Earlier today ACRA submitted comments regarding proposed changes to the definition of Waters of the United States (WOTUS). The new definitions aim to restrict the US Army Corps of Engineers’ jurisdiction by removing seasonal and ephemeral water courses from federal regulation. our response focuses on the lack of adequate public comment time, the elimination of well-developed legal concept of “significant nexus,” and lack of incorporating or using scientific data in making jurisdictional decisions. The rule inappropriately excludes major season streams from environmental review, a change that has serious potential implications on ACRA member firms.
Read ACRA's full comments here, and let us know how the proposed changes could affect your firm in the comments below.
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