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restate and further clarify its intent to include all land used in production 

 agriculture for food, fiber, timber and biomass. 



Farm Bureau recommends that the word "normal" be dropped from the law 

 in Section 404(f)(1) because it has specific relation to the date the law was 

 passed and thus inhibits the adoption of new or different farming practices at 

 some future date. In addition it should be clarified that the normal farming 

 exemption supersedes all other sections of the Clean Water Act. Congress 

 should clarify that brush and land-clearing as part of farming, ranching and 

 silviculture operations are also exempt in order to avoid confusion with the 

 recent Tvdloch ruling. 



Farm Bureau recommends the specific recognition that ranch roads should 

 be allowed to be constructed and maintained the same as farm and forest 

 roads. 



Soil Conservation Service 



The USDA Soil Conservation Service (SCS) should be the coordinating agency 

 delineating wetlands on agricultural land. 



We strongly agree with the Administration's efforts to make SCS wetlands 

 delineations the final government position on the extent of Swampbuster and 

 Clean Water Act jurisdiction on agricvdtural lands. However, we beUeve this 

 concept needs to be incorporated into legislation and enacted into law. It 

 would provide much needed consistency and greatly reduce potential conflict. 



There are several reasons why SCS is the appropriate agency to delineate all 

 wetlands on agricultural lands. SCS has offices in nearly every county, making 

 it much more cost-effective and timely for them to do delineations than it 

 would be for any of the other agencies. SCS is a technical assistance agency. 

 The U.S. Fish and Wildlife Service, EPA and Corps of Engineers are wildlife 

 and land managers, regulators and, originally, bridge builders for the Armed 

 Services, respectively. These three agencies already have little or no 

 understanding of agriculture. Finally, SCS staff have a much better feel for 

 the local landscape and cUmate than the other three and should be better able 

 to recognize rehct wetland situations where hydric soil is still present but 

 hydrology has been removed. 



Farm Bureau strongly recommends that authority for delineation of all 

 wetlands on agricultural land be the sole responsibility of the Soil Conservation 

 Service (SCS). 



