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EPA and Army Corps Unveil Draft WOTUS Rule With New ‘Wet Season’ Test and Hydrology Model

Courts will review the policy without Chevron deference, increasing the likelihood of multi-year challenges.

Overview

  • The proposal interprets “relatively permanent” to cover waters that flow year-round or during a wet season, but it does not define the seasonal period.
  • Regulators plan to use the University of Delaware’s WebWIMP tool to evaluate hydrology when deciding whether waters qualify for federal protection.
  • For the first time, the draft states that human-made obstructions such as tunnels, debris piles, or boulder fields can sever a surface connection and remove upstream waters from jurisdiction.
  • EPA and the Army Corps acknowledge a narrower federal reach, while scientists and advocates warn of large wetland and intermittent-stream losses in arid regions and foresee litigation.
  • Public comments run through Jan. 5, with Administrator Lee Zeldin emphasizing alignment with Sackett and inviting feedback as courts are expected to scrutinize the rule without deference.