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ABC, as part of the Waters Advocacy Coalition, responded to a draft scientific report released by the Environmental Protection Agency (EPA) on the connectivity of water, which the EPA said is intended to guide a forthcoming proposed rule that would likely expand its jurisdiction under the federal Clean Water Act (CWA). The proposed rule has not been released publically, but is under review by the Office of Management and Budget (OMB).

In comments to the EPA, the coalition stated the report provides no scientific support to make distinctions between significant connections and non-significant connections. 

“Merely because a connection can be identified does not mean it is significant to downstream water quality or ecosystem health,” the coalition wrote. 

The coalition also pointed out that the report does not account for factors of variability in connectivity, such as climate, stream size, habitat, watershed characteristics, frequency and duration of flow, or proximity to navigable waters. 

The report titled, “Connectivity of Streams and Wetlands to Downstream Waters,” currently is being reviewed by the Scientific Advisory Board panel, an independent peer review.