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NASAC Sends Letter of Comment on EPA's Water of the U.S.

The National Association of State Aquaculture Coordinatgors (NASAC) sent a letter of comment on EPA's “Waters of the United States Proposed Rule”

 

To Whom it may concern,

The National Association of State Aquaculture Coordinators (NASAC) represents aquaculture throughout the United States.  Our goal is to help aquatic farmers be successful and expand this growing industry in an environmentally sound and sustainable manner within our respective states and nationally. It is for those reasons that we would like to address the proposed EPA water rule.

We feel this rule, if implemented as stated, will restrict current operations, prohibit the future growth of the US Aquaculture industry and severely limit all of agriculture.  Water is quickly becoming a limited, precious resource, and we agree there is an emphatic need to conserve and protect. However, prohibiting water use will be detrimental to the agriculture community including its economic vitality and that of all support industries which in turn will affect consumers.

NASAC agrees with the Supreme Court findings limiting federal jurisdiction to navigable waters and recommends that the agencies, EPA and ACOE, abandon this attempt to define a phrase that appeared in a dissenting opinion, “significant nexus.” Instead the agencies would better serve the nation by defining navigable waters and waters of the United States in understandable, simple, and unambiguous terms.   This definition should abandon terms such as “adjacent,” “significant nexus,” and “neighboring” and focus clearly on the presence of water that is not admixed with soil. If the agency feels there is a concern that wetlands are unprotected, then the Administration should draft specific legislation focused on wetlands protection. 

NASAC works with all types of aquatic farmers; pond and raceway culturist, large lake farmers, reservoirs ranchers, shellfish farmers and algae growers, all with special water needs and requirements. Aquaculture is a water dependent industry, without good water, fish farmers would be out of business; fish farmers are good stewards of the watersheds in which they operate. In some cases aquaculture has actually benefitted environments by creating habitat and withdrawing nitrates and phosphorous from areas.

NASAC believes that agencies working with stakeholders can attain fair and equitable ways of protecting the water resources of the US without causing hardship to the agricultural communities or the consumers they serve. This will go hand in hand in protecting and ensuring our food security by allowing U S agriculture to expand as the population expands, without depending on foreign imports to feed our own. 

With respect, we support the EPA and the CWA, but not as proposed in the “Waters of the United States Proposed Rule”.

 

 

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