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that is would be desirable to encourage delegation of this State authority to 

 local governments, as well, because of strong local interest in and knowledge 

 of wetlands within their jurisdictions. Other persons respond, however, that 

 problems of conflicting interest, inconsistency, and administrative difficul- 

 ties, would be greater under locally-managed wetland programs. 



Pro 



In the 1977 Clean Water Act amendments, Congress authorized delegation 

 of section 404 authority to qualified States but provided no mechanism for 

 delegation of the national program to local governments. However, some persons 

 contend that there are several reasons why it may now be appropriate to do so. 



Several States have wetland programs that rely on local government for 

 implementation. In these States, such as Connecticut, the State cannot partic- 

 ipate in the Federal program because it has delegated management responsibil- 

 ities for freshwater wetlands to local government. Yet the State/local partner- 

 ship, at least in Connecticut, is working well, according to a State official. 



Lessons from the Federal coastal zone management program may also be in- 

 structive, according to this viewpoint. Several States with approved coastal 

 plans are implementing them by requiring local jurisdictions to develop detailed 

 plans that are then approved by the State. These plans become the vehicle for 

 implementing the more general State plan. When local jurisdictions refuse to 

 take on these responsibilities, the State steps in, but most local jurisdic- 

 tions apparently prefer the option of operating their own programs. Local pro- 

 grams can allow for State review and involvement when the issue is of more than 

 local concern. 



The best program can occur when local officials, who know local conditions, 

 have a strong role. States should retain an ability to intercede in a local 

 program, just as the Federal government now can intercede in an approved State 



