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2) Vast acreages of freshwater wetlands, particularly bottomland hard- 

 woods and prairie potholes, are excluded from effective regulatory protection 

 under the current program (see page 39). These wetlands represent a signif- 

 icant nonrenewable resource which should be protected by a national program, 

 as should all wetland areas identified in the national wetlands inventory. 



3) Current debate — particularly about the section 404 program — tends to 

 concentrate on the question of which of the Nation's waterways are navigable 

 and which waterways, therefore, should be subject to some Federal regulatory 

 jurisdiction. Unfortunately, this focus does not set clear policy for wetland 

 areas of the United States because navigable streams and wetlands are not al- 

 ways associated with one another. Consequently, the current approach fails 



to present national goals for a wetland management program. While wetland 

 protection may be an indirect beneficiary of this approach, a more direct 

 focus could involve some newer management tools including the critical area 

 concept and special area management planning. 



4) The water quality functions performed by wetlands are among the high- 

 est values of such areas. However, the section 404 regulatory program is an 

 inefficient tool for recognizing other functions and values (see pages 77, 82). 

 For example, under a pollution control program, it is difficult to consider 

 the value of wetlands for migratory and waterfowl habitat, values that have 

 been recognized in separate Federal land acquisition and conservation programs. 

 A more comprehensive approach would allow a weighing of all functional changes 

 when considering effects of proposed alterations. 



Con 



In response, other persons contend that the current water quality approach 

 provides ample protection for wetlands and need not be revised. In fact, this 

 approach ensures thorough consideration of activities most likely to alter or 



