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the regulatory program. Recognition might take the form of modified review 

 procedures or complete exemption from regulatory review. Others respond that 

 the varied functions performed by wetlands, regardless of size or location, 

 require that they all should be afforded the protection of a uniform regulatory 

 process intended to determine the environmental impact of any material removal 

 or disposal project, before the project can be permitted. 



Pro 

 Some persons contend that there should be a mechanism to exempt or modify 

 permitting requirements for certain wetland areas of the United States. They 

 argue that such wetlands, including substantially-altered wetlands and those 

 created ancillary to other activities, are not critical to maintenance and 

 enchancement of water quality in navigable waters — waters which were the 

 original focus of the section 404 program. Further, the value of many of these 

 areas to perform wetland functions is minimal because they are less likely 

 to provide multiple functions such as flood control, groundwater recharge, and 

 food chain productivity. Most State wetland programs recognize some differ- 

 ences by only applying to wetlands larger than a certain size and by recog- 

 nizing that wetlands of differing characteristics require different levels of 

 protection (see pages 104-105). It is inappropriate to require the same Fed- 

 eral review and permitting procedures for wetlands adjacent to navigable water- 

 ways and for other wetlands of limited value as well. The administrative costs 

 of carrying out permit review for certain wetland areas are not commensurate 

 with benefits these areas may provide. The costs are particularly burdensome 

 to small landowners. 



These persons point out that it may be possible to eliminate the time-con- 

 suming permit review procedures of section 404 for small or artifically created 

 wetlands, as well as for others that have already been heavily modified by man's 



