Posted by Jane Clark

Urgent: Contact Your Representatives Today and Ask Them to Protect
Isolated Waters and Wetlands!

In January the Supreme Court dealt a blow to wetlands protections
nationwide.  The SWANCC decision (Solid Waste Agency of Northern Cook
County vs. Army Corps of Engineers) punched a hole in the Clean Water
Act's protection of isolated waters and wetlands.  Since then, Network
members have reported seeing bulldozers destroying countless isolated
wetlands throughout the country.

EPA and the Army Corps of Engineers are developing a guidance document
to be used by Corps Districts when determining if a waterbody falls
under the jurisdiction of the Clean Water Act as defined by the Supreme
Court SWANCC decision. We must ensure that this document defines
isolated waters in the most narrow way possible, consistent with the
Supreme's Court opinion.

Here is where you come in: Representatives are urging the EPA and the
Corps to issue joint guidance that retains as much legal protection as
possible for isolated wetlands and other waterbodies.  We need to get as
many representatives signing on to this letter as possible by COB
MONDAY, DEC. 10.  Please contact your representatives by calling the
Capitol Switchboard at 202-224-3121.  Ask to speak with the
environmental legislative assistant and deliver this message:

* I would like to urge Rep. X to protect our nation's wetlands.

* I ask Rep. X to sign on to the letter being circulated by Reps. Kind
and Gilchrest on isolated wetlands guidance by December 10.

A copy of the letter is included below and you can pass this on to
staffers as needed.

Thanks for your help and please pass this around to your organizaton's
members as well!


December XX, 2001

Christine Todd Whitman, Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., N.W. (1101A)
Washington, D.C. 20460

Mike Parker
Assistant Secretary of Army (Civil Works)
108 Army Pentagon
Washington, DC 20310-0108

Dear Administrator Whitman and Assistant Secretary Parker:

We strongly urge the Environmental Protection Agency and Army Corps of
Engineers to issue joint guidance as soon as possible which narrowly
interprets the U.S. Supreme Court's decision in Solid Waste Agency of
Northern Cook County (SWANCC) vs. Army Corps of Engineers.  The SWANCC
decision limited federal jurisdiction over certain non-navigable,
isolated wetlands and other waterbodies under the Clean Water Act.

The SWANCC decision was based on the narrow argument that federal
agencies could not use the migratory bird rule as the sole basis with
which to justify continued Clean Water Act jurisdiction over isolated
wetlands and other waterbodies.  Therefore, SWANCC only affects
agencies' authority to utilize this specific rule alone to assert
regulatory authority over wetlands and other waters.  This
interpretation of the Court's opinion is consistent with recent rulings
of lower federal courts and positions taken by the Department of
Justice.

Adopting a policy or guidance that gives an overly-broad reading to the
Court's decision in SWANCC would run counter to the letter and spirit of
the Clean Water Act itself.

When Congress adopted the Act in 1972, it made clear its objective "to
restore and maintain the chemical, physical, and biological integrity of
the Nation's waters."  The Act directs EPA and other federal agencies to
give "due regard," to "improvements which are necessary to conserve such
waters for the protection and propagation of fish and aquatic life and
wildlife [and] recreational purposes..."  Any interpretation that does
more than discard the use of the Migratory Bird Rule as the sole basis
for Clean Water Act jurisdiction conflicts with the law as well as with
the will of Congress when it adopted these far-reaching protections for
the nation's waters.

State officials have already expressed concern that the Supreme Court
decision will force them to extend their role in regulation of wetland
destruction.  The State of Wisconsin has already moved forward and begun
to implement an expanded state role in the regulation of wetland
destruction, however, this will place a greatly increased financial
burden on the state.  In addition, there is a disparity in existing
wetlands regulations between the states; some have adequate programs,
others do not.  To make matters worse, in the absence of guidance to
interpret this ruling, Corps districts across the country are taking
widely varying approaches to questions of jurisdiction, frequently
resulting in an overly-broad interpretation of the SWANCC ruling and
confusion about where federal jurisdiction ends.

We strongly urge you to issue joint guidance or rule-making that retains
as much legal protection as possible for isolated wetlands and other
waterbodies.  This will allow protection of millions of wetlands that
provide critical habitat for migratory waterfowl, store floodwater, and
improve water quality through filtration of sediments and nutrients.  As
you know, wetlands are some of the most biologically productive and
sensitive ecosystems in the United States.  We hope that you will work
hard to avoid the further loss of wetlands and the devastating
environmental and economic consequences that a broad interpretation of
this case may bring.

 Sincerely,

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