A letter to U.S. EPA and the Army Corps of Engineers outlining ACWA’s pre-proposal comments on the agencies intent to revise the Navigable Waters Protection Rule/ WOTUS. ACWA’s letter offers five recommendations:
(1) respect the role of the states as co-regulators and provide early, continuous, and meaningful opportunities for dialogue and input as any new rule is developed; (2) respect and follow the science; (3) recognize the geographic, geologic, climatic, hydrologic and leadership diversity among states and craft a definition that provides clarity but also flexibility for state implementers; (4) prepare to provide the states, well in advance, with technical assistance, tools and trainings to assist with implementation of any revised definition; and (5) include a delayed effective date to give state partners ample time to revise state regulations and/or to develop new state policy to cover any changes in coverage as a result of the revised jurisdictional definition.
WOTUS Pre Proposal Comments final
