The letter reads, in part, “The proposed redefinition of WOTUS will make it impossible to achieve the objectives of the CWA because it excludes numerous waters and wetlands that directly affect the chemical, physical, and biological integrity of primary waters. Furthermore, many of the definitions and terms in the proposed Rule lack clarity and/or are not based in science. Likewise, many of the criteria for jurisdiction are not based in science and fail to meet the stated goal of clarity, predictability and consistency. Under this proposed Rule, the CWA's primary goal of maintaining and restoring the chemical, physical, and biological integrity of downstream traditional navigable waters would not be possible. In conclusion, we wish to state in the strongest possible terms that the proposed Rule should be rejected.”
(AIBS)
The comments, including a list of signatories, can be found here: https://www.aibs.org/position-statements/20190410_joint_society_l_1.html
