• Mark Ryan

Comments on the Proposed NWP Changes

The Association of State Wetlands Managers and the Center for Biological Diversity have commented on the proposed changes to the Corps NWPs. See my August 4, 6 and Sept. 14 blogposts for more on the proposed NWP changes. As I've said before, these are very significant changes to the 404 permitting scheme, yet they're not garnering that much attention.

The two above-mentioned comment letters, which were sent to me, and which I have attached below, are serious dives into the details of the proposed changes, and are worth reading. Public comments were due by November 16. The website shows 954 comments submitted, and they can all be accessed at this link. See

The Corps will now be required to write response to comments before finalizing. I'm sure the Trump administration will work hard to finalize these changes before the end of the administration. As with many of the Trump administration regulatory changes, expect litigation.

ASWM Comments on Proposal to Reissue and
Download • 326KB
2020-11-16 Master NWP Comments (final)
Download P • 706KB

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