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Delineation Training. Certification and Outreach 



The Administration has accurately characterized the situation by stating that 

 "for too long, contradictory policies from feuding federal agencies have blocked 

 progress, creating uncertainty and confusion." Farm Bureau is concerned this 

 situation will continue unless Congress requires development of a strong 

 delineator certification program. The goal should be to have anyone who 

 delineates wetlands certified and reviewed for consistency. 



Farm Bureau supports the Administration's efforts to have all federal agencies 

 and private sector delineators trained and certified to improve accuracy and 

 consistency in delineating jurisdictional wetlands. However, it fails to require 

 an independent review board with explicit oversight and individual delineator 

 performance evaluation. 



Farm Bureau recommends: The goal should be to develop a national 

 certification program that strives for consistency among all certified 

 delineators. 



Legislation should include a national certification program that 



requires: 



a) proficiency standards for delineators; 



b) 5-year certification duration; 



c) specific performance review and evaluation that wo\ald include: 



1) random field performance reviews; 



2) random data sheet performance reviews; 



3) emergency performance review based upon complaints; and 



d) continuing education. 



Mitigation Banking 



Farm Bureau supports proposals to provide for mitigation banking. Farm 

 Bureau is concerned that this proposal provides no guidance on mitigation 

 requirements (acreage), lacks specific guidelines in the replacement of functions 

 and values and requires mitigation "in advance." Mitigation should not be tied 

 to acreage, but rather to function and values. 



Farm Bureau recommends mitigation requirements based on the 

 replacement of wetland functions, but in no case should acreage replacements 

 exceed one acre for one acre. We also recommend changing the "mitigation 

 bank" definition to remove the requirement for advance mitigation when 

 simviltaneous efforts wiU be practicable. 



