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Letters of Comment

Following are letters of comment in reference to issues related to or affecting the practice of wetland science. 

 SWS-logo-2015-H-LONG


Scientific societies respond to proposed WOTUS Repeal

21 September 2017

Re: Docket ID No. EPA-HQ-OW-2017-0203; FRL-9962-34-OW; Definition of “Waters of the United States” - Recodification of Pre-existing Rules

Dear Administrator Pruitt and Deputy Assistant Secretary Lamont:

We are submitting these comments regarding the proposed rule, Definition of “Waters of the United States” - Recodification of Pre-existing Rules, EPA-HQ-OW-2017-0203; FRL-9962-34-OW, published in the Federal Register on July 27, 2017; on behalf of the approximately 200,000 members of the Societies listed in the next paragraph. Our societies strongly oppose the proposed rule to rescind the definition of “Waters of the United States” (WOTUS) as promulgated by the Agencies in 2015 (Clean Water Rule: Definition of Waters of the United States; 80 FR 37054, June 29, 2015) (2015 CWR). Continue reading.


CASS requests proposed WOTUS Repeal not be exempted from the Administrative Procedures Act

21 September 2017

Dear Chairman Murkowski and Ranking Member Udall,

The Consortium of Aquatic Science Societies (CASS) would like to urge your subcommittee not to adopt a policy rider that would allow the federal government to exempt the administration’s proposed repeal of the Clean Water Rule from the Administrative Procedures Act. The repeal of Clean Water protections requires a meaningful opportunity for stakeholders to engage in the process to ensure the best available science is considered. At a minimum, the public should have the opportunity to comment on this critically important issue. Continue reading.


Professional Societies language in committee report accompanying FY2018 Dept. of Interior, Environment & Related Agencies Appropriations bill

16 August 2017

Dear Chairman Frelinghuysen, Ranking Member Lowey, and Committee Members:

The undersigned organizations thank you for your recognition of the importance of professional societies in the committee report that accompanies the Fiscal Year 2018 (FY 2018) Department of the Interior, Environment, and Related Agencies Appropriations bill.

House Report 115-238 highlights on page 7 the valuable role professional societies hold in assuring sound scientific management principles are applied to resources management through strengthening competencies of the federal workforce. Federal employees benefit greatly from participation in professional societies, which provide opportunities for continuing education, access and contribution to scientific journals, and meaningful interaction with other professionals. Such networking is key to enhancing collaboration between federal, state, and local governments, non-governmental organizations, and private industries. Continue reading.


20,000 scientists warn that repeal of Wetlands Rule puts important aquatic resources at risk: 

27 July 2017

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. Continue reading


SWS supports the Herring River Restoration Project: 

6 June 2017

Dear Boards of Selectmen for the Towns of Wellfleet and Truro and Acting Superintendent Kathy Tevyaw for the Cape Cod National Seashore,

The Society of Wetland Scientists (SWS) is an international scientific society, representing approximately 3,000 members from 58 countries, whose mission is to promote understanding, conservation, protection, restoration, science-based management, and sustainability of wetlands. SWS members work in the private sector, academia, and various tribal, state, federal, and international agencies. The New England Chapter of the SWS is dedicated to fostering conservation, restoration and understanding of wetland issues in the six New England states. 

SWS supports the Herring River Restoration because of the regional, national and international significance of the project, which will provide extensive benefits to estuarine wetlands as well as contributing to the advancement of the science of wetland restoration (as outlined in the attached information and in this letter). SWS wishes to endorse ongoing support for the project as it moves forward with the implementation phase. Continue reading


SWS and partners support FY2018 funding for scientific research and education:

23 May 2017

Dear Members of Congress,

As leading scientific organizations in the biological sciences, we urge you to make strong investments in scientific research and education in fiscal year 2018, and to reject the deep cuts to federal research programs proposed in the President’s budget request.

Research is an important engine that powers our economy. Over the past 50 years, roughly half of our nation’s private sector economic growth has resulted from research and development. Continue reading


CASS supports FY18 funding for EPA, NASA and NOAA:

26 April 2017

The Consortium of Aquatic Scientific Societies (CASS) is comprised of six professional societies representing diverse knowledge of the aquatic sciences. CASS members include the: American Fisheries Society, Association for the Sciences of Limnology and Oceanography, Coastal and Estuarine Research Federation, Phycological Society of America, Society for Freshwater Science, and Society of Wetland Scientists. Our collective membership totals almost 20,000 individuals that span the private sector, academia, non-governmental organizations, and various tribal, state, and federal agencies. The CASS organizations represent professionals 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. We support 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.

CASS writes in strong support of the Environmental Protection Agency (EPA), National Aeronautics and Space Administration (NASA) and National Oceanic and Atmospheric Administration (NOAA) programs that support the research, conservation, restoration, and sustainable use of aquatic ecosystems required by all U.S. citizens, who rely on clean and abundant water for their health and well-being.

Read the full letter to the House in support of the EPA.

Read the full letter to the Senate in support of the EPA.

Read the full letter to the House in support of NASA.

Read the full letter to the Senate in support of NASA.

Read the full letter to the House in support of NOAA.

Read the full letter to the Senate in support of NOAA.


Endorsement of Amici Curiae Brief of Wetland and Water Scientists in Support of the Clean Water Rule:

1 March 2017

Dear President Trump:

The Society of Wetland Scientists (SWS), American Fisheries Society (AFS), American Institute of Biological Sciences (AIBS), Ecological Society of America (ESA), Phycological Society of America (PSA), Society for Ecological Restoration (SER), and Society for Freshwater Science (SFS) support the sustainable management of the nation’s waters. We are science-based organizations with diverse areas of expertise in the ecological and biological sciences. Our collective 200,000+ members and 130+ professional societies and research organizations work in the private sector, academia, and various tribal, state and federal agencies. As non-profit organizations, we support and foster sound science, education, restoration and management of wetlands and other aquatic resources. Thus, we track policies and actions that affect these aquatic resources and we promote science-based policy-making.

The United States Court of Appeals for the Sixth Circuit is reviewing the U.S. Environmental Protection Agency and the U.S. Army Corps of Engineers’ Clean Water Rule, which defines the geographic coverage of the Clean Water Act. Recently, wetland and aquatic scientists filed an amici curiae brief with the court in support of the Clean Water Rule. The organizations that have signed this letter agree with the brief and its use of sound science to explain the urgent need for the Clean Water Rule. Continue reading.


Endorsement of Amici Curiae Brief of Wetland and Water Scientists in Support of the Clean Water Rule:

1 March 2017

Dear Members of Congress:

The Society of Wetland Scientists (SWS), American Fisheries Society (AFS), American Institute of Biological Sciences (AIBS), Ecological Society of America (ESA), Phycological Society of America (PSA), Society for Ecological Restoration (SER), and Society for Freshwater Science (SFS) support the sustainable management of the nation’s waters. We are science-based organizations with diverse areas of expertise in the ecological and biological sciences. Our collective 200,000+ members and 130+ professional societies and research organizations work in the private sector, academia, and various tribal, state and federal agencies. As non-profit organizations, we support and foster sound science, education, restoration and management of wetlands and other aquatic resources. Thus, we track policies and actions that affect these aquatic resources and we promote science-based policy-making.

The United States Court of Appeals for the Sixth Circuit is reviewing the U.S. Environmental Protection Agency and the U.S. Army Corps of Engineers’ Clean Water Rule, which defines the geographic coverage of the Clean Water Act. Recently, wetland and aquatic scientists filed an amici curiae brief with the court in support of the Clean Water Rule. The organizations that have signed this letter agree with the brief and its use of sound science to explain the urgent need for the Clean Water Rule. Continue reading.


CASS letter to President-Elect Trump: 

21 November 2016

Dear President-Elect Trump,

The Consortium of Aquatic Scientific Societies (CASS) is writing to offer our best wishes and assistance as you begin your Presidency. We understand that your transition team and future administration will have many important decisions to make regarding our Nation’s aquatic resources, and CASS is ready to provide the requisite expertise to help your administration address those pressing concerns. Continue reading.


SWS letter to Mayor Chen regarding the Jiading Wetland: 

Mayor CHEN, Chu
Mayor of Kaohsiung City Government
Taiwan

5 October 2016

Dear Mayor Chen:

On behalf of the Society of Wetland Scientists (SWS), we would like to express our concern about the recent plans for the construction of Road 1-4 through the Jiading Wetland area. The Society has a world‐wide membership of more than 3,000 wetland professionals from 58 countries, whose mission is “to promote understanding, conservation, protection, restoration, science-based management, and sustainability of wetlands’’ (see www.sws.org). It has come to our attention that the Kaohsiung City government has decided to move ahead with plans to construct Road 1-4, which would reduce traveling time through the Jiading Wetland by only 90 seconds. The construction would dissect Jiading into two separate hydrologic units and endanger the natural functions and services of this wetland. We also understand that this is a deviation from the earlier established understanding that Jiading could be designated as a Taiwan Wetland of International Importance, using the Ramsar definition of designating wetlands of International Importance (see below) and be allowed to remain wholly intact. We hope to make you aware of the current services and benefits provided by the wetland to the people of the region and the potential impacts any change to the management/protection of this area might incur. Continue reading.


ScienceDebate's 2016 top presidential questions:

10 August 2016

Dear (Candidate)
and Key Campaign Policy Staff,

Attached please find a presidential candidates questionnaire entitled: 2016’s Top Presidential Science, Engineering, Technology, Health and Environmental Questions.

These 20 questions were solicited from the public and refined by experts at America’s leading nonpartisan science and engineering organizations.

President Obama, Senator McCain, and Governor Romney answered similar questions in 2008 and 2012. Our promotion of their responses garnered more than 850 million earned media impressions for the candidates each cycle.

We kindly request that you attend a forum, hosted by our organizations, to discuss your positions on these 20 major policy questions, broadcast by a mutually agreed upon broadcast partner. Science, engineering, health and environmental issues affect every voter’s life as profoundly as the foreign policy, economic policy, and faith and values candidates often discuss on the campaign trail. In order to successfully manage these increasingly complex issues in the policymaking process, we need to find new ways to incorporate them into our national dialog. Your leadership will help the nation in that process, and polling shows that 87 percent of American voters want to know candidates’ views on these broad issues before they vote.

The ScienceDebate project is supported by nearly every major science organization and university in America. Thank you for your leadership and your attention to addressing these important policy issues with us and on the campaign trail. Continue reading.


SWS tells Congress amendment 3140 to Energy Policy Modernization Act would make climate change worse:

22 February 2016

Dear Majority Leader Mitch McConnell, Minority Leader Harry Reid, Chairwoman Lisa Murkowski, and Ranking Member Maria Cantwell:

We are 65 research scientists and practitioners who study energy, soils, forested and wetland ecosystems and climate change. We are writing in our individual capacities to express our concern over the implications of a “forest biomass carbon neutrality” Senate Amendment 3140 to the Energy Policy Modernization Act that was recently accepted by the US Senate.

This well-intentioned legislation, which claims to address climate change, would in fact promote deforestation in the U.S. and elsewhere and make climate change much worse. The amendment would require all federal departments and agencies to promote consistent policies that “reflect the carbon neutrality of forest bioenergy and recognize biomass as a renewable energy source.” Mandating that there are no carbon dioxide emissions from burning wood from forests to produce energy does not make it so in fact. Continue reading.


CASS strongly opposes Senate Joint Resolution 22, invalidating the final Clean Water Rule:

2 November 2015

Dear Senator:

We are writing today on behalf of CASS (Consortium of Aquatic Scientific Societies), a group of five scientific societies that include the American Fisheries Society, the Association for the Sciences of Limnology and Oceanography, the Phycological Society of America, the Society for Freshwater Science, and the Society of Wetland Scientists. Our member societies represent more than 12,000 professional aquatic and wetland scientists from academia, government agencies, private industry, NGOs, and elsewhere. Most of the leading freshwater and wetland scientists in the United States belong to at least one of our societies.

As the nation’s leading scientists, we strongly support the current final Clean Water Rule with its inclusion of headwater streams, including intermittent or temporary streams that do not have perennial flow but that do directly drain to a Traditional Navigable Water, interstate waters or the sea. There is ample scientific evidence that there are strong and varied physical, chemical, and biological connections between wetlands, headwater streams (whether they have perennial flow or not) and downstream navigable or interstate waters. Loss of protection of these waters will harm water quality, degrade drinking water, negatively impact water storage that leads to reduced flooding, reduce carbon storage, be deleterious to wildlife and fisheries resources, and cause other harmful impacts. Our member organizations continue to strongly endorse the importance of the Clean Water Rule and find efforts of Senate Joint Resolution 22 (S.J. RES. 22) to be harmful to the interests of the nation. Continue reading.


SWS urges mayor of Ohrid to preserve Studenchista Wetland and Lake Ohrid ecosystem:
Authored by Jos T.A. Verhoeven, Ph.D., Society of Wetland Scientists Europe Chapter President, and supported by SWS scientists Kimberli Ponzio, James Perry, Keith Edwards, Matthew Simpson, Rob McInnes

7 October 2015

Mr. Nikola Bakračeski
Mayor of the City of Ohrid
Dimitar Vlahov Street No. 57
6000 Ohrid
R. Macedonia

Respected Sir,

On behalf of the Society of Wetland Scientists (SWS), we would like to express our concern about the recent plans for the Studenchishta Wetland area.  The Society has a world‐wide membership of more than 3,000 wetland professionals whose mission is ‘to promote understanding, conservation, scientifically based management and sustainable use of wetlands throughout the world’ (see www.sws.org).  We have been informed about the current plan for Studenchishta, which is a deviation from the earlier established General Urban Plan for the town of Ohrid and environs and the broader Spatial Plan for Macedonia, which proposed the area as a Natural Monument1.  We hope to make you aware of the current services and benefits provided by the wetland to the people of the region and the potential impacts any change to the management/protection of this area might incur. Continue reading.


SWS responds to U.S. Wildlife Conservation Blue Ribbon Panel:

23 July 2015

Earlier this summer, the Society received a request from a Blue Ribbon Panel on Sustaining America’s Diverse Fish and Wildlife Resources for information on how to equitably and sustainably finance fish and wildlife conservation to help prevent more species from becoming endangered. The Panel reached out to influential organizations for ideas on how to sustainably fund conservation work that will benefit the full array of fish and wildlife. SWS sent the following response which was presented to the Panel in a summary report in Washington D.C. on July 23rd:

“The Society of Wetland Scientists is a non-profit, international organization of over 3,000 individuals who engage in research, science-based management, conservation, protection, restoration, and promotion of sustainability of wetlands around the world. Our membership includes employees of national, state, and local governments, academic institutions, NGO’s, and private consultants who are keenly interested in the actions and policies that affect wetlands and the variety of wildlife that make these diverse habitats their home. In 2008, we formed a Wildlife Section of the SWS that focuses on the relationships between wetland habitat dynamics and wildlife population dynamics. It is from this perspective that we offer these suggestions on how best to secure dedicated and sustained funding to support fish and wildlife conservation." Continue reading.


SWS supports the EPA proposed rule on waters of the U.S.: 
Compiled by SWS members Joy Zedler, Daniel Larkin and Carter Johnson

2 July 2015

SWS is an international membership organization of more than 3,000 wetland professionals dedicated to fostering sound wetland science, education, and management.

SWS supports the EPA proposed rule on waters of the US as follows:

  • The proposed rule is science-based, following EPA’s review of over 1,000 peer-reviewed papers on the physical, chemical, and biological connections by which streams, wetlands, and open-waters affect downstream waters such as rivers, lakes, and oceans. The review is comprehensive, clear, technically accurate, and it summarizes solid science. The proposed rule correctly addresses the provision of clean water, which is a well-known function of wetlands. Here, we emphasize and expand on the following topics:
    1. The quality of downstream waters depends on materials that are (or are not) discharged upstream in the watershed and carried by streams to wetlands that can remove materials and cleanse the water.
    2. The system of connected streams and wetlands includes wetlands that perform in aggregate, both synergistically and cumulatively. We illustrate this for the Prairie Pothole Region (PPR).
    3. Because water quality is degraded during and after flooding, SWS supports the need to protect wetlands to reduce flood risk. Continue reading.

The Deepwater Horizon disaster and wetland:
Compiled by Dennis F. Whigham, Chair, Stephen W. Broome, Curtis J. Richardson, Robert L. Simpson and Loren M. Smith, SWS Environmental Concerns Committee

18 May 2010

Coastal wetlands are essential components of healthy and productive coastal fisheries, and nowhere within the lower 48 states has the critical linkage between wetlands and fisheries resources been more clearly demonstrated than in the Gulf Mexico (e.g., Chesney et al. 2000, Crain et al. 1979). Louisiana alone, for example, generates 30% of the nation’s seafood production (Day et. al., 2005) and accounts for 40% of the total wetlands in the conterminous United States (Richardson and Pahl 2006). The ongoing loss of wetland resources in the Gulf of Mexico and the potential economic and environmental costs, especially in Louisiana and Florida, is an issue of international concern. The impacts of the current oil spill are unknown but the potential for direct and indirect environmental damage to coastal ecosystem services are extraordinary. Both the oil and the activities used in the cleanup have the potential to adversely affect wetland flora and fauna. Continue reading.


SWS encourages regeneration of cypress forests:
Authored by Past SWS President Christopher Craft

2 March 2009

On behalf of the Executive Board of the Society of Wetland Scientists (SWS), I write to support sound management and stewardship of cypress forests, including those harvesting practices that promote and ensure regeneration of the forest. The Society of Wetland Scientists is a 3500+ member organization that promotes scientific understanding, scientifically-based management and sustainable use of wetlands. The state of knowledge on cypress regeneration raises significant concerns over whether harvesting cypress in permanenntly or semi-permanently flooded areas results in a permanent loss of habitat and ecosystem services. Continue reading.