Waters of the United States rule drew farm-bureau template
The Environmental Protection Agency received 408 nearly identical comments in 2022 opposing the revised definition of "waters of the United States." The campaign argued that the proposed scope would pull ephemeral streams and isolated wetlands on agricultural land back under federal Clean Water Act jurisdiction.
Campaign window
62 days · 408 comments detected
Shape of the campaign
Each red dot is one comment that matched the campaign's template text. Grey dots are unrelated submissions to the same docket. The clustering algorithm groups comments by semantic similarity, not by exact string match, so light wording changes don't hide the pattern.
Scale
The template
“As a fifth-generation farmer, I oppose the proposed revision of the Waters of the United States definition. The proposal would pull ephemeral streams and isolated ponds on my land back under federal Clean Water Act jurisdiction, requiring permits for routine farming activities like ditch maintenance and stock-pond construction. We need clear, narrow rules that focus on truly navigable waters, not every wet spot after a heavy rain.”
Attribution
Who organized this?
The American Farm Bureau Federation organized a grassroots letter campaign through its state affiliates, providing template language that farm operators could submit opposing the return to broader WOTUS definitions.
Attribution is based on publicly available evidence. It does not imply wrongdoing.
Migration analysis
Did the campaign's language make it into the final rule?
EPA adopted a broader WOTUS definition in the January 2023 rule despite the campaign's opposition. The campaign got narrower waters jurisdiction not from this rulemaking but from the Supreme Court's separate Sackett v. EPA decision, which constrained the rule's reach.
Phrase overlap is correlation, not causation. Many advocates and agency staff use the same vocabulary; matching language is not evidence the campaign drafted the rule.
Rule outcome
Did it influence the final rule?
EPA finalized the revised WOTUS rule in January 2023, but the Supreme Court's Sackett v. EPA decision in May 2023 significantly narrowed the definition of waters subject to Clean Water Act jurisdiction, effectively overriding the rulemaking.
Rule outcomes are matters of public record. Astroturf does not claim the campaign caused or prevented the outcome.
> Technical details
curated-epa-hq-ow-2021-0602-e1a8b0778e06426dDocket IDEPA-HQ-OW-2021-0602Finding slugwaters-of-the-united-states-rule-drew-farm-bureau-template-ad95baGeneratedManual (edited)