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  • Home
    • Contact Us
    • Join or Renew 2022-2023
    • Donate
  • About
  • Issues/Projects
    • Green Waters: Algae Blooms
    • Stormwater Education Project >
      • Useful Resources for All
      • Homeowner Solutions
      • Neighborhood & Regional Solutions
      • Manage Stormwater Protect Lake Michigan
    • Coal Tar Sealants
    • Native Plants
    • Watershed Education
  • Member Resources
    • League Administration
    • 2021 Annual Conference
    • 2020 Annual Conference
    • 2019 Annual Meeting Conference
    • 2022 Climate Forum
    • 2022 Conference

Rulemaking on the Waters of the United States

Help strengthen the Clean Water Act!  Submit comments supporting the
Rulemaking on the Waters of the United States (WOTUS).


The League of Women Voters worked to help pass the Clean Water Act (CWA) of 1972 and has continued working to see it strengthened in the decades since.  Supreme Court decisions in 2001 and 2006 (the SWANCC and Rapanos decisions) created uncertainty about whether certain waters are covered by the CWA, thwarting regulators' ability to protect those waters. The Army Corps of Engineers and the Environmental Protection Agency (EPA) have published a rule which will provide clarity and allow for cleaner water for Lake Michigan, the other Great Lakes, and waters across the country.  Citizens are invited to comment on the rule through November 14, 2104.  Please review the resources below, then submit your comments.

To read the rule, see Clean Water Act; Definitions: Waters of the United States.

Thanks to everyone who participated in our conference call on October 24, and our webinar on October 29 to learn more about this rulemaking.  Thanks especially to Karen Hobbs, Senior Policy Analyst, Natural Resource Defense Council, for taking the time to educate us during both of these events.  

In response to a question during the webinar, Karen referred us to the
EPA’s Science Advisory Board report on the connectivity of different types of waterbodies.  This document endorses the science behind why it is necessary to have the CWA cover a wider variety of waters.
Picture
The rule will bring many small streams and wetlands under the protection of the Clean Water Act.

Additional Information

Materials from the US EPA:
Supporting Materials for the Definition of the Waters of the United
     States
, including technical, scientific, and economic analysis of
     the rule.

Waters of the US website is loaded with information written with
     citizens in mind and has scores of links to additional sources.

Ditch the Myth website debunks some misconceptions about the
     rule.

From Our Friends:
Natural Resources Defense Council
Clean Water Act page includes a fact sheet & many great links.

Act Now page has a form to submit comments through their site.

Healing Our Waters-Great Lakes Coalition
Waters of the US blog posts on their website. One is an Action
     Alert.



How to Submit Comments

Suggested comments are found below.  Please personalize the template to reflect your own views and situation, or, if you wish, feel free to cut and paste it as it is.

There are three ways to submit comments:
  • Federal e-Rulemaking Portal:  http://www.regulations.gov
          Click the "Comment Now" button and follow the
          directions.
  • Email to: ow-docket@epa.gov                                                 Include EPA-HQ-OW-2011-0880 in the subject line of the message.  Please cc us at lwvlakemichigan@gmail.com so we can keep track of email submittals.
  • Mail:  Send the original and 3 copies of comments to: 
               Water Docket, Environmental Protection Agency
               Mail Code 2822T
               1200 Pennsylvania Avenue NW
               Washington, DC 20460

               Attention: Docket ID No. EPA-HG-OW-2011-0880

The comment period ends November 14, 2014.  But don't delay--take action today!  Our Great Lakes depend upon it!


SUGGESTED COMMENTS 
Based on LWVMI comments previously submitted. Personalize as desired.

RE: Docket ID No. EPA-HQ-OW-2011-0880

I support the Army Corps and EPA's rulemaking recommendations to define the waters of the United States.  Clarity will provide
regulators the authority needed to protect our water quality, public health and environment.

Water knows no boundaries and all waters function as an interconnected system.  It is imperative to protect all
tributaries, including wetlands and in-stream flows, to Lake Michigan and the Great Lakes, which provide drinking water for 40 million people.
I support stringent controls to protect the quality of current and potential drinking water supplies including protection of watersheds for surface supplies and recharge areas for groundwater.

Thank you for the opportunity to comment on the proposed rules for the Clean Water Act and voice my support for regulations that will ensure water quality.

Sincerely,


your name and contact info


LWV & the Clean Water Act:  History & Relevant Positions

The LWVUS approved submission of comments on the CWA Rulemaking for the LWV Michigan in the summer of 2014.  LWVUS granted permission for LWVLMR members to submit similar comments in advance of the LWVLMR Annual Meeting held in early October, 2014. 

The LWVUS publication, Impact on Issues (2012) states in the Natural Resources section,
The League’s citizen activists helped pass the landmark Clean Water Act in the early 1970s and worked to protect, expand and strengthen it through the 1990s. Water issues, from groundwater protection to agricultural runoff to the Safe Drinking Water Act, have energized League leaders, especially at the local level, for decades. (p. 43)
The Resources Management subsection of the Natural Resources section refers to the League's involvement in water policy prior to the adoption of the Clean Water Act. It states,
The League’s 1956-1958 water resources study was the basis for action on a broad range of resource management issues. By 1958, the League had taken a position that, as rephrased and expanded in 1960, has formed one of two foundations for League action on water ever since. The key concept is a strong federal role in formulating national policies and procedures. (p. 44)
The LWVUS Natural Resources positions contain many statements which lend support for the rule, including the following:
  • "water resource policies should reflect the interrelationships of water quality, water quantity, ground water and surface water;"
  • support for "Stringent controls to protect the quality of current and potential drinking water supplies including protection of watersheds for surface supplies and recharge areas for groundwater;"
  • support for policies that "achieve water quality essential for maintaining species populations and diversity, including measures to protect lakes, estuaries, wetlands and in-stream flows."
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