Cayuga Lake Watershed Network

170 Main Street POB 348

Aurora NY 13026

It takes a Network to protect a watershed!


September 27, 2017

IE: Docket ID No. EPA-HQ-OW-2017-0203

Dear US Environmental Protection Agency and US Department of the Army:

I am writing on behalf of the Cayuga Lake Watershed Network (‘Network’) and our members and supporters, and on behalf of Cayuga Lake and its contributing lands and waterways, which include thousands of acres of wetlands, headwaters streams, and seasonal streams.

We ask that US EPA and the US Department of the Army not rescind the Clean Water Rule and not take any steps to limit the water quality protections provided by the Clean Water Act. Clean water is our country’s most valuable resource, as we enter an era of extreme weather events and climate change. Wetlands, headwaters streams and seasonal streams are major sources for the waters of the US and need full protection.

Lacking wetlands, headwaters, and seasonal streams, the waters of the United States would be cut off from their sources. If wetlands, headwaters, and seasonal streams are truncated, filled in, paved over, developed, and turned into waste dumping grounds, the waters of the United States would be negatively impacted by a rise in stormwater runoff, steeply decreased amounts of high quality water, and rapid water quality degradation. Removing legal protection for the sources of waters of the United States is the same as cutting off a person’s head and expecting their body to continue to live without it.

Cayuga Lake is one of eleven Finger Lakes stretched across central New York State. Our region celebrates clean water and beautiful waterways for recreation, residents, visitors, municipalities, farming, and other businesses. Cayuga Lake and its burly neighbor to the west, Seneca Lake, contain 60% of the Finger Lakes’ water. Our lakes drain to Lake Ontario, a magnificent and globally essential waterway for drinking, recreation, transport, and business.

Without continued full protection of these essential clean water resources, our creeks and lake water quality would become degraded, and many essential and beneficial uses – including drinking water for thousands of people, farming, and clean water for green, sustainable industries – would be impaired. We know that it costs a lot less to protect our waterways and clean water up front, than to try to restore them after damage has been done.

To better protect our lake and its watershed’s clean water resources, in 2014-6 the Network sponsored a locally-funded research project to update the 1980s era wetlands maps (state and federal) available for Tompkins County. Tompkins County surrounds the southern end of Cayuga Lake; its wetlands, streams, and big creeks supply over 60% of Cayuga Lake’s waters. The two-year study, Wetlands Mapping and Protection for Tompkins County, authored by Nicholas Hollingshead, may be viewed at our website here:

These new wetlands maps document that 5% of Tompkins County’s land area is made up of wetlands. The Network and our agency partners are committed to their preservation and protection, as key to stewarding our water resources.

This focus on wetlands mapping and protection is the result of a 2008 study carried out by the Water Resources Council of Tompkins County, Wetland Protections in Tompkins County: Existing Status, Gaps, and Future Needs, which found that up to 19% of the wetlands in Tompkins County have no protection based on existing state and federal regulations. This study was funded by a Wetland Program Development Grant from the EPA, administered by the Tompkins County Soil and Water Conservation District, and overseen by the Tompkins County Water Resources Council (WRC) Wetlands Committee. In response to the findings of this study, the WRC Wetlands Committee developed a sample wetlands protection local law, approved by the WRC in 2012 and presented to municipalities for adoption.

In April of 2017, the Network submitted the updated Cayuga Lake Watershed Restoration and Protection Plan to the NYS Department of State, the culmination of a two-year project carried out by the Network under the guidance of the Intermunicipal Organization of the Cayuga Lake Watershed. The 2017 Plan may be viewed at our website here: Please note the chapter on Wetlands and Riparian Corridors Management, pp. 112-122.

The message of this Plan chapter, of the updated Plan as a whole, and of the work that the Network does in cooperation with our agency partners and the public, is that protection, conservation, and restoration of wetlands, headwaters and seasonal streams are essential to good stewardship of our local watershed, and for the country as a whole, as we enter a turbulent era of weather and climate disruption and change.

We call on the US EPA and US Army to do nothing that weakens the legal and regulatory protections for these essential waters of the United States. Please leave the Clean Water Rule in place and fully uphold the Clean Water Act.

Sincerely yours,

Dr. Hilary Lambert

Steward and Executive Director, Cayuga Lake Watershed Network