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On April 5, 2019 CoNPS wrote a letter to the Environmental Protection Agency strongly opposing the removal of wetlands, fens, small headwater streams, and ephemeral/intermittent drainage waters from EPA regulation through the clean water act.  The letter follows below:

I am writing this comment as the Chairman of the Conservation Committee of the Colorado Native Plant Society (CoNPS). CoNPS is a non-profit organization with over 1,000 professional and non-professional members dedicated to furthering the knowledge, appreciation and conservation of native plants and habitats of Colorado through education, stewardship and advocacy

We believe that this new proposal will negatively affect wetlands, fens, small headwater streams, and ephemeral/intermittent drainages in Colorado. This proposal does not support the Best Available Science. In the past prior to the Clean Water Act and “No Net Loss of Wetlands”, 50% of Colorado wetlands were lost to drainage, agricultural conversion, road construction, and reservoir development. If additional wetlands, fens, and small headwater streams are lost in Colorado, this proposes losses of rare plants and plant communities that thrive in these systems.

Wetlands and fens have a disproportionately high amount of biodiversity compared to other types of ecosystems. Wetlands and fens are also critical to wildlife, livestock, fish, nutrient cycling, and downstream water quality and quantity. Some isolated headwater wetlands and fens hold onto pollutants and protect downstream drinking water. Wetlands, fens, and small headwater streams have habitat for many rare plants in Colorado and are of high value to CoNPS. For instance, fens in Colorado support the following Forest Service Sensitive plants: Eriophorum chamissonis (G5 S1), Eriophorum gracile (G5 S1S2), Carex diandra (G5 S1), Carex livida (G5 S1), Sphagnum balticum (G5 S1), Drosera anglica (G5 S1), and Drosera rotundifolia (G5 S1). In the new proposal, in Colorado isolated ancient fen peatlands (over 9,000′ in elevation) that maintain rare plants and plant/wildlife fossils will have no protections. Perennial streams that become ephemeral or intermittent due to climate change will not have protection.

Please include this comment in the record. The Colorado Native Plant Society opposes any changes to the Clean Water Act, including its definitions.


Bayard C. Ewing
Chairman, CoNPS Conservation Committee

Many thanks to Gay Austin for authoring our comments.