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Comments to EPA on the Clean Water Rule

The Trump administration is working to repeal the EPA’s Clean Water Rule, which provides important legal clarity on the extent of wetland area subject to the Clean Water Act, ensuring greater federal protection of wetlands. In our recent comments on the attempted repeal, we show how the EPA and Army Corps of Engineers obscured the value of wetlands protection in their proposal to repeal the rule. In revising the original economic analysis, which quantified the rule’s substantial environmental and economic benefits, the agencies use arbitrary and inconsistent assumptions to suggest that the rule is not cost-benefit justified.