Dec 1, 2023 Waters Advocacy Coalition (WAC) Final Comments on the National Ordinary High Water Mark
The Waters Advocacy Coalition (“WAC” or “Coalition”) submitted comments on the Interim Draft of the National Ordinary High Water Mark Field Delineation Manual for Rivers and Streams (“Draft Manual”). WAC represents a large cross-section of America’s construction, transportation, real estate, mining, manufacturing, forestry, agriculture, energy, wildlife conservation, and public health and safety sectors—all of which are vital to a thriving economy and provide much-needed jobs. WAC members’ activities, projects, and operations are often subject to Clean Water Act (“CWA”) regulation.
The comments detail how:
I. EPA and the Corps Must Go Through Rulemaking to Change the Scope of CWA Jurisdiction
II. At a Minimum, the Agencies Must Reaffirm That the OHWM Has No Relevance to the Relatively Permanent Standard
