CRS-115 



attempting to work out cooperative arrangements with the key Federal agencies 

 to develop a simpler system that operates through the State, at least for cer- 

 tain types of permits. In Connecticut, under the present system, applicants 

 file two permits. But the State and Federal government define wetlands dif- 

 ferently, so in some cases, only one or the other permit is needed. This 

 State is trying to arrange with the Corps to review permits so that both appli- 

 cations could be processed in a single step. 



It is not uncommon for Federal agencies and the State agency to disagree 

 on a permit. Most of these disagreements are evidently not on whether to 

 award the permit or not, but rather on conditions to be attached to the 

 permit. These conditions, which further define how or when the work is to 

 be done, may be inconsistent or even incompatible. This lack of coordination 

 can leave the applicant bewildered about what to do next and can further delay 

 his project. Several managers differentiated large, controversial proposals 

 which receive detailed attention from smaller proposals. State and Federal 

 wetland people tend to coordinate their review and analysis of large projects, 

 but work independently on smaller proposals, primarily because of time con- 

 straints. 



Other sources of concern to individuals seeking a permit are the length 

 of time required to process it and actual Federal review. On the first point, 

 the Louisiana wetlands manager noted that the State processed 65 percent of 

 its applications In 55 days while the Corps processed 50 percent in 75 days. 

 According to the Massachusetts manager, his State requires action within 70 

 days, while the Corps can take up to six months. In terms of Federal review, 

 it should be noted that individual District offices of the Corps vary in the 

 average length of time required to process a permit application; this fact 

 may, in part, explain differences reported by the States. For example, the 



96-073 0-82 



