The following is the formal public comment submitted through the federal registry on behalf of the Flint, MI and Memphis, TN Youth Environmental Justice Advisory Council.

April 22, 2025

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Docket ID No. EPA-HQ-OW-2025-0093

Dear Environmental Protection Agency Officials,

We, the members of Young, Gifted & Green’s Youth Environmental Justice (EJ) Council, are a collective of high school and college-aged youth leaders from communities directly impacted by environmental Injustices In Flint, Michigan, and Memphis, Tennessee. We are writing to you today to share our concerns and strong opposition to any further weakening of the Waters of the United States (WOTUS) protections under the Clean Water Act.

The proposed rollback is not just a regulatory shift, It Is a threat to our communities, our health, our environment, and our future. As young people growing up in frontline communities, we have inherited a legacy of pollution and neglect. However, we are also the ones working to build a different future —one rooted in justice, health, and environmental stewardship.

We speak from lived experience. In Flint, the community continues to navigate the long-term health and psychological impacts of the Water Crisis, which began in 2014. Unsafe water destroyed trust in public systems, damaged children’s health, and revealed the systemic racism that underpins environmental decision-making. In Memphis, where groundwater sources like the Memphis Sand Aquifer are threatened by Industrial development and contamination, many of us have been actively advocating for the protection of our water from companies who see our neighborhoods as sacrifice zones.

Now, with up to 90 million acres of wetlands at risk due to the Supreme Court’s Sackett v. EPA ruling and the EPA’s own announced plans to align further with that decision, we are extremely concerned that even more vital protections will be stripped away. These wetlands are not abstract concepts – they are part of our ecosystems, our natural infrastructure, and our lives.

Wetlands play a crucial role in ensuring clean water, mitigating floods, supporting biodiversity, and sequestering carbon. According to the Environmental Defense Fund, they serve as natural filters that remove pollutants from our waterways, acting like the kidneys of the environment, a critical buffer as we face more frequent and intense climate-related storms.

The reality is that pollution doesn’t stay in one place. It flows downstream. We know this firsthand in Flint, where lead, bacteria, and other contaminants moved through our pipes and into our bodies. We know this in Memphis, where industrial runoff threatens to leach into the aquifer that provides drinking water to over one million people. When smaller streams and wetlands are left unprotected, the entire watershed suffers, including our lakes, rivers, and drinking water sources.

These rollbacks would disproportionately harm Black, Brown, and low-income communities, like ours, that are already overburdened by environmental hazards and under-resourced when it comes to Infrastructure and public health. If protections are further weakened, it will be our communities that bear the brunt of Increased flooding, higher water treatment costs, and the loss of natural spaces that provide joy, healing, and connection.

Moreover, these changes go against the very mission of the EPA, which is to protect human health and the environment. Instead of strengthening safeguards, these proposed changes would hand more power to polluters and developers at the expense of future generations.

We urge you to recognize that we, the youth, are watching. We are paying attention. And we are rising up to demand that our waters be protected, not polluted.

We’ve seen what happens when young people are left out of the room where decisions are made. We are here now to say: Let us in. Let us be heard. Let us protect our future.

We are not alone in our stance. According to polling, 94% of Americans support protecting the water in our lakes, rivers, and streams. Clean water is not a non-partisan Issue. It is a human right. Yet, we are witnessing a deliberate attempt to chip away at the Clean Water Act, a law that has stood for over 50 years as our nation’s most Important environmental protection.

The EPA has already issued a final rule that aligns with Sackett v. EPA. We strongly believe that this should be the endpoint, not a starting point, for further deregulation. To go even further, it is not a matter of compliance with the law; it is a political choice to prioritize polluter profits over public health. That choice would have devastating consequences for youth, families, and ecosystems across the country.

This is not just about numbers and regulations. It is about our lives. It is about the kids in Flint who still can’t drink from the tap without fear. It’s about the Black families in South Memphis whose homes flood every time there’s a heavy rain. It’s about the youth who are already facing anxiety about climate change, only to now have to fight for the very water that sustains us.

We need wetlands. We need clean water. We need the EPA to do its job and enforce the Clean Water Act to the fullest extent still possible under the law. We ask that you reject any further reinterpretation of WOTUS that would strip protections from seasonal streams, geographically isolated wetlands, or waters without surface connections, because these definitions do not reflect ecological reality. All waters are connected, and all deserve protection.

This public comment is not the end of our engagement. We will continue to mobilize our communities, submit testimony at EPA listening sessions, and demand accountability at every level of government. But we are asking you to meet us with the same level of commitment.

Do not roll back the protections we depend on. Do not erase the ecosystems that sustain us. Do not ignore the voices of youth who are calling out for justice.

We are not just future leaders. We are leaders now. And we are telling you: our wetlands, our streams, our clean water, they must be protected.

Sincerely,

The Youth Environmental Justice Council

Young, Gifted & Green