Washington D.C. – December 28 – The SmarterSafer Coalition submitted the following comment letter to the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers on the 2025 Proposed “Waters of the United States” (WOTUS) Rule.
Dear Ms. Jensen and Mr. Boyd,
On behalf of the SmarterSafer Coalition, thank you for the opportunity to comment on the proposed revisions to the definition of “Waters of the United States” (WOTUS). We appreciate the opportunity provided by the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (Corps) to offer these comments.
We would like to highlight the essential role that connected waters, wetlands, and other nature-based systems play in reducing flood risk, protecting communities, supporting agriculture, and strengthening local and regional economies. Natural systems function as critical buffers that absorb floodwaters, reduce wave energy, and improve water quality. They are also cost-effective and fiscally responsible tools that help safeguard taxpayers. As such, we urge EPA and the Corps to be as protective as possible of wetlands and streams to the fullest extent allowed by law.
Nature-Based Systems Provide Strong Flood Protection
Scientific research continues to demonstrate the significant protective value of natural features.
- U.S. coastal wetlands provide an estimated 23.2 billion dollars in storm protection services each year.
- Wetland and reef restoration in the Gulf of America region can yield benefit-to-cost ratios greater than seven to one, providing seven dollars in flood reduction benefits for every dollar invested in restoration.
- Wetlands reduced damages during Hurricane Sandy by more than 22 percent in many affected areas and by as much as 30 percent in some states, saving hundreds of millions of dollars in avoided flood losses.
- These investments can also help avert more than 45 percent of climate-related flood risk over two decades, potentially saving the region more than 50 billion dollars in damages.
These findings reinforce what communities across the country experience each year. Restored and protected wetlands, oyster reefs, mangroves, and floodplains significantly reduce storm impacts while also providing long-term environmental and economic value.
Support for Agriculture and Rural Landowners
Clear and strong protection for waters is especially important for farmers, ranchers, and rural landowners who rely on predictable rules for managing their land and water resources. Many nature-based features on working lands, such as restored wetlands and riparian buffers, not only reduce flooding but also improve soil health, support pollinators, and enhance water quality. SmarterSafer believes it is important to recognize the fact that these systems contribute to both environmental stewardship and agricultural productivity.
Taxpayer Savings and Efficient Use of Federal Resources
Nature-based mitigation is one of the most effective strategies for reducing disaster costs. Research shows that every dollar invested in pre-disaster mitigation can save up to thirteen dollars in federal spending. Local examples across the country, including the Bee Branch Watershed Flood Mitigation Project in Iowa and rain garden installations in Illinois,⁹ show how proactive planning and natural infrastructure can reduce future damages while lowering long-term public expenditures.
Conservation, Recreation, and Economic Benefits
Healthy wetlands and connected water systems also support wildlife habitat, outdoor recreation, and tourism. Organizations such as Ducks Unlimited and the Congressional Sportsmen’s Foundation have highlighted the importance of resilient landscapes for hunting, fishing, and broader conservation goals. Protecting and restoring these systems strengthens ecological health and contributes to local economies tied to outdoor activities.
The SmarterSafer Coalition appreciates the agencies’ commitment to public input and thanks you for the opportunity to share our perspective.
Sincerely,
The SmarterSafer Coalition
SmarterSafer WOTUS Comment Letter 12.19.25