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
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 firstname.lastname@example.org or