Comment from American Rivers

American Rivers is gravely concerned that these proposed actions could impact the viability of many existing FWS easements beyond the PPR. The linked document does a great job summarizing the issues, both why it’s difficult to measure impacts and why landowners would potentially be upset about the setbacks. However, doing away with the setbacks would allow landowners to install drainage tile immediately adjacent to the easements, potentially draining existing wetlands or at least intercepting flow into the wetlands. This would negate the purpose of the easement and be a waste of the federal taxpayer funds that were spent on purchasing the easement. While we understand that the fee-title ownership of a property changes hands, and landowners who purchase properties with easements on them may not fully be aware of the restrictions, but that is their responsibility to learn the rules and not the responsibility of the FWS to change course when fee-titles transfer. The document only talks about the impacts on waterfowl habitat, and while those would be highly detrimental, the wildlife impacts go well beyond waterfowl to all species that utilize wetlands and wetland edges during their life cycles. However, the long-term negative results would be much greater in my opinion. More tile means lower groundwater levels, faster runoff, more flooding, and more sediment and nutrients in our waterways. We would lose the flood storage capacity for those wetlands. We would also lose the nitrate removal functions performed by natural wetlands, leading to increased pollution and algae levels in our lakes and rivers, and increases in the Dead Zone in the Gulf of Mexico. Considerable funding is currently being provided by numerous government agencies to combat these issues and reducing tile setback limits would challenge those efforts. American Rivers opposes the proposed rollback to these wetland protections. While the negative impacts will be "seen" in the PPR, they will be "felt" by all communities, farmers, businesses, and wildlife from North Dakota to Louisiana.