EPA shrinks workforce and wetlands definition – The Wildlife Society

Report on Proposed U.S. Environmental Policy Changes and Their Implications for Sustainable Development Goals

Executive Summary

A recent proposal by the U.S. Environmental Protection Agency (EPA) to redefine “Waters of the United States” (WOTUS) under the Clean Water Act, coupled with a significant reduction in the agency’s workforce, poses substantial challenges to the achievement of several United Nations Sustainable Development Goals (SDGs). These actions risk undermining progress on SDG 6 (Clean Water and Sanitation), SDG 14 (Life Below Water), SDG 15 (Life on Land), and SDG 16 (Peace, Justice, and Strong Institutions) by narrowing the scope of environmental protection and reducing institutional capacity for enforcement.

Proposed Regulatory Changes: A Challenge to SDG 6 and SDG 14

The proposed redefinition of WOTUS significantly curtails federal oversight of wetlands and waterways, directly impacting the goals of ensuring clean water and protecting aquatic life. This policy shift presents a direct conflict with the objectives of SDG 6, particularly Target 6.6 to protect and restore water-related ecosystems, and SDG 14, which calls for the conservation of marine and freshwater resources.

• The new definition, influenced by the 2023 Sackett v. EPA Supreme Court decision, limits federal jurisdiction to relatively permanent, standing, or continuously flowing bodies of water.
• It requires that a wetland be an “indistinguishably part” of a larger water body to qualify for protection.
• The proposal removes protections for waterways that do not meet a “continuous-surface-connection” test to traditional navigable waters.
• The number of permafrost wetlands eligible for federal protection is expected to be reduced.

By limiting the scope of the Clean Water Act, these changes could lead to increased pollution and degradation of water sources, jeopardizing both human access to clean water and the health of aquatic ecosystems.

Impact on Biodiversity and Ecosystems: Contradicting SDG 15

The reduction in protected wetlands and ephemeral streams has severe implications for terrestrial and freshwater biodiversity, undermining the core principles of SDG 15 (Life on Land). Wetlands are critical habitats that support a vast array of wildlife and provide essential ecosystem services. The proposed rule change threatens progress on key targets within this goal.

• Target 15.1: The rule directly counters the goal of ensuring the conservation and restoration of inland freshwater ecosystems.
• Target 15.5: By removing protections, the policy may accelerate the degradation of natural habitats and contribute to the loss of biodiversity, directly opposing the call to halt such losses.

Institutional Capacity and Governance: A Setback for SDG 16

Concurrent with these regulatory changes, the EPA is undergoing a major workforce reduction, raising concerns about the agency’s capacity to implement and enforce environmental law. This institutional weakening is at odds with SDG 16 (Peace, Justice, and Strong Institutions), which emphasizes the need for effective, accountable, and transparent institutions.

• Over 2,600 employees, representing more than 17% of the agency’s staff, have accepted a deferred resignation offer.
• The EPA’s Office of Research and Development was closed and replaced by a smaller Office of Applied Science and Environmental Solutions.

These developments question the ability of a leaner EPA to uphold its mandate under the Clean Water Act, even within its newly narrowed jurisdiction, thereby challenging the effectiveness of the governing institution as outlined in Target 16.6.

Public Consultation Process

A public comment period has been established to allow for stakeholder engagement, a principle aligned with SDG 17 (Partnerships for the Goals). The key dates and opportunities for public input are as follows:

1. Rule Publication: The proposed rule was published on November 20, 2025.
2. Public Comment Deadline: Public comments will be accepted until January 4, 2026.
3. Public Meetings: Two public meetings will be held, offering both in-person and virtual participation options, with details to be posted on the EPA website.

Analysis of SDGs, Targets, and Indicators

1. Which SDGs are addressed or connected to the issues highlighted in the article?

1. SDG 6: Clean Water and Sanitation

   • The article’s central theme is the proposed change to the “Waters of the United States” (WOTUS) definition, which directly impacts the protection of wetlands and waterways under the Clean Water Act. This connects to SDG 6, which aims to ensure the availability and sustainable management of water and sanitation, including the protection of water-related ecosystems.

2. SDG 15: Life on Land

   • The article explicitly states that the proposed actions “will likely affect wildlife and wetland habitats.” Wetlands are critical inland freshwater ecosystems. The reduction in their protection directly relates to SDG 15, which focuses on protecting, restoring, and promoting the sustainable use of terrestrial ecosystems, including halting biodiversity loss.

3. SDG 14: Life Below Water

   • The redefinition of WOTUS affects streams and wetlands that are part of larger water systems. The article mentions that the new definition focuses on “streams, oceans, rivers, and lakes.” The degradation of these inland and freshwater sources can lead to pollution and negative impacts on downstream marine ecosystems, connecting the issue to SDG 14’s goal of conserving and sustainably using the oceans and marine resources.

4. SDG 16: Peace, Justice, and Strong Institutions

   • The article highlights a significant reduction in the workforce of the U.S. Environmental Protection Agency (EPA), with “more than 17% of the agency’s staff” leaving. This raises questions about the institution’s capacity to enforce environmental laws like the Clean Water Act. This issue is directly linked to SDG 16, which calls for building effective, accountable, and inclusive institutions at all levels.

2. What specific targets under those SDGs can be identified based on the article’s content?

1. Target 6.6: Protect and restore water-related ecosystems

   • The article discusses a proposal to “remove federal wetlands protections” and “limit the scope of federal waterway protections.” This action is in direct opposition to Target 6.6, which aims to protect and restore water-related ecosystems, including wetlands and rivers, by 2020. The proposed rule changes would reduce, not enhance, the protection of these ecosystems.

2. Target 15.1: Conserve and restore terrestrial and freshwater ecosystems

   • The article’s focus on limiting protections for “wetlands and temporarily flowing waters” directly relates to Target 15.1, which calls for the conservation and sustainable use of inland freshwater ecosystems. The proposed changes threaten the conservation status of these habitats.

3. Target 15.5: Protect biodiversity and natural habitats

   • The article notes the “potential implications for wildlife dependent on these sources of water.” By reducing protection for wetland habitats, the proposed rule could lead to their degradation, which aligns with the concerns of Target 15.5 to reduce the degradation of natural habitats and halt the loss of biodiversity.

4. Target 16.6: Develop effective, accountable and transparent institutions

   • The article questions whether “a leaner EPA can uphold the Clean Water Act as its jurisdiction narrows” following a 17% staff reduction. This directly addresses the effectiveness of a key environmental institution, which is the focus of Target 16.6. The workforce reduction challenges the EPA’s capacity to effectively implement its mandate.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

1. Indicator for Targets 6.6 and 15.1 (Implied): Change in the extent of protected water-related ecosystems

   • The article implies this indicator by discussing the narrowing scope of the WOTUS definition. Progress (or regression) could be measured by tracking the total area (e.g., in acres or square kilometers) of wetlands and streams that qualify for federal protection under the Clean Water Act before and after the proposed rule change. The article specifically mentions “reductions in the number of permafrost wetlands eligible for federal protection” as a measurable outcome.

2. Indicator for Target 16.6 (Explicit): Proportion of staff in a key government institution

   • The article provides explicit data that can serve as an indicator for institutional capacity. It states that “More than 2,600 agency employees have accepted the Administration’s ‘Fork in the Road program'” and that “More than 17% of the agency’s staff has left or will leave.” This percentage change in the workforce of the EPA is a direct measure of the institution’s human resource capacity to perform its functions.

4. Summary Table of SDGs, Targets, and Indicators

Source: wildlife.org