CRS-12 



program may be the only means of protecting the entire aquatic ecosystem, 

 including wetlands. Moreover, it may be the only means of protecting some 

 particular types of wetlands, such as the pocosins in North Carolina (sev- 

 eral hundred thousand acres of freshwater wetlands concentrated in that 

 State). At the same time, there are other wetlands, particularly bottomland 

 hardwoods of the Lower Mississippi Valley, that are not protected under any 

 program. Thus, it could be argued that the geographic scope of the Corps 

 program should be enlarged, so as to encompass resources not presently pro- 

 tected. 



Moreover, if the current program were restricted to so-called Phase I 

 waters — those considered to be navigable in the traditional sense — it is 

 likely that there would be reduced protection of water quality and of wetlands 

 in the other areas no longer included, except in those few States with strong 

 management programs. 



Furthermore, it is uncertain whether major administrative savings would 

 be achieved by narrowing the scope of the current Federal program to Phase I 

 waters. The Corps of Engineers has reported that the majority of projects 

 which actually experience lengthy permitting delays are, in fact, located in 

 Phase I waters. Thus, it is unlikely that removal of Phase II and III waters 

 from the Federal program would provide relief or time savings to large, con- 

 troversial projects. 



Issue 2 



Should some wetlands, by virtue of size, location, or other factors, be 

 excluded from a national resource management program or be managed differently? 

 Some persons argue that certain wetlands (including very small wetlands, arti- 

 ficially created wetlands, and heavily modified wetlands) should be recog- 

 nized as different from all others and should be given special treatment under 



