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ATTACHMENT 5 



THE PRESIDENT'S PLAN 

 "PROTECTING AMERICA'S WETLANDS: A 

 FAIR, FLEXIBLE AND EFFECTIVE APPROACH- 

 ISSUED AUGUST 24, 1993 



March 23, 1994 



The Coalition prefers the concepts offered in the President's Plan to 

 either H.R. 350 or H.R. 3465. However, it is difficult to comment on the specifics of 

 the program since most of the promised Executive Branch actions that will provide the 

 substance of the plan have not yet been taken. Nevertheless, the Coalition likes the 

 administrative appeals process that has been promised by the President; the fact that 

 the Soil Conservation Service is to take the lead on the delineation of agricultural 

 lands; the fact that the benefits of a broadly defined mitigation banking program are 

 recognized; the recognition that all wetlands are not of equal value and that flexibility 

 is needed in the Section 404 permitting methodology; and the fact that the benefits 

 of "classification" of wetlands are recognized by incorporating "classification" in the 

 proposed state wetlands and watershed management plans. The entire list of 

 principles incorporated in the President's Plan is attached to this document. 



The Coalition strongly opposes the expansion of the Section 404 

 permitting program through the adoption of the so-called Tulloch rule and is 

 disappointed that the President's Plan does not address the legitimate concerns of the 

 State of Alaska. The Coalition is also disappointed that the Administration has not 

 submitted legislation to implement its plan and has not taken the promised action to 

 implement the plan administratively. 



