health of our nations waters. Wetlands keep our streams, lakes, and groundwater cleaner by treating urban and agricultural runoff through natural processes. They also provide water during times of drought, and absorb runoff and floodwaters, which reduce disaster recovery costs. Wetlands sustain essential habitat for commercially and recreationally valuable wildlife, fish, and waterfowl.
Urge the EPA and the U.S. Army Corps of Engineers to consider the far-reaching implications to aquatic resources from repealing the rule.
Call for a meaningful opportunity for stakeholders to engage in the repeal and replacement of WOTUS to ensure the best available science is considered.
Reiterate your opposition.
Comment using this link to the proposed rule in the Federal Register. https://www.federalr...-existing-rules
Frank H. McCormick,
Chair ASIH Conservation Committee
AMERICAN SOCIETY OF ICHTHYOLOGISTS AND HERPETOLOGISTS
P.O. BOX 1897
LAWRENCE, KANSAS 66044-8897 U.S.A.
PHONE: 1-800-627-0326 EXT. 405 FAX: 785-843-1274 ASIH@ALLENPRESS.COM
"No thanks, a third of a gopher would merely arouse my appetite..."
Posted 04 August 2017 - 11:43 AM
This can be a sensitive subject, and the "no religion, no politics" rule is generally good policy on message boards that do not directly involve these contentious subjects. However, since already broached. . .
Most of us here regard ourselves as conservationists, or we probably wouldn't be here, but I contend that it is possible to be a conservationist and also regard bureaucratic overreach as insidious and stifling of basic liberties and pursuit of happiness, often with dubious upside, with reasoned opposition dismissed as "anti-science".
There have been many threads here by small-time commercial fish farmers and native-aquarium-fish keepers alike lamenting the burdensome, confusing, and sometimes contradictory restrictions often placed on us, frequently accompanied by onerous penalties for noncompliance.
Much has been written about the ever-expanding jurisdiction of the EPA based on internal reinterpretations of decades-old law by unelected bureaucratic lifers.
Here are a few cogent counter arguments, for completeness.
As your fellow, I can demand of you no more, and accept no less, than I allow to be demanded of myself
Posted 05 August 2017 - 12:58 PM
True, we really don't have a federal law intended to protect wetlands and smaller non-navigable streams. EPA and other fed and state agencies have been stretching the Clean Water Act, Endangered Species Act, and other laws for many decades to achieve the habitat and health protections that we need, but don't specifically have laws for. "Leaving it up to the states" sounds like a reasonable strategy in a Federalist nation, but quite a few states have adopted rules that specifically prohibit their state (and all local governments within their state) from adopting environmental or health regulations more strict than federal standards. In essence, these states are rejecting the privilege and responsibility (to wisely manage their own resources) that our federalist system offers them.
Hangin' on the Neuse
"Taxonomy is the diaper used to organize the mess of evolution into discrete packages" - M.Sandel
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