CRS-25 



same problems could result if the referral authority of other Federal environ- 

 mental agencies were eliminated or modified. Increasing State involvement in 

 the permit program, national permits and other initiatives are already reducing 

 permit processing time. If these changes provide the same levels of protection 

 while reducing permit processing time, their value will be proven in actual 

 experience, rather than rest on an arbitrary legislative mandate. 



It also is questionable how much delay actually results from interagency 

 review procedures. The Fish and Wildlife Service estimates that most permit 

 applications are processed efficiently and that the average review time for a 

 permit is brief. In addition, the Corps has reported that projects that do 

 experience lengthy delays prior to construction frequently are waiting for 

 more than just a section 404 permit. Many, in fact, are held up by various 

 State and local permit decisions rather than Federal approvals. 



FEDERAL/STATE RELATIONS 



Issue 1 



Should States be given a stonger role in managing the Nation's wetland 

 resources, for example, by encouraging transfer of program responsibility that 

 is now partially authorized in section 404 of the Clean Water Act or, if 

 necessary, by developing new incentives for the States to assume these respon- 

 sibilities? Many persons contend that programs for wetland protection and 

 management are best carried out primarily by the States, which have greater 

 familiarity with conditions within their jurisdictions. Other persons respond 

 that wetland protection is better served by a section 404 program that Is 

 national in character, in order to ensure consistent application of resource 

 management principles. 



