Suwannee Riverkeeper, among 64 U.S. Waterkeepers, joined Waterkeeper Alliance and Environmental Integrity Project in asking the U.S. Environmental Protection Agency and the U.S. Army Corps of Engineers to maintain and restore longstanding protections for the nation’s waters.

Waterkeeper Alliance advocates EPA and USACE restore longstanding protections for the nation’s waters 2025-04-23

Most of this long comment letter is applicable to the Suwannee River Basin. For example, related to the ongoing Georgia attempts to define which rivers and creeks are navigable: “lUnder the agencies’ Pre-2015 Regulatory Definition, all tributaries to traditionally navigable waters, interstate waters, impoundments, and ‘other waters’ are categorically defined as ‘waters of the United States.’” For example, see Valdosta sewage into Sugar Creek and Quitman sewage and cattle manure into Okapilco Creek, both into the Withlacoochee River in Georgia, upstream from Florida and the Suwannee River.

The comment doesn’t mention the Floridan Aquifer, but there are mentions of “Large numbers of rivers and streams… that briefly flow subsurface and then reemerge as surface waters.” and river-connected “subsurface flows and springs” elsewhere. Subsurface flows are important in the Suwannee River Basin and the Floridan Aquifer.

The Florida Basin Managment Action Plans (BMAPs) supposedly intend to reduce by 85-95% the leaching of fertilizer nitrates through the soil and subsurface limestone into springs and rivers, causing algae blooms and crowding out native vegetation, to the detriment of manatees and other wildlife.

See also the Dead River Sink where the Alapaha River goes underground and comes back up in the Alapaha River Rise on the Suwannee River.

Dead River Sink, 2021-11-07

Here’s the introduction to the comment letter.

April 23, 2025

Submission via www.regulations.gov

Robyn S. Colosimo
Senior Official Performing the Duties of the Assistant Secretary of the Army (Civil Works)
Department of the Army
Environmental Protection Agency
EPA Docket Center, Water Docket, Mail Code 28221T,
1200 Pennsylvania Avenue NW,
Washington, DC 20460

Benita Best-Wong
Deputy Assistant Administrator for Management, Office of Water
Environmental Protection Agency
EPA Docket Center, Water Docket, Mail Code 28221T,
1200 Pennsylvania Avenue NW,
Washington, DC 20460

Re: WOTUS Notice: The Final Response to SCOTUS; Establishment of a Public Docket; Request for Recommendations, Dkt. ID EPA–HQ–OW–2025–0093

Dear Senior Official Colosimo and Deputy Assistant Administrator Best-Wong:

Waterkeeper Alliance, Environmental Integrity Project, and the undersigned U.S. Waterkeepers (collectively “Commenters”) submit the following comments on the U.S. Environmental Protection Agency’s (“EPA”) and the Department of the Army, U.S. Army Corps of Engineers’ (“Corps”) (collectively the “agencies”) notice1 requesting recommendations on the regulatory definition of “waters of the United States” (“WOTUS”) under the Federal Water Pollution Control Act, 33 U.S.C. § 1251 et seq. (“Clean Water Act”), and the implementation of the WOTUS definition in light of the Supreme Court’s 2023 decision in Sackett v. EPA, 598 U.S. 651 (2023) (“Sackett”).

On behalf of our organizations and our respective individual members and supporters, we write to emphasize the importance of maintaining, and where possible, consistent with Supreme Court precedent, restoring longstanding protections for the nation’s waters. As the agencies contemplate additional administrative action regarding the WOTUS definition, it is imperative that the protections in the current regulatory definition be maintained and that any amendments and reinterpretations of that regulatory definition through rulemaking, guidance, memoranda, or other means, fully restore protections consistent with the objective, structure, and text of the Clean Water Act, the entire body of case law interpreting the Act, and sound science. 2 The agencies must reject calls to further narrow the scope of Clean Water Act jurisdiction in order to achieve bureaucratic policy goals like reducing “red-tape” that are contrary to the objective and text of the Act, including through the adoption of unfounded reinterpretations of settled law or the creation of definitional limitations and implementation measures that will exclude waters from protection.

The whole comment is on the WWALS website. Images are below of all of its pages.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

You can help with clean, swimmable, fishable, drinkable, water in the 10,000-square-mile Suwannee River Basin in Florida and Georgia by becoming a WWALS member today!
https://wwals.net/donations/

WKAC

Introduction
PDF

CWA

II. The Clean Water Act Requires Broad Protections for the Nation’s Waters
PDF

WOTUSDef

III. A Broad and Legally Sound WOTUS Regulatory Definition is Critically Important to the Integrity of the Nation’s Waters
PDF

Effects

IV. The Impacts of Eliminating Protections in the WOTUS Regulatory Definition
PDF

CT

V. Comments on Topics Identified in the March 24, 2025 Notice
PDF

Tribs

A. Tributaries
PDF

WL

B. Adjacent Wetlands and Relatively Permanent Lakes, Ponds, and Other Intrastate, Non-navigable Waters
PDF

Des

C. Ditches
PDF

Signatories

Respectfully submitted,
PDF

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

You can help with clean, swimmable, fishable, drinkable, water in the 10,000-square-mile Suwannee River Basin in Florida and Georgia by becoming a WWALS member today!
https://wwals.net/donations/

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