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Permit Processing Improvements 



We agree with the Administration's proposal to provide decisions within a 

 90-day period. Farm Bureau strongly believes Congress should include an 

 appeals process for wetland delineations, permit denials/restrictions and 

 administration penalties. 



Farm Bureau recommends Section 404 individual permit decision within a 

 90-day period. No more than one additional 90-day extension can be requested 

 by any one agency or combination of agencies if additional data is required for 

 an individual Section 404 permit. If a decision is not made by the end of these 

 time frames the permit should be considered granted. 



Farm Bureau recommends the following regarding Costs and Fees of 

 Parties: In court cases where a party other than the United States prevails, 

 the prevailing party should be awarded fees and other expenses in connection 

 with the proceeding regardless of whether the proceeding is brought by the 

 United States for violations of the Act or by the prevailing party for issuance or 

 denial of a Section 404 permit. If the party is dissatisfied with the 

 determination of fee and other expenses awarded, there should be an additional 

 appeals process aveiilable. 



Appeals Process 



We are pleased to see the Administration has recognized the need for an 

 appeals process and recommended limiting participation of people who are not 

 directly affected by the decision. 



Farm Bvireau recommends Congress provide an equitable, efficient and 

 inexpensive means for landowners to appeal 1) delineations, 2) permit 

 applications, and 3) penalties and fines without going to court. 



General Permit Improvements 



Farm Bureau supports the concept of general permits. We believe Congress 

 should allow state, regional or nationwide permits that will allow activities 

 that cause only minimal adverse environmental effects. Farm Bureau 

 questions proposals that will make individual and general permits contingent 

 on the development of watershed/wetland management plans. We are also 

 very concerned about what appears to be an added requirement to add 

 mitigation requirements to general permits. 



