CRS-17 



Harbors Act, a related statute and program concerned with activity occurring 

 in waters that are navigable under the traditional definition. However, if 

 certain administrative confusion does exist between EPA and the Corps of Engi- 

 neers, it could be handled without legislative change. 



Issue 4 



Should Congress clarify national goals for a wetland management program 

 through some other legislative vehicle than a water pollution control law? 

 Some persons contend that, if a comprehensive wetland management program is 

 desired, Congress should enact such a program directly, rather than continuing 

 to take an indirect approach principally through section 404 of the Clean Water 

 Act. Others respond that the current water quality approach is, in fact, com- 

 prehensive enough as a national approach to managing wetlands. 



Pro 



Many persons believe that the established water quality approach to wet- 

 land management has a number of disadvantages, including the following, which 

 could be remedied by explicit wetland legislation. 



1) Responsibility for wetland protection has been placed with an agency 

 (the Corps) that has not traditionally been concerned with environmental pro- 

 tection and has only slowly developed the expertise to deal with complex issues 

 of wetland science. In fact, the primary responsibilities of the Corps are 

 water resource development and navigation (see page 77-79). The Corps has be- 

 come overly-burdened by being made responsible for the additional water qual- 

 ity considerations inherent in section 404. It would be more sensible to locate 

 all wetland management responsibilities in a single agency that has environmen- 

 tal protection activities as one of its major missions, and that can Interre- 

 late water quality enhancement with other environmental goals. 



