American Agri-Women Encourages Comments to the EPA

Posted on: June 23rd, 2014

by Arwen McGilvra

American Agri-Women recently sent out this update- We’re sharing news regarding the latest issue with the Clean Water Act and the EPA — and offer a chance for you to get involved and submit comments. The latest issue is related to the definition of the scope of “waters of the US.” The comment period is open until July 21. 

Here is background information from Karolyn Zurn, chair of AAW’s Resolutions & Vital Issues Committee:

The latest concern with the Clean Water Act is the EPA overreach that threatens our livelihood and will put farmers and ranchers in a grave position to protect their land.

Here are the related AAW position statements:

#226. AAW supports a national water quality policy on non-point source pollution that gives states the control to develop and manage water quality programs specific to the states’ own watershed issues. Programs under the Clean Water Act should promote the use of voluntary Best management Practices (BMPs) by rural landowners, agricultural producers and urban natural resources users.
#240. AAW demands retention of the word “navigable” in the Clean Water Act.
#240 ON NAVIGABLE WATERS AAW opposes proposed changes to the Clean Water Act that expand federal government’s jurisdiction over all intrastate waters including groundwater, storm water, ditches, farm and stock ponds and prior converted cropland.

Please comment by July 21 at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2011-0880-0001. Follow the link and then click on “Comment Now” in the upper right.

OWA’s Positions on water rights are:

·OWA recognizes agriculture as a priority user of water to continue producing the public benefits of food, fiber and shelter as opposed to prioritizing water for wildlife, recreational and scenic uses.
·OWA supports existing water rights and opposes additional water user fees.
·OWA supports retaining the word “navigable” in the Clean Water Act.

Sample Letter to the EPA:

Docket ID No. EPA-HQ-OW-2011-0880

I am concerned with the proposed changes to the Clean Water Act. I come from a multi-generation farm family and am very concerned with taking care of our natural resources so that the farm can see many more generations. However this proposed change is an overreach that threatens our livelihood and will put farmers and ranchers in a precarious position.

Instead of clarifying the Clean Water Act “in light of the U.S. Supreme Court cases” it adds more confusion. Property owners will be left with more uncertainty and no guarantee of due process for deciding if water on private property falls under the new rules.

Particularly worrisome is expansion of “other waters” and the use of the term “significant nexus.” This leaves a lot of gray area that is subjective to the opinions of EPA regulators.

I support the positions of the American Farm Bureau Federation which believes that the Clean Water Act “should be limited to navigable streams and waterways that have continuous flow.”

I also support the position of the American Agri-Women (AAW) which states “#226… Programs under the Clean Water Act should promote the use of voluntary Best management Practices (BMPs) by rural landowners, agricultural producers and urban natural resources users.”

Please “ditch the rule” as it will only be troublesome and burdensome to farmers, ranchers, and property owners. Work with natural resource and property right groups to come up with a better way to clarify the Clean Water Act.

 

Respectfully,

Arwen McGilvra

Albany, OR

 
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