16 • Wetlands: Their Use and Regulation 



Option 3: Increase appropriations for acquisition 

 and easement programs. 



The National Wildlife Refuge System contains 

 over 33 million wetland acres: 4 million are in the 

 lower 48 States and 29 million are in Alaska. The 

 National Park System contains untabulated but 

 substantial wetland acreage. Federal funding for 

 these programs could be increased, and greater pri- 

 ority could be given to wedands in purchasing deci- 

 sions. Federal wedand-related income, such as the 

 fee charged for duck stamps, could be increased to 

 support these programs. 



Option 4: Increase tax benefits for wetland preser- 

 vation through legislation. 



Congress could alter Federal taxation policies to 

 increase the attractiveness of donating wetlands or 

 of selling conservation easements to Government 

 agencies or to private conservation groups for the 

 purpose of preservation. While the acreage of wet- 

 lands being protected might increase, the ecologiceJ 

 value of the wedands donated would probably vary. 



Option 5: Reverse the Corps' 1982 administrative 

 changes to the 404 program. 



The Corps' recent administrative changes to the 

 404 program have been designed to streamline the 

 permit process. For example, average processing 

 time for individual permits has been reduced from 

 over 120 to about 70 days. Although the Army con- 

 tends that the level of wetlands protection actually 

 achieved has been unchanged by the administrative 

 measures, anecdotal and qualitative evidence sug- 

 gests that these changes, such as the expanded use 

 of general permits, have generally reduced the 

 amount of potential control over wetland use. 

 However, existing data do not allow quantification 

 of the effects of these administrative changes on 

 wedand trends. Reversing these changes would re- 

 establish the administrative framework for regulat- 

 ing wetland use at levels that existed before the ad- 

 ministration's 1982 regulatory reform initiatives. 



Option 6: Improve the Corps' administration of the 

 existing 404 program. 



The efficiency and effectiveness of the 404 pro- 

 gram could be improved by implementing the 

 following measures, which may require modest 

 increases in program funding and personnel. Con- 



gressional oversight may also be required to deter- 

 mine the extent to which these options are imple- 

 mented by the Corps. 



Standardize Corps' district procedures. — The 



Corps' 404 program is implemented by 38 semi- 

 autonomous district offices that often differ great- 

 ly in how they interpret and implement the 404 

 program. Some inconsistencies could be avoided 

 through continued and increased use of regulatory- 

 guidance letters on presently vague policies, such 

 as those on the mitigation of project impacts. Dis- 

 tricts also could exchange information about suc- 

 cessful solutions to common problems. 



Improve coordination among Federal agen- 

 cies and between the 404 and State regulatory 

 programs. — Improved coordination, increased use 

 of single public notices, and joint processing of per- 

 mit applications could provide "one-stop shop- 

 ping" for permit applicants and reduce procedural 

 duplication and delays. Procedures of this sort al- 

 ready have been successfully implemented in a few 

 Corps districts. 



Increase program publicity. — Many people 

 planning development activities on wetlands are 

 unaware of the 404 progrcim and its permit require- 

 ments. Greater public understanding could lead to 

 better planning and result in fewer violations, less 

 damage to wetlands, and reduced costs to devel- 

 opers stemming from delays and fines. 



Improve monitoring and enforcement. — 



Many districts make inadequate efforts to monitor 

 for permit violations, particularly in inland wedand 

 areas. Action is often taken only in response to 

 reported violations. This situation could be im- 

 proved by increasing district funding, using per- 

 sonnel specifically for this purpose, and by provid- 

 ing equipment (e.g., observation planes) as needed. 

 A congressional mandate may also be required. 



Establish reporting requirements for general 

 permits. — The Corps does not monitor activities 

 covered by general permits or the impacts of such 

 activities on wetlands. More complete reporting 

 could be required so that individual and cumula- 

 tive impacts associated with individual projects 

 could be assessed. If reports indicated unaccept- 

 able impacts, permit requirements could be 

 strengthened. 



