183 



• NASF opposes development of re^onal Management Measure ^idance. It 

 would add unnecessary complexity, inconsistency and inefficiency to the pro- 

 cess. 



• Incentives and assistance programs should be expanded to include silvicul- 

 tural non-p)oint source preventive practices such as Best Management Practices 

 (e.g., Agrictilture Conservation Program, Water Quality Incentives Programs). 



Wetlands Protection: 



NASF recognizes that forested wetlands represent important National resources deserving 

 of attention £ind protection. We hope the pubHc and Congress will continue to recognize that 

 forestry is a land use that is compatible with the goals of wetland protection. Forest man- 

 agement contributes to the maintenance and enhancement of wetland functions and val- 

 ues while allowing landowners the opportunity to derive income and other benefits. 

 Forested wetlands can and should be managed to provide economic returns to landowners 

 without compromising the integrity of wetland functions and values. 



The 1 988 Final Report of the National Wetlands Policv Forum which first coined the goal 

 of 'no net loss' found that "appropriate silvicultural operations can be carried out without 

 damaging the ecosystem. Good silvicultural management practices and the production of 

 native crop species can generate income without significant loss of wetlands functions. 

 Private landowners, including timber companies, should be encouraged to pursue ecologi- 

 cally sound silvicultural practices in privately owned forested wetlands". 



The 404 program enables this through exemptions for 'ongoing' and 'normal' silvicul- 

 tural activities. It is essential that these exemptions be extended. 



Recommendations for Wetlands Protection legislation: 



• Continue the current Section 404 exemptions for normal and ongoing silvi- 

 cultural activities. 



• Include and/or adapt incentive-based approaches for non-industrial private 

 forest lands to gain lasting landowner commitment. 



• Establish clear national goals and values for wetlands protection at the fed- 

 eral level; allow flexibility to the states to design programs to achieve these 

 goals and tailor management to local hydrologic and ecological conditions. 



• Ensure states (incdiiding state forestry) have the opportunity to participate in 

 training and become certified in wetland delineation. 



• Recognize that for many owners of forested wetlands, income fi^om timber 

 production is the only economic value coming to them from these lands. 

 Denying an owner the rij^t to manage wetland forest resources and produce 

 timber for markets would in effect 'take' aU residual economic value from 

 many landowners. 



• NASF supports a wetlands appeal process whereby forest wetlands owners 

 can appeal EPA jurisdictional determinations including notices alleging vi- 

 olations for Section 404(f). A pre-enforcement administrative appeal is a 

 more cooperative and less adversarial process to resolve areas of disagree- 

 ment. An administrative appeal should occur before a penalty is assessed^ 



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