Dear Ms. Colosimo and Ms. Brown:

Protecting the Nation’s surface water and groundwater is essential to public health and the quality of life our citizens enjoy. The American Public Works Association (APWA) represents 32,000 public works professionals across North America who serve in both the public and private sectors providing expertise at the local, state and federal government levels. Working in the public interest, our members plan, design, build, operate, and maintain, America’s vast infrastructure network that is so fundamental to our economy, environment, public health, and safety. This includes large and small, urban and rural, water supply, wastewater treatment, stormwater management, drainage and flood control systems. We appreciate the opportunity to participate in the federalism consultation to revise the definition of Waters of the United States (WOTUS).

APWA members take their responsibilities under the Clean Water Act (CWA) seriously and strongly support the U.S. Environmental Protection Agency’s (EPA) desire to provide greater clarity and predictability for WOTUS jurisdictional determination. Public works departments need clear implementation processes to ensure their activities consistently meet both government standards and community needs.

With this in mind, we offer the below comments.

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