CRS-113 



Several of the State managers were most concerned with the cumulative 

 loss of wetlands and the impact of those losses on larger ecological systems. 

 As a result, programs for mitigation and restoration seem to be rapidly gaining 

 in popularity. None of the State respondents discussed either the cumulative 

 loss or the incremental impact questions in detail, nor were any specific 

 suggestions given on how to consider these problems in future permit decisions. 



Several managers also pointed to problems and concerns in differenti- 

 ating wetland types. The wetland manager from Massachusetts pointed out 

 that coastal wetlands are all treated similarly because, from the standpoint 

 of the State's requirements, they are similar natural units. Inland wet- 

 lands, on the other hand, present difficult problems because of the wide vari- 

 ety of natural systems, each with its own set of functions and values. 



The State of Louisiana is developing a three-tiered system to deal with 

 its wetlands. The highest tier will include special management areas, where 

 protection will be strongest. These areas are being proposed by a team of 

 scientists using 12 factors including measures of biological productivity, 

 the condition of the wetland, and the species that inhabit it. 



The Minnesota wetland manager pointed out another problem in differenti- 

 ating wetlands — seasonal variation. Many inland wetland types expand and con- 

 tract during wet and dry seasons. He reported that, in one recent case, a 

 permitting decision had been appealed to the district court. The case was 

 heard during the dry season. The judge visited the site, walked across it 

 without getting his feet wet and declared that it was not a wetland and could 

 be converted to another use. If he had visited the same site during the wet 

 season, he would have had trouble wading through the birds. 



Concern was expressed about limited compatibility between Federal and State 

 programs. Several State program managers said that the Federal classification 



