Letters of Comment
Brief of the Society of Wetland Scientists as Amicus Curiae Brief of the Society of Wetland Scientists as Amicus Curiaein Support of Plaintiffs’ Motion for Summary Judgment
Summary of Argument: An agency must provide a reasoned explanation when promulgating or amending a rule. An agency’s implausible explanation or its failure to consider relevant and significant aspects of a problem renders a rulemaking arbitrary and capricious. Because the EPA and Corps refused to consider the scientific basis of the Clean Water Rule, including…
Read MoreScience Societies oppose the proposed addition of applicability date to Clean Water Rule
The Honorable Scott Pruitt Administrator U.S. Environmental Protection Agency Office of Policy Regulatory Reform Mail Code 1803A 1200 Pennsylvania Ave NW Washington, DC 20460 The Honorable Ryan Fisher Acting Assistant Secretary of the Army for Civil Works Office of the Assistant Secretary of the Army for Civil Works Department of the Army 104 Army Pentagon Washington, DC…
Read MoreScience Societies oppose Scalia definition of WOTUS
The Honorable Scott Pruitt Administrator U.S. Environmental Protection Agency Office of Policy Regulatory Reform Mail Code 1803A 1200 Pennsylvania Ave NW Washington, DC 20460 The Honorable Ryan A. Fisher Acting Assistant Secretary of the Army for Civil Works Office of the Assistant Secretary of the Army for Civil Works Department of the Army 104 Army Pentagon Washington,…
Read MoreCASS condemns silencing of EPA scientists
The Consortium of Aquatic Science Societies (CASS) is very concerned with the actions of the U.S. Environmental Protection Agency (EPA) to prohibit three EPA scientists from presenting their research at “The State of Narragansett Bay and Its Watershed” workshop in Providence, Rhode Island, on 23 October 2017. CASS values scientific freedom and recognizes the importance…
Read MoreCASS condemns silencing of EPA scientists
The Consortium of Aquatic Science Societies (CASS) is very concerned with the actions of the U.S. Environmental Protection Agency (EPA) to prohibit three EPA scientists from presenting their research at “The State of Narragansett Bay and Its Watershed” workshop in Providence, Rhode Island, on 23 October 2017. CASS values scientific freedom and recognizes the importance of collaboration among scientists…
Read MoreSWS urges Macedonia to preserve Studenchista Wetland and Lake Ohrid ecosystem
To: National Ramsar Committee of the Republic of Macedonia Ministry of Environment and Physical Planning of the Republic of Macedonia Government of the Republic of Macedonia On behalf of the Society of Wetland Scientists (SWS), an international expert organization with over 3,000 members, we would like to emphasize the pressing need for Lake Ohrid and…
Read MoreSWS comments on proposed WOTUS repeal
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: These comments are submitted 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…
Read MoreScientific societies respond to proposed WOTUS repeal
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,…
Read MoreCASS requests proposed WOTUS Repeal not be exempted from the Administrative Procedures Act
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…
Read MoreProfessional Societies language in committee report accompanying FY2018 Dept. of Interior, Environment & Related Agencies Appropriations bill
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…
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