American Fisheries Society • Association for the Sciences of Limnology and Oceanography • Coastal and Estuarine Research Federation • Freshwater Mollusk Conservation Society • North American Lake Management Society • Society for Freshwater Science • Society of Wetland Scientists • Phycological Society of America
20,000 Scientists Warn that Repeal of Wetlands Rule Puts Important Aquatic Resources at Risk
(July 27, 2017) Washington, D.C. – The Consortium of Aquatic Science Societies (CASS) opposes the Trump Administration’s ongoing efforts to repeal and replace the 2015 Clean Water Rule (Waters of the United States Rule or WOTUS). CASS urges the EPA and the U.S. Army Corps of Engineers to consider the far-reaching implications to aquatic resources from repealing the rule and calls for a meaningful opportunity for stakeholders to engage in the repeal and replacement of WOTUS to ensure the best available science is considered.
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.[i]
CASS is particularly concerned with the removal of the long-recognized value of ecosystem services provided by wetlands from the Administration’s cost-benefit analysis that is used to justify the repeal of the rule. 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.
Freshwater and marine wetlands provide many services that promote human well-being and are critically important to aquatic resources and the health of our nation’s 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 to feed, nest, breed, spawn, and rear their young. Our nation’s wetlands cover a small proportion of our landscapes (<6% of the lower 48 states), yet they contribute many times their proportional share in services to human well-being.
Dr. Colden Baxter, President of the Society for Freshwater Science stated, “More than a century of scientific research has unequivocally demonstrated that the physical, chemical, and biological integrity of entire river networks depend on ephemeral, intermittent, and perennial headwater streams, as well as the myriad associated lakes, wetlands, and off-channel habitats.”
This overwhelming scientific evidence formed the basis for WOTUS, yet the proposed repeal ignores carefully collected data and heavily scrutinized studies. WOTUS is a scientifically defensible regulation that defines the scope of Clean Water Act jurisdiction in a way that bolsters its effectiveness in maintaining and restoring our nation’s waters and, in doing so, protects the public interest in flood control, water quality, and fisheries and associated biological resources.”
Dr. Douglas Austen, Executive Director of the American Fisheries Society (AFS), stated that “the 2015 Clean Water Rule provided a scientifically sound definition of ‘Waters of the U.S.’ The move to roll back the rule puts America’s headwater streams and wetlands at greater risk of being destroyed or polluted and imperils vital habitat for fish and aquatic resources.”
Dr. Robert Twilley, President of the Coastal and Estuarine Research Federation (CERF) and a professor at Louisiana State University, said: “Estuaries and coastal waters rely on clean water from upland watersheds to support productive commercially and recreationally valuable fisheries of the United States. The definition of ‘Waters of the United States’ was a joint effort of industry, private landowners, and government that recognized the importance of headland and other wetlands in providing the water quality that supports downstream economies.”
Dr. Arnold van der Valk, President, Society of Wetland Scientists (SWS) and a professor at Iowa State University, decried the decision to repeal and replace the current WOTUS rule and noted, “It will result in the loss of many of the nation’s wetlands. This decision is short-sighted and counterproductive. It will significantly reduce the multitude of ecosystem services that these wetlands currently provide us at no cost. As a result, the tax payers will have to pay to build elaborate and expensive infrastructure to replace these free ecosystem services, such as flood reduction and cleaning up polluted water.”
Dr. Linda Duguay, President of the Association for the Sciences of Limnology and Oceanography (ASLO) stated, “As aquatic scientists, we know how tricky it can be to define where a waterbody begins and ends. WOTUS was crafted with input from a diverse range of stakeholders and with reference to a host of peer-reviewed studies regarding the connectivity of aquatic systems. Repealing the rule at this juncture would undo years of open and deliberate rulemaking, unnecessarily placing the nation’s aquatic resources at risk.”
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CASS is comprised of seven professional societies representing almost 20,000 individuals with diverse knowledge of the aquatic sciences. Those members work in the private sector, academia, non-governmental organizations, and various tribal, local, state, and federal agencies. CASS represents professional scientists and managers who combine deep subject matter expertise, a commitment to independent objectivity, and the critical review of environmental information, along with a passion for the natural places and resources that form the foundation of American greatness. CASS supports the development and use of the best available science to sustainably manage our freshwater, estuarine, coastal, and ocean resources to the benefit of the U.S. economy, environment, and public health and safety.
For more information, please contact Martha Wilson or Tom Bigford at AFS:
[i] See the Amicus brief filed with the U.S. Court of Appeals for the Sixth Circuit, http://www.stetson.edu/law/international/biodiversity/media/amici_curiae_brief_of_wetland_and_water%20_scientists-01-20-17_filed.pdf, and the EPA technical report, Connectivity of Streams and Wetlands to Downstream Waters: a Review & Synthesis of the Scientific Evidence (EPA/600/R-14/475F).