CRS-93 



site. Conditions and general permits have both been subject to controversy 

 and analysis about their environmental and regulatory effectiveness. 126 / 



Concerns about the permit process have caused the Presidential Task Force 

 on Regulatory Relief to request that the Corps, with OMB, review the section 

 404 program. The five topics addressed in the review were: 



1. shorten permit processing time; 



2. give states more opportunities to issue permits; 



3. eliminate conflicting and overlapping policies; 



4. expand regional and nationwide general permits to give blanket 

 approval to certain dredge and fill activities; and 



5. more explicitly define the objectives and jurisdictional extent 

 extent of the permit program. 127 / 



The review was conducted using the Regulatory Impact Analysis process defined 

 in Executive Order 12291 on regulatory reform. A draft study has been com- 

 pleted which reviews the present program in terms of benefits and costs, and 

 suggests several alternatives. This report has been submitted to the Task 

 Force on Regulatory Relief 128 / 



The Role of EPA 



EPA has substantial responsibilities under the section 404 program. These 

 diverse responsibilities, which presume active cooperation between the Corps 

 and EPA, include the following: 



126 / For example, see Blumm, The Clean Water Act's Section 404 Permit Pro- 

 gram, p. 428-432; and Holmes, Federal Participation in Land Use Decision Making, 

 p. 394-396. 



127 / National Wetlands Newsletter, Corps Reviews Section 404, v. 3, 

 no. 5, 1981. p. 6. 



128/ U.S. Army Corps of Engineers, Impact Analysis, Draft. 



