Coalition Comments on EPA’s Connectivity Report

The American Farm Bureau Federation and 35 other organizations comprising the Waters Advocacy Coalition recently filed detailed comments with the Environmental Protection Agency highlighting significant problems with the agency’s report, Connectivity of Streams and Wetlands to Downstream Waters: A Review and Synthesis of the Scientific Evidence. EPA announced the availability of the report in September. It synthesizes the peer-reviewed scientific literature on the connectivity of streams and wetlands relative to downstream waters. 


The coalition noted in the comments that the report provides no scientific support to make distinctions between significant connections and insignificant connections; assumes, with little scientific support, that all connections, no matter the kind, size, or frequency, are considered equivalent; does not account for site specificity, regional variability or temporal variability; and speaks in generalities that cannot be used to support specific applications or significant policy choices.