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function and value, and requires that all government agencies adhere to this 

 single inventory methodology. We suggest that the Corps of Engineers be 

 mandated to conduct and maintain the inventory of wetland functions and 

 values in consultation with the Soil Conservation Service. Regulatory efforts 

 should only offer a protection to the nation's most valuable and unique 

 wetland areas. 



Definition and Delineation of Wetlands 



The temporary return to the 1987 wetland manual is an improvement over the 

 1989 manual, but it too contains some of the uncertainties that led to the 

 original controversy. The conflict over wetland delineation stems from the lack 

 of a clear public policy to apply good science. In that context, we look forward 

 to the product of the National Academy of Sciences (NAS), but we do not view 

 the NAS study as a panacea. As members of the House, you, not the NAS, 

 must be the arbiter of that conflict, the source of the compromise for what 

 constitutes a federally regulated wetland. Eighteen more months of study will 

 not resolve it. 



Ultimately, private landowners should not be required to bear the cost of 

 protecting "wetlands" that are recognized by the Clean Water Act as being a 

 "pubUc resource." Congress should estabUsh the concept in the Clean Water 

 Act that certain types of wetlands may qualify technically as a wetland but 

 should not be subject to federal regvilation because they have no significant 

 function or value. 



Farm Bureau is very concerned that a definition with explicit reference to 

 geological features such as potholes, playas, vernal pools and etc., could mean 

 that all of these geographic locations are jurisdictional wetlands, regardless of 

 the presence of any required wetland criteria. It also fails to differentiate 

 between a wetland by definition and a jurisdictional wetland. 



Farm Bvireau recommends: 



• "Normal circumstances"--defined in this legislation to mean current 

 physical conditions and land use. 



• Wetlands should be defined as naturally occurring areas of 

 predominantly hydric soils, as determined by soil taxonomy, that 

 support hydrophytic vegetation because of existing wetland hydrology. 

 A hydric soil is a soil that in its natural state is satvu-ated, flooded or 

 ponded long enough during the active growing season to have 

 predominant anaerobic conditions at the surface; and hydrophytic 



