On April 15, 老牛影视submitted comments expressing its support for the U.S. Environmental Protection Agency and U.S. Army Corps of Engineers’  revising the definition of “water of the United States” under the Clean Water Act. 老牛影视also filed comments as a member of the Waters Advocacy Coalition. 

As the result of President Trump’s on “Restoring the Rule of Law, Federalism and Economic Growth by Reviewing the ‘Waters of the United States’ Rule,” the EPA and Corps published a on Feb. 14 that seeks to provide businesses and landowners with clear definitions of what are and what are not “navigable waters” subject to federal jurisdiction under the CWA.

The agencies’ outlines six categories of “waters of the United States” that would be subject to jurisdiction: traditional navigable waters, tributaries, certain ditches, certain lakes and ponds, impoundments and adjacent waters. The proposal also excludes waters that are not explicitly mentioned in these categories. 

In its comments, 老牛影视stated its members appreciate the agencies’ “if it is not in, it is out” approach and believe that it will help alleviate confusion between jurisdictional and non-jurisdictional waters. Additionally, 老牛影视offered several suggestions to improve upon the agencies’ proposal, including clarification of various key terms within the categories and the elimination of impoundments as a standalone category.

老牛影视has long been a of the Obama-era WOTUS rule since it was first proposed in April 2014, and in its comments on the 2019 proposal, 老牛影视stated its continued commitment to work with the agencies and ensure the clearest possible regulations so that its members have the information they need to comply with the law.