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Bedford Audubon Society Bedford Audubon Society, Inc. is a 90-year old not-for-profit chapter of National Audubon Society whose purpose is to promote conservation and protection of wildlife habitats in the Northern Westchester County and Eastern Putnam County region through education, advocacy, nature study and bird watching. In keeping with these goals, we are also a member of the Croton Watershed Clean Water Coalition. Our region contains a large number of so-called "isolated wetlands" which protect the water quality of New York City reservoir basins and tributaries. Due to real estate development pressures within our region, these isolated wetlands come under increasing threat due to their small size, coupled with the restrictions imposed by the SWANCC decision. They are crucial to both water quality in our watersheds and to ensuring wildlife habitat for threatened species here. The EPA's guidance and advance rulemaking will exclude many so-called "isolated" wetlands, streams, and ponds from the protection of the Clean Water Act. To do so would exclude critical habitat for wildlife that depends on it for migration, as a food source, as habitat, and for reproduction/nesting. These wetlands also offer other hydrologic functions such as absorption of floodwaters and filtering of naturally occurring pollutants. If the proposed rules were enacted today, the public and the government would be subject to higher costs for flood damage, degradation of wildlife habitat, and degradation of our drinking water quality. Last year, New York State Governor George Pataki and the New York District of the Army Corps of Engineers designated the whole East of Hudson Watershed as Critical Resource Waters, specifically to enforce increased protection for all water bodies, including isolated wetlands. Both the Governor and the Army Corps are aware of the importance of these isolated wetlands and acted for this reason. The New York State Legislature is currently considering a bill that may accomplish this statewide with the intent of filling the gap that the SWANCC decision has created in wetlands law enforcement. The Federal Government and specifically the E.P.A. should not abrogate it's responsibility to protect the public and enforce laws to protect our nation's waters. We can remember when the rivers running through the city of Cleveland, Ohio caught fire and raised public awareness of the importance of protecting our fragile waters. The guidance you have issued does not accomplish the task you have been charged with. Please rescind it. Very truly yours, e-mail
conservation@bedfordaudubon.org |
Bedford
Audubon Society