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lands have a significant probability of being convened to agricultural lands; and it is more 

 efficient for the SCS to do this work rather than other agencies. The MOA also includes 

 provisions to ensure that all Federal agency personnel conducting wetlands delineations are 

 properly trained and that standard, agreed-upon methods will be used in making such 

 determinations. An ongoing review of the SCS wetlands delineation process that can be 

 carried out by the other Federal agencies under the MOA will also add to the consistency of 

 Federal wedands programs. 



In addition, when its comprehensive wetlands plan was released last August, the 

 Administration issued a final rule that affirms the exclusion of an estimated 53 million acres 

 of prior converted croplands from Clean Water Act jurisdiction. These are areas that, prior 

 to December 23, 1985, were cropped and manipulated to the extent that they no longer 

 perform the functions they did in their natural condition. The Administration plan 

 recommends corresponding congressional action to define the term "waters of the United 

 States" in the Clean Water Act to exclude prior converted croplands. 



The Administration Plan does not explicitiy address the permit exemptions listed in Section 

 404(f)(1). However, some proposals would change these exemptions. In general, we oppose 

 revising these exemptions, which we believe would generate new controversy and confusion. 

 In particular, the proposal to exempt discharges associated with "maintenance" is vague and 

 creates the potential to exempt a broad range of activities. Similarly, the Administration is 

 concerned that the language exempting water management activities associated with cranberry 

 farming is too broad and may inappropriately exempt those cranberry farming activities with 

 more than minimal environmental impacts. The Administration is eager to work with the 

 Subcommittee to address these outstanding issues and clarify that general permits have and 

 could more specifically and appropriately address such discharges. 



