February 7, 2019

Andrew Wheeler Acting Administrator U.S. Agency William Jefferson Clinton Building (Mail Code: 1101A) 1200 Pennsylvania Avenue, N. W. Washington, DC 20460

Re: Retain the Existing Clean Water Act Section 404(c) Implementing Regulations

Dear Acting Administrator Wheeler:

On behalf of our millions of members and supporters across the country, the undersigned 310 conservation and social justice organizations and businesses call on you to retain the existing Clean Water Act Section 404(c) implementing regulations, and to rescind the June 26, 2018 Memorandum issued by your predecessor that directs the revision of those regulations. The revisions required by the June Memorandum are unlawful and unwarranted, and threaten the health of the nation’s waters and the vital benefits they provide to people and wildlife.

Poll after poll shows that the public overwhelmingly wants the clean, fishable, and swimmable waters promised by the Clean Water Act. Section 404(c) is a vital tool for fulfilling this promise for all communities by reinforcing the importance of avoiding adverse impacts to the nation’s waters and serving as an action of last resort to stop the most unacceptably damaging harm to the nation’s rivers, streams, and wetlands.

The Environmental Protection Agency has used its 404(c) authority to protect an extensive array of nationally significant resources, while stopping just 13 out of more than two million Section 404 activities in the 46-year history of the Clean Water Act. These 404(c) actions have protected more than 200,000 acres of wetlands and 36 miles of rivers and streams in 11 states, including: red maple forested swamps in New England; vital bottomland hardwood wetlands in Mississippi and Georgia; blue crab and shrimp spawning grounds in South Carolina; fish nurseries and black duck habitat in the Chesapeake Bay; habitat for endangered and in and New Jersey; a gold medal trout stream in Virginia; and some of the last remaining high quality headwater streams in West Virginia.

If finalized, the proposed 404(c) determination for the Pebble Deposit Area in Bristol Bay Alaska would protect the habitat that supports the largest salmon fishery on earth, the source of over half of the world’s supply of sockeye salmon, and the largest source of economic activity for the region.1 More than sixty two million adult salmon returned to the rivers of Bristol Bay in 2018.

1 U.S. Environmental Protection Agency, Proposed Determination of the U.S. Environmental Protection Agency Region 10 Pursuant to Section 404(c) of the Clean Water Act Pebble Deposit Area, Southwest Alaska, July 2014. Notably, this pre-permit proposed determination was upheld by former Administrator Pruitt just months before he issued the June Memorandum that seeks to eliminate the authority to issue pre-permit determinations. 83 Fed. Reg. 8,668 (Feb. 29, 2018). February 7, 2019 Page 2 of 15

Each of these Section 404(c) actions was carried out under the existing 404(c) regulations, which have been in place since 1979. In a testament to the quality of the existing regulations, EPA’s use of its 404(c) authority has been upheld by Federal courts each time it has been challenged. The existing regulations should be retained intact due to their clear track record of ensuring careful and prudent use of the 404(c) authority.

The June Memorandum directs EPA to develop and propose new regulations that would eliminate the authority to initiate the Section 404(c) process before a permit application is filed or after a permit has been issued. However, any such regulations must be rejected because they cannot be reconciled with the plain language of the Clean Water Act. The Clean Water Act explicitly states that Section 404(c) can be used “whenever” the Administrator determines that the discharge of dredged material would cause an unacceptable adverse impact on “municipal water supplies, shellfish beds and fishery areas (including spawning and breeding areas), wildlife, or recreational areas.” Federal Courts have confirmed that this language means just what it says: the Section 404(c) authority may be used at any time.2

Any revisions to the existing regulations based on the June Memorandum must also be rejected because such revisions clearly are not needed. To the contrary, the record demonstrates that the existing 404(c) regulations fully satisfy the June Memorandum’s stated purpose of ensuring the “careful, predictable, and prudent use” of the 404(c) authority. The existing regulations establish detailed procedures that EPA must follow to determine whether a veto is warranted. Among other things, EPA must conduct an extensive scientific review of the impacts of the activity in question, hold at least one public hearing, provide a formal opportunity for public comment, and give the permit applicant and the Army Corps of Engineers two formal opportunities to revise their permits or plans to prevent unacceptable harm. These procedures require a minimum of six months to complete. As discussed above, these procedures have protected an extensive array of nationally significant water resources while stopping just 13 of more than two million activities in the past 46 years.

Our organizations call on EPA to retain the existing Clean Water Act Section 404(c) implementing regulations, which have ensured careful, predicable and prudent use of the 404(c) authority since they were adopted in 1979. EPA should also rescind the June Memorandum since it requires unwarranted regulatory revisions that are contrary to the plain language of the Clean Water Act. Instead of engaging in this ill-advised and unnecessary rulemaking, EPA should focus its limited resources on achieving the Clean Water Act’s promise of clean, fishable, and swimmable waters for all Americans.

Sincerely, Molly M Flanagan Adrienne Morgado Vice President, Policy Board Member Alliance for the Great Lakes 350.org Bucks County Jen Hilburn Bo Webb Altamaha Riverkeeper Director Altamaha Riverkeeper ACHE

2 Mingo Logan Coal Co. v. U.S. Environmental Protection Agency, 829 F.3d 710, 714 (D.C. Cir. 2016); Mingo Logan Coal Co. v. U.S. Environmental Protection Agency, 714 F.3d 608, 613 (D.C. Cir. 2013), cert denied, 572 U.S. 1015 (March 14, 2014); City of Alma v United States, 744 F.Supp.1546, 1588 (S.D. Ga. 1990). February 7, 2019 Page 3 of 15

Steve Holmer Michael A. Eggleton Vice President of Policy President American Bird Conservancy Arkansas Chapter of the American Fisheries Society Don Riepe Director, NE Chapter Charles Trey Buckner, III American Littoral Society President Arkansas Wildlife Federation Jim Bradley Vice President, Policy and Government Elinor Williams Relations President American Rivers Arthur R. Marshall Loxahatchee National Wildlife Refuge Joseph Zupan Executive Director Kathy Phillips Amigos Bravos Executive Director/Assateague COASTKEEPER Assateague Coastal Trust Charles Falzon President Tom Vanderplaat Amigos de Bolsa Chica Board President Association of Northwest Steelheaders Trey Sherard Interim Anacostia Riverkeeper Dean A. Wilson Anacostia Riverkeeper Executive Director Atchafalaya Basinkeeper Erin Garnaas-Holmes Project Director Heather Cantino Anacostia Waterfront Trust Steering Committee Chair Athens County Fracking Action Network James Foster President Jill Mastrototaro Anacostia Watershed Society Policy Director Audubon Mississippi Georgia Ackerman Riverkeeper and Executive Director Eliza Cava Apalachicola Riverkeeper Director of Conservation Audubon Naturalist Society Joe Lovett Executive Director Greg Goldman Appalachian Mountain Advocates Executive Director Audubon Pennsylvania Jim Vogt President Mark Conway Aquashicola/Pohopoco Watershed Executive Director Conservancy Baltimore Tree Trust

Brad Powell Jim Blackburn President Owner Arizona Wildlife Federation BlackburnCarter Law Firm February 7, 2019 Page 4 of 15

Louis Zeller Glenn Wahl Executive Director Co-founder Blue Ridge Environmental Defense League Cattaraugus-Chautauqua for Clean Water

Jenn Aiosa David C. Kyler Executive Director Executive Director Blue Water Baltimore Center for a Sustainable Coast

Rebecca Roter Randy Serraglio Chairperson Southwest Conservation Advocate Breathe Easy Susquehanna County Center for Biological Diversity

Eric Baird Trish Rolfe President Executive Director Brodhead Chapter Trout Unlimited Center for Environmental Law & Policy

Bob Heil Jason Ulseth Executive Director Chattahoochee Riverkeeper Brodhead Watershed Association Chattahoochee Riverkeeper

Stanley Pannaman James M. Pfiffer Conservation and Programs Chair Executive Director Broward Group of the Sierra Club Chemung River Friends

Teresa Mills Lisa Feldt Executive Director Vice President for Environmental Protection Buckeye Environmental Network and Restoration Chesapeake Bay Foundation Sharon Furlong Spokesperson Eliza Smith Steinmeier Bucks County Sierra Club Executive Director Chesapeake Legal Alliance Sharon Furlong Spokesperson Michael William Mullen Bucks Environmental Action Riverkeeper/Executive Director Choctawhatchee Riverkeeper Frank Rodgers Executive Director Aimee Erickson Cacapon Institute Executive Director Citizens Coal Council Randall C. Haddock, PhD Field Director Arthur Feinstein Cahaba River Society Board Member Citizens' Committee to Complete the Refuge Bill Jennings Executive Director Joe Levine California Sportfishing Protection Alliance Director Citizens For Water February 7, 2019 Page 5 of 15

Karen Knudsen Elaine Cimino Executive Director Director Clark Fork Coalition Common Ground Rising

Jennifer Peters John D. Elder National Water Programs Director Vice President Clean Water Action Communities for Safe and Sustainable Energy

Dean Hoegger Donald Hebbard President President / Founding Member Clean Water Action Council of NE Wisconsin Compressor Free Franklin

Vernon Haltom Suzy Winkler Executive Director Co-founder Coal River Mountain Watch Concerned Burlington Neighbors

Ken Dolsky Brigid Lawlor Organizer Provincial Advocacy Liaison Coalition Against Pilgrim Pipeline New Jersey Congregation of Our Lady of the Good Shepherd, US Provinces Emily Vuxton Policy Director Taylor Krug Coalition to Restore Coastal Louisiana Conservation Associate Conservancy of Southwest Florida Alan Levine Director, Coast Action Group Ron Suttles Coast Action Group Board Chair Conservation Coalition of Oklahoma Laura Cantral Executive Director Wayne Tanaka Coastal Conservation League Board President Conservation Council for Hawai’i Harrison Langley Waterkeepeer Brandon Butler Collier County Waterkeeper Inc Executive Director Conservation Federation of Missouri Patricia Olson President Heather A. Govern, Esq. Colorado Rising Director, Clean Water Program Conservation Law Foundation Dale Beasley President Paul Wesley Pyron Columbia River Crab Fisherman’s Association Associate Corridor Partners Clark Bullard Director Forest Jahnke Committee on the Middle Fork Vermilion River Program Coordinator Crawford Stewardship Project February 7, 2019 Page 6 of 15

Jane Morton-Galetto Tara Thornton President Program Director CU Maurice River Endangered Species Coalition

B. Arrindell Bart Johnsen-Harris Director Clean Water Advocate Damascus Citizens for Sustainability Environment America

Diane Rosencrance Doug O'Malley Executive Director Director Delaware Highlands Conservancy Environment New Jersey

Anne Harper Peter M. Iwanowicz Executive Director Executive Director Delaware Nature Society Environmental Advocates of New York

Maya van Rossum Brian Trautwein the Delaware Riverkeeper Environmental Analyst/Watershed Program Delaware Riverkeeper Network Coordinator Environmental Defense Center Tommy Lawrence Managing Director Sylvia Lam Earth Conservation Corps Attorney Environmental Integrity Project Mary Gutierrez Executive Director Joy Bergey Earth Ethics Director Environmental Justice Center at Chestnut Hill John Barnes United Church Advocacy Coordinator Earth Forum of Howard County Charley Bowman Co-Chair Jenifer Collins Environmental Justice Task Force of the WNY Legislative Representative Peace Center Earthjustice Ann Mesnikoff Aaron Mintzes Federal Legislative Director Senior Policy Counsel Environmental Law & Policy Center Earthworks Eric Wilkinson Pam Richart General Counsel Co-Director Environmental League of Massachusetts Eco-Justice Collaborative Timothy Male Dan Silver Executive Director Executive Director Environmental Policy Innovation Center Endangered Habitats League February 7, 2019 Page 7 of 15

Thomas Wheeler Glenda Booth Executive Director President Environmental Protection Information Center Friends of Dyke Marsh

Michelle Roos Jacqueline Lane Executive Director Director Environmental Protection Network Friends of Perdido Bay

John Peck Marian Dombroski Executive Director Program Manager Family Farm Defenders Friends of Quincy Run Watershed

Manley Fuller Bob Clarke President & CEO President Florida Wildlife Federation Friends of the Central Sands

Liz Kirkwood Dawn Buehler Executive Director Kansas Riverkeeper & Executive Director FLOW (For Love of Water) Friends of the Kaw

Tom H. Logan Shelly Backlar Chairman and Senior Conservation Advisor Vice President of Programs Fly Fishers International Friends of the Los Angeles River

Amanda Nelson Trevor Russell Executive Director Water Program Director Foothill Conservancy Friends of the Mississippi River

Mary Allessio Leck Jay Martin Retired Emeritus Professor of Biology/Executive President Commitee Friends of the Nanticoke River Friends for the Abbott Marshlands Ronald Stork Kris Unger Senior Policy Staff Primary Conservator Friends of the River Friends of Accotink Creek Bill Tanger Robert Eisenstadt Chair Treasurer Friends of the Rivers of Virginia (FORVA) Friends of Black Bayou Lake NWR, Inc. Marion Bottorff Judy Rodd Board Member Executive Director Friends of the Santa Clara River Friends of Blackwater Vivian Newman Carolyn Lange Friends of the Weskeag Medical Technologist

Friends of Cherry Valley February 7, 2019 Page 8 of 15

Jim Blackburn Cynthia Sarthou Chair Executive Director Galveston Bay Conservation and Preservation Gulf Restoration Network Association Donna Cooper Bob Stokes Billing Manager President Harry Enstrom Chapter of the Izaak Walton Galveston Bay Foundation League of America

Yvonne Taylor Richard L. Hines Vice President President Gas Free Seneca Hines & Jones, P.A.

Mike Worley Adrienne L. Hollis President & CEO President Georgia Wildlife Federation Hollis Environmental Consulting & Community Resource Center, Inc. (ECCRC) Patti Wood Executive Director Indra Frank Grassroots Environmental Education Director of Environmental Health and Water Policy Fred Akers Hoosier Environmental Council Administrator Great Egg Harbor Watershed Association Danielle Diamond Attorney and Co-founder Kathleen Henry Illinois Citizens for Clean Air & Water President Great Rivers Environmental Law Center Edward L Michael Government Affairs Chair David Stokes Illinois Council of Trout Unlimited Executive Director Great Rivers Habitat Alliance Liz Rupel Policy Organizer Fran Teplitz Illinois Stewardship Alliance Executive Co-director Green America Howdy Henritz President Victoria Laubach Indian Creek Watershed Association Executive Director Green Valleys Watershed Association Elizabeth Peer Environment Team Lead Tish Molloy Indivisible Lambertville NJ/New Hope PA President Guardians of The Brandywine Jennifer Thurston Executive Director Greg Pace Information Network for Responsible Mining Organizer Guernsey County Citizens Support on Drilling Issues February 7, 2019 Page 9 of 15

Shiney Varghese Sandy Bihn Senior Policy Analyst Lake Erie Waterkeeper Institute for Agriculture and Trade Policy Lake Erie Waterkeeper

Jodi Rose Philip Wenger Executive Director President and CEO Interfaith Partners for the Chesapeake Lancaster County Conservancy

Cindy Lane Madeleine Foote Water Program Director Legislative Representative Iowa Environmental Council League of Conservation Voters

Anna L. Gray Susan Calkins Public Policy Director Everglades Coalition Representative Iowa Natural Heritage Foundation League of Women Voters Florida

Joe Wilkinson Mary Mathews President Treasurer Iowa Wildlife Federation League of Women Voters of Lake County, IL

Jared Mott Diana Hoke Conservation Director President Izaak Walton League of America League of Women Voters Roselle- Bloomingdale Laura Mendenhall Board President Gretchen Sabel Kansas Wildlife Federation Chair League of Women Voters Upper Mississippi Tom FitzGerald River Region Director Kentucky Resources Council Jessica Jones-Capparrel Policy & Legislative Affairs Senior Manager Ward G Wilson League of Women Voters US Executive Director Kentucky Waterways Alliance Nancy Tate Coordinator Deborah Kratzer LEPOCO Peace Center (Lehigh-Pocono Steering Committee Member Committee of Concern) Kingwood Citizens Against the Pipeline Barry Kohl Kimberly Baker President Executive Director Louisiana Audubon Council Klamath Forest Alliance Shannon McMulkin Lori Fisher Director Executive Director Lower Mississippi River Foundation Lake Champlain Committee February 7, 2019 Page 10 of 15

Drew Martin Noreen Tyler Conservation Chair Office Administrator Loxahatchee Group, Sierra Club Minnesota Division Izaak Walton League of America John R Lyons Owner/Operator James L. Cummins Lyons Farm President Mississippi River Trust William C. Long Community Director Maisah Khan March of Dimes Water Policy Coordinator Missouri Coalition for the Environment Barry Marshall Owner Kendra Varns Wallis Marshalls Automotive Executive Director Missouri Parks Association Kirsten Johnson President Nimrod Chapel, Jr. Maryland Native Plant Society President The Missouri State Conference of the NAACP Jen Lomberk Matanzas Riverkeeper Trana Rogne Matanzas Riverkeeper Steering Committee Chair MnDak Upstream Coalition Bonnie Bick

Vice President David Brooks Mattawoman Watershed Society Executive Director Deborah Lynch Montana Trout Unlimited Property & Casualty Specialist David Chadwick MetLife Executive Director Todd Pride Montana Wildlife Federation Managing Partner & Lead Coach Dr. Alan Hunt Mid-Atlantic Youth Anglers & Outdoors Executive Director Partners Musconetcong Watershed Association

Kimberlee Wright Lawrence E. Couch Executive Director Director Midwest Environmental Advocates National Advocacy Center of the Sisters of the Cheryl Nenn Good Shepherd Riverkeeper Julie Hill-Gabriel Milwaukee Riverkeeper Vice President, Water Conservation Betsy Lawton National Audubon Society Program Director and Attorney Minnesota Center for Environmental Advocates February 7, 2019 Page 11 of 15

Rudy Arredondo Beverly Edwards President/CEO/Founder Chair National Latino Farmers & Ranchers Trade NH Pipeline Health Study Group Association Tim Gestwicki Chad Lord CEO Senior Director, Water Policy North Carolina Wildlife Federation National Parks Conservation Association Wayne Beyer Melissa Samet Board President Senior Water Resources Counsel North Dakota Wildlife Federation National Wildlife Federation Matt Norton Emmie Theberge Policy Director Federal Project Director Northeastern Minnesotans for Wilderness Natural Resources Council of Maine Sridhar Vedachalam Jon Devine Director, Safe Drinking Water Program Director of Federal Water Policy Northeast-Midwest Institute Natural Resources Defense Council Matt Malina Melinda Hughes Director & Founder President NYC H2O Nature Abounds Buck Moorhead Douglas Bechtel Chair President NYH2O New Hampshire Audubon Michael Stocker Kelly Mooij Director Vice President of Government Relations Ocean Conservation Research New Jersey Audubon Kristy Meyer Peter Kasabach Vice President of Policy, Natural Resources Executive Director Ohio Environmental Council New Jersey Conservation Foundation Rich Cogen Julia Somers Executive Director Executive Director Ohio River Foundation New Jersey Highlands Coalition Alexis Baden-Mayer Ed Potosnak Political Director Executive Director Organic Consumers Association New Jersey League of Conservation Voters Vivian Stockman Julia Woldorf Vice Director President of Board of Directors OVEC-Ohio Valley Environmental Coalition Newtown Creek Coalition February 7, 2019 Page 12 of 15

Dr. James S. Cleghorn Jeff Ruch Owner Executive Director Paradise Gardens and Farm Public Employees for Environmental Responsibility (PEER) Laurie Howard Executive Director Alyssa Barton Passaic River Coalition Policy Analyst Puget Soundkeeper Alliance Stephanie Wein Clean Water and Conservation Advocate Arthur William Norris PennEnvironment Quad Cities Waterkeeper Quad Cities Waterkeeper Inc. Jacquelyn Bonomo President and CEO John Ruskey PennFuture Owner Quapaw Canoe Company Rev. Sandra L. Strauss Director of Advocacy & Ecumenical Outreach Bob Musil Pennsylvania Council of Churches President & CEO Rachel Carson Council Jonas Minton Senior Water Policy Advisor Bill Schultz Planning and Conservation League Riverkeeper Raritan Riverkeeper Peter Hudiburg Founder Eleanor Hines Plymouth Friends for Clean Water North Sound Baykeeper RE Sources for Sustainable Communities Louise Troutman Executive Director Gayle Killam Pocono Heritage Land Trust Science and Policy Deputy Director River Network Caitlin Wall Senior Director of Policy Renee Fortner Potomac Conservancy Watershed Resources Manager RiverLink Phillip Musegaas Vice President of Programs and Litigation Margaret Miner Potomac Riverkeeper Network Executive Director Rivers Alliance of Connecticut Kim Knowles Staff Attorney & Policy Specialist Jeanne Braha Prairie Rivers Network Executive Director Rock Creek Conservancy Roseanna Sacco President Richard Averitt Preserve Monroe, Monroe County, WV Partner Rockfish Valley Investments, LLC

February 7, 2019 Page 13 of 15

Mary Kushner David Godfrey Founding Member Executive Director Roseland Against Compressor Station (RACS) Conservancy

Trygve B Sletteland Joseph Campbell Founding Executive Director President Sacramento River Council Seneca Lake Guardian

Nancy S Vann Lynne Rockenbauch President President Safe Energy Rights Group, Inc. Severn River Association

Jimbo Buickerood Suzanne Sullivan Lands and Forest Protection Program Manager Education & Restoration Manager San Juan Citizens Alliance ShoreRivers

Daniel McCarter Dalal Aboulhosn President Deputy Legislative Director Santa Barbara Urban Creeks Council Sierra Club

Laura Early Dave Stets Executive Director and Riverkeeper Chapter Chair Satilla Riverkeeper Sierra Club Delta Chapter

Tom Wolfe Robert Mahoney Vice President Conservation Chair Savage River Watershed Association Sierra Club Miami Group

Joseph Bogaard Louie Miller Executive Director State Director Save Our Wild Salmon Coalition Sierra Club Mississippi

Stephen Green Charles W. Marsh President President Save the American River Association Sleepy Creek Watershed Association

Michael Rice Gail Musante Director Official Signer Save the Cape, Inc. S-OACC (Sanford-Oquaga Area Concerned Citizens) Stephen Kunz Senior Ecologist Nathaniel González Santiago Schmid & Company, Inc., Consulting Ecologists President Sociedad Ornitológica Puertorriqueña, Inc. William Reichert President Chris Hesla Schuylkill Headwaters Association, Inc Executive Director South Dakota Wildlife Federation February 7, 2019 Page 14 of 15

Melinda Booth Mara Dias Executive Director & Film Festival Director Water Quality Manager South Yuba River Citizens League Surfrider Foundation

Chuck Roe Andrew Hayslip President Executive Director and Waterkeeper Southern Conservation Partners, Inc. Tampa Bay Waterkeeper

Navis A. Bermudez Kathy Hawes Federal Legislative Director Executive Director Southern Environmental Law Center Tennessee Clean Water Network

Bob Lukinic John McFadden Conservation Chair CEO Southern Maryland Audubon Society Tennessee Environmental Council

Larry Wegmann Janice Bezanson President Executive Director Southwest Missouri Fly Fishers Texas Conservation Alliance

Jerry White, Jr. Dwain Wilder Spokane Riverkeeper Editor/Publisher Spokane Riverkeeper The Banner

Lisa Rinaman Barbara Heskins Davis Riverkeeper Vice President, Programs St. Johns Riverkeeper The Land Conservancy of New Jersey

Bob Lewis Mike Petersen Executive Director Executive Director St. Mary's River Watershed Association The Lands Council

Suzannah Glidden Michael L. Pisauro, Jr., Esq. Co-founder Policy Director Stop the Algonquin Pipeline Expansion The Watershed Institute

Cathy Kristofferson Kimi Wei Organizer CEO StopNED The Wei LLC

Michael J Chojnicki Paul Botts President Executive Director and President Sullivan Alliance for Sustainable Development The Wetlands Initiative

Karen London Richard McNutt Co-Founder President Sullivan Area Citizens for Responsible Energy Tidewaters Gateway Partnership Inc. Development (SACRED) February 7, 2019 Page 15 of 15

Grenetta Thomassey Stacy Lovelace Watershed Policy Director Co-founder Tip of the Mitt Watershed Council Virginia Pipeline Resisters

Paula Guenst Larissa Liebmann Secretary Staff Attorney Tobyhanna Creek/Tunkhannock Creek Waterkeeper Alliance Watershed Association Betsy Nicholas Diane Beeny Executive Director Chair Waterkeepers Chesapeake Union County (NJ) Peace Council Paula G. Maccabee Edith Kantrowitz Advocacy Director and Counsel Board Member WaterLegacy United for Action Cynthia Rank Quanah Brightman Chair, Extractive Industries Committee Executive Director West Virginia Highlands Conservancy United Native Americans Angie Rosser James Cummings Executive Director Director of Experiential Learning/Founder West Virginia Rivers Coalition UrbanTrekkers/Urban BoatWorks Michael Gondell UrbanPromise Board Member Nick Schou Western Pocono Trout Unlimited Conservation Director Helgaleena Healingline Utah Rivers Council ArchDruid John Blair White Rabbit Grove RDNA President Valley Watch, Inc Lauren McGrath Director of Watershed Protection Program Brian Shupe Willistown Conservation Trust Executive Director Vermont Natural Resources Council Jon Anderholm Director Lindsay Newsome Xun Biosphere Project Program Director Virginia Association for Biological Farming Emma Reisinger Farmer Mary Rafferty Yellow House Farm Executive Director Virginia Conservation Network

cc: David Ross, Assistant Administrator; Dennis Lee Forsgren, Jr., Deputy Assistant Administrator Brian Frazer, Office of Water; Russell Kaiser, Office of Water