CRS-14 



activities in the past. One means of at least modifying the requirements might 

 be to adopt the Corps' abbreviated permit procedures for minor projects coming 

 only under section 10 of the Rivers and Harbors Act. Such activities can be 

 authorized through Letters of Permission, after coordination with appropriate 

 Federal and State agencies, but without a public hearing or administrative 

 referral process. Extension of that section 10 process to projects in lesser 

 wetland areas could achieve administrative and time savings but without 

 adversely affecting the wetland environment. 



Con 



Opponents of modifying the regulatory process for certain types of wet- 

 lands contend that water quality is not the only function that comes under the 

 umbrella of the Corps' public interest review. Other valued functions should 

 continue to be equally protected by the Corps' regulatory program. Many small 

 wetland areas and artif ically created wetlands are more fragile and may have 

 greater value than coastal wetlands. Such areas actually should be afforded 

 greater protection, rather than less, which would likely be the case under a 

 modified management arrangement. For example, isolated inland wetlands are 

 more easily disturbed and permanently altered by direct and indirect changes, 

 perhaps because of their small size and because of their separation from larger 

 hydrologic/hydraulic systems. But these small wetlands are highly valued for 

 waterfowl habitat. They are the principal areas of interest in the wetland 

 acquisition programs of the Interior and Agriculture Departments, evidence of 

 the high value of such areas (see pages 96-98). 



Artif ically created wetlands often have similar high value. For example, 

 dredged material has created several thousand man-made islands, many of which 

 are being managed for wildlife habitat. The Corps has reported that a large 



