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those requirements to other Federal agencies, as well? Some persons contend 

 that giving statutory basis to this policy would promote interagency consis- 

 tency and elevate the stature of the mitigation concept when agencies review 

 a dredge or fill permit application. Other persons respond that the policy 

 could be adopted administratively by other Federal agencies, without any need 

 for statutory change, and could thus be applied flexibly, depending on a spe- 

 cific situation. 



Pro 



In January 1981 the Fish and Wildlife Service adopted a mitigation pol- 

 icy for making recommendations on proposed actions that may adversely affect 

 habitat (see page 54). The policy has two principles: (1) either avoidance 

 of the activity or compensation for the impact should be recommended in the 

 case of highly valued habitat resources; and (2) the degree of mitigation 

 requested should correspond to the value and scarcity of the habitat at risk. 

 Proponents argue that giving statutory basis to the current Fish and Wildlife 

 Service policy could overcome a number of current limitations. First, the 

 policy applies only to the Service; other agencies having major wetland review 

 responsibilities, such as the Corps, EPA, and the National Marine Fisheries 

 Service, do not have similar requirements. The value of this policy in 

 enhancing the Nation's dwindling wetland resources has already been demon- 

 strated in several cases. However, this limitation of the policy to a single 

 agency tends to be uneven within the Federal community, sometimes leading to 

 interagency conflict. 



Second, giving the policy statutory basis could also succeed in broadening 

 its current focus, which Is now mitigating losses of fish and wildlife habitat. 

 Other possible impacts on proposed actions, on public health or heritage values, 



