April 15, 2003


Water Docket

Environmental Protection Agency

Mailcode 4101T

1200 Pennsylvania Avenue, NW

Washington , DC 20460

Attention Docket ID No. OW-2002-0050


To Whom It May Concern:


The Responsible Growth Management Coalition was founded in 1988 as a response to growing concerns over the impact of burgeoning growth on the environment of Southwest Florida .  The RGMC is comprised of local citizens who are interested in the overall longevity and the health of our region.  In the nearly fifteen years since its inception the RGMC has been a vocal proponent of environmental protection in Southwest Florida .


The purpose of this letter is to provide information to the Environmental Protection Agency and the Army Corps of Engineers regarding the advanced Notice of Proposed Rulemaking (ANPRM) on the Clean Water Act Regulatory Definition of the “Waters of the United States ” which was published in the Federal Register on January 15, 2003 .  The objective of the ANPRM is, “to obtain early comment on issues associated with the scope of waters that are subject to the Clean Water Act (CWA). In light of the U.S. Supreme Court decision in the Solid Waste Agency of Norther Cook County v. U.S. Army Corps of Engineers, 531 (2001) (SWANCC).” Further clarified, the Federal Government is seeking input as to what wetlands shall be considered isolated and to what extent isolated wetlands should be protected under the CWA.


The RGMC clearly recognizes the importance of isolated wetlands in the Southwest Florida landscape.  Decreased protection for these wetlands could degrade our region’s natural environment and our quality of life.  The Florida Department of Environmental Protection recently published its CWA Section 303(d) list of impaired waters in the Florida Administrative Weekly.  Included on the impaired list were all the tributaries of Estero Bay .  Efforts to reduce the scope of the CWA could significantly impact the impaired waters process thereby impacting our local efforts to improve water quality in these tributaries.


Careful reading of the SWANCC decision outlines a very narrow ruling regarding an abandoned mine pit that had not been used for nearly thirty years.  Natural wetlands are significant features that are found throughout the Southwest Florida landscape.  They provide habitat for Federally endangered species such as the wood stork, the provided recharge areas for Southwest Florida ’s Strained aquifers and they allow the uptake of pollutants from our human environment.  Due to the importance of isolated wetlands to our natural landscape we request that all natural, isolated wetlands be protected under the Clean Water Act.






Michael Andoscia M.A.

President RGMC