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November 08
​NACo Files Comments on EPA’s Connectivity Study

In response to the U.S. Environmental Protection Agency’s (EPA) draft Connectivity of Streams and Wetlands to Downstream Waters: A Review and Synthesis of the Scientific Evidence, NACo submitted comments to the Science Advisory Board (SAB) panel, which will be reviewing those comments at their December panel meeting.

The connectivity report will be used as the scientific basis for revising the “waters of the U.S.” definition within the Clean Water Act (CWA). The “waters of the U.S.” draft regulation is currently undergoing interagency review at the Office of Budget and Management (OMB).

NACo raised several concerns with the connectivity report within their letter and requested the comment period be extended 90 days due to the technical nature of the report. Because regions of the country differ significantly, impacts of the report on different regions need to be carefully analyzed. 

NACo noted that whether a conveyance is considered a “waters of the U.S.” will have a significant impact on local governments. The report essentially states that all streams are connected, regardless of size or flow. The report did not assess limits of connectivity nor the impact that various types of connections may have on downstream waters. To read NACo’s letter, click here.

Contact: Julie Ufner at or 202.942.4269


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