CRS-31 



Con 



Other persons respond that the present system works acceptably. States 

 have defined wetlands and management goals for purposes that are different from 

 the Federal water quality goal. Some States that have initiated a wetland pro- 

 gram would now like to gain increased responsibilities through a stronger role 

 in the Federal program. So long as the administering State agency can properly 

 maintain the separated identities of these two programs, there is no reason to 

 force consistency. The benefits to applicants would be negligible so long as 

 the State agency can clearly indicate how, geographically and procedurally, 

 the two programs operate, and how they overlap and differ. 



The Federal program should not alter the flexibility of States to admin- 

 ister more, the same, or less wetlands or wetland parameters than the Federal 

 program. The Federal government should try to encourage States to participate 

 more actively in the Federal program; a requirement to adopt a uniform defin- 

 ition of key terms would be a strong disincentive. The present Federal program 

 should remain in place in States that choose not to assume responsibilities. 



Issue 4 



Should the national wetlands inventory be used as the basis for deter- 

 mining wetland boundaries under the regulatory program? Some persons contend 

 that the current national assessment is designed to identify all of the 

 Nation's wetlands and, thus, is an appropriate definitional tool for the 

 section 404 regulatory program. Other persons respond that the wetlands inven- 

 tory is primarily a scientific effort, with purposes and goals that differ from 

 those of a regulatory program, and should not be utilized for purposes of regu- 

 lation. 



