December 29, 2025
Comment re: Updated Definition of ‘Waters of the United States’ Docket ID No. EPA-HQ-OW-2025- 0322
We are writing on behalf of more than 4,700 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 50,000 years of national park management and stewardship experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former National Park Service (NPS) directors, regional directors, superintendents, resource specialists, park rangers, maintenance and administrative staff, volunteers and other supporters.
We strongly oppose efforts to dramatically restrict which bodies of water are protected by the Clean Water Act. These protections would be substantially weaker by a proposed rule announced on November 17, 2025, by the EPA and the Army Corps of Engineers. If enacted, this rule would erase basic Clean Water Act protections for millions of acres of wetlands and millions of miles of rivers and streams across our country, including small headwater streams that may not flow continuously year-round. These “intermittent and ephemeral” streams, no matter how small, are significant to the health of downstream lands and waters.
These streams provide essential fish and wildlife habitat that support a robust outdoor recreation economy worth over $1 trillion. In 2024, 332 million visitors travelled to the 433 National Park System units covering more than 85 million acres in all 50 states, the District of Columbia, and US territories. They relied on these streams and bodies of water for their enjoyment and recreation. These national park sites also provide habitat for many species, including those that are threatened and endangered, and clean water sources are vital to their continued existence.
Damage or destruction of small streams and wetlands will result in damage and loss of flow to downstream waters, resulting in loss of habitat for fish and wildlife. Wetlands filter pollution, recharge groundwater, and reduce flooding, putting the drinking water of millions at risk by allowing pollution to flow more freely downstream. Once they’re gone, they don’t come back on their own.
To be effective, the Clean Water Act must be able to control pollution at its source – upstream in the headwaters and wetlands that flow downstream through communities to our major lakes, rivers, and bays.
Protecting our watersheds and ensuring that clean, fresh water is available for wildlife, visitors to national parks and other recreation areas, as well as communities, is vital. Therefore we oppose this rule.
Sincerely,
Phil Francis
Chair of the Executive Council
Coalition to Protect America’s National Parks
Email:Ed****@********ps.org
Mail: 2 Massachusetts Ave NE, Unit 77436, Washington, DC 20013
Web: www.protectnps.org
Phone: (202) 819-8622