186 



• Recognize that for many owners of forested wetlands, income from timber production is 

 the only economic value coming to hem from these lands. Denying an owner the right to 

 manage wetland forest resources and produce timber for markets would in effect 'take' 

 all residual economic value from many landowners. 



• NASF supports a wetlands appeal process whereby forest wetlands owners can appeal 

 EPA jurisdictional determinations including notices alleging violations for Section 404 

 (0 . A pre-enforcement administrative appeal is a more cooperative and less adversarial 

 process to resolve areas of disagreement. An administrative appeal should occur before a 

 penalty is assessed. 



• NASF supports that all three wetland criteria -- hydrology, soils and vegetation -- should 

 be present to verify a site as "water of the United States. " 



- 7 



