EPA “Waters of the United States” Proposal

Prime Mover appreciates the Agencies’ efforts to update and narrow the definition of “waters of the United States” (WOTUS) following Sackett v. See Updated Definition of “Waters of the United States,” 90 Fed. We write in support of the Proposed Rule’s steps toward clarity and restraint, while urging further, targeted revisions to ensure the final rule adheres to the Clean Water Act’s text, respects constitutional boundaries, and provides fair notice through bright-line, field-verifiable criteria.