Wednesday, November 12, 2014

My Comments on the Proposed Waters of the US Rule: 7 of 8: Ongoing Illegal Federal Regulation of Stormwater Ponds to Continue

My name is River Mud.  I am a wetland systems ecologist and twice-confirmed Professional Wetland Scientist with 17 years experience siting, monitoring, designing, and constructing habitat and stormwater projects in 14 states.   I have reviewed the documents proffered by the US EPA on the "New Rule" for Waters of the United States, and have also reviewed the Scientific Review Board's findings.  As a career professional in wetland and stream conservation, and as a staunch conservationist in my personal life and actions, I cannot and do not support the New Rule as currently drafted in October, 2014.  I have ample experience and expertise to support this position.

Stormwater Ponds
Comment:  EPA claims that stormwater ponds will not be regulated as wetlands under the New Rule.  However, some federal regulators have repeatedly attempted to regulate impacts to existing, maintained stormwater ponds if the pond has developed wetland vegetation.  Allegedly, federal mitigation has been required for pond basin "wetland" impacts associated with reconfiguring the footprint of an existing, maintained stormwater pond.

Recommendation:  Add language to the New Rule exempting from Section 404 all pond basins and slopes in pond and stormwater facilities that are adhering to the state's and municipality's guidelines for pond management and maintenance.  Abandoned stormwater ponds can be regulated as federal wetlands, as they have been for 20 years. 

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oakleyses said...
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