CRS-27 



protected under State-based programs (see pages A5-51 for discussion of wetland 

 functions). The Federal regulatory role may well serve to make existing State 

 and local programs more effective and more consistant. At the same time, the 

 decentralized offices of the Corps' 38 District Engineers provide flexibility 

 to recognize specific State and regional needs. 



Another concern of some of these persons is that greater State assumption 

 of regulatory responsibility in these areas could result in reduced water qual- 

 ity and wetland protection, as well as uneven regulatory patterns among the 

 States. For example, States with coastal wetlands have, in many cases, oper- 

 ated strong wetland programs (see Chapter IV), and it is likely that these 

 States would continue their efforts. However, in the absence of a visible Fed- 

 eral leadership role and without adequate Federal funding support other States 

 may be unwilling to assume added or new responsibilities, and they might conduct 

 only a minimal program. 



Finally, it is uncertain whether major time savings will be achieved in 

 project review, particularly for large development projects, some of which have 

 experienced lengthy permit delays. The Corps has reported that the few large 

 projects which account for the preponderance of economic activity (commercial 

 and industrial developments) regulated under its program would continue to fall 

 under the National Environmental Policy Act. In addition, according to the 

 Corps' analyses, it is frequently State and local activities, such as review 

 and issuance of water quality certificates, that are the greatest cause of pro- 

 ject delay. 



Issue 2 



Should section 404 be revised to authorize delegation of wetland manage- 

 ment authority by States to local governments? Since States may already assume 

 responsibility for a portion of the section 404 program, some persons contend 



