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Several steps could be taken to streamline section 404 permitting. These 

 efforts would be beneficial to small landowners who frequently cannot afford 

 delay, as well as to larger developers who bear large costs when regulatory 

 delays occur. The regional and national permit programs have already been 

 helpful, and other actions could be initiated (see pages 91-92 for discussion 

 of regional and national permits). 



1) Formalize interagency coordination. The Corps could be required to 

 enter into formal agreements with other Federal agencies to coordinate permit 

 review and specific activities such as site inspection. A number of Corps 

 districts have individual arrangements of this type now with some Federal agen- 

 cies and with some States, as well. If extended to all districts, it would be 

 possible to avoid duplication of efforts and achieve time savings. In specific 

 areas where States or other Federal agencies have a comprehensive program in 

 place, the Corps could delegate its authority, subject to a recapture provis- 

 ion, so that wetlands considerations are integrated into planning by the lead 

 agency in the area (see North Carolina example, page 110). 



2) Impose time limits on permit issuance. Section 404 could be amended to 

 provide that a permit would issue automatically within 90 days after a complete 

 application is filed, unless the Corps denies a permit within that time or 

 determines that the proposal's magnitude requires an environmental impact state- 

 ment. Such a time limitation would not only reduce an applicant's delay and 

 uncertainty, but would also provide incentive to other Federal agencies to ex- 

 amine a permit request promptly. Ninety days is an appropriate limit for two 

 reasons: first, section 404 now provides that Federal agencies should attempt 

 to make permit decisions within 90 days, to the maximum extent practicable; 



and second, the Corps reports that 70 percent of all applications are, in fact, 



