CRS-24 



processed within 75 days. Computerizing applications and developing programs 

 to combine State and Federal applications are further reducing time require- 

 ments, and greater efficiencies are anticipated in the future. 



3) Modify the authority of other Federal agencies to refer a disputed 

 application to higher level officials. Under this authority, EPA or the Fish 

 and Wildlife Service can object to the District Engineer's decision and request 

 that the permit be elevated to higher levels in the Department of the Army (see 

 pages 90-91, 95) Some persons contend that the referral authority tends to hold 

 some applicants hostage: in order to avoid delays that would result from 

 referral, an applicant may simply alter his project plan and thus satisfy the 

 reluctant agency. Moreover, it has been argued that the referral authority 

 results in greater consideration actually being given to environmental matters, 

 thus unbalancing the Corps' consideration of issues within its public interest 

 review. Finally, it may no longer be necessay to provide explicitly for 

 referral by environmental agencies, since during the last several years, the 

 Corps staff has been augmented with personnel fully capable of representing 

 such interests. 



Con 



Opponents of streamlining say that, while it may be desirable to obtain 

 better interagency cooperation, it would not necessarily be better to artifi- 

 cially limit the time for the permit review process. The current system of 

 permit review, involving several agencies having different missions (water 

 quality, fish and wildlife, impacts on marine species), serves to insure a 

 balancing of the public interest. In many cases, the thoroughness of review 

 would be reduced if a precise time limit were imposed on permit review, and 

 it is possible that adverse effects of a project might not be fully aired. The 



