82 



UK 



ASSOCIATED BUILDERS 

 AND CONTRACTORS. INC. 



Octobers, 1993 



The Honorable Gerry Studds 



Chairman 



Merchant Marine and Fisheries Committee 



U.S. House of Representatives 



1334 Longworth House Office Building 



Washington, DC. 20515 



Dear Chairman Studds: 



On behalf of the Associated Builders and Contractors, I would like to submit for the 

 hearing record the following statement regarding the Administration's new wetlands policy. 



Associated Builders and Contractors (ABC) represents some 16,000 contractors, 

 subcontractors, material suppliers and related firms from across the country and from all 

 specialties in the construction industry. Our diverse membership is bound by a 

 commitment to the meht shop -- the most efficient construction technique in America. 

 The merit shop philosophy of awarding construction contracts to the lowest responsible 

 bidder, regardless of labor affiliation, through open and competitive bidding, assures 

 taxpayers and consumers the most value for their construction dollar. With 75 percent 

 of construction done today by merit shop contractors, ABC is proud to be their voice. 



ABC looks forward to working with the Administration, the Merchant Mahne and 

 Fisheries Committee, as well as the various other committees that are working to develop 

 a comprehensive wetlands policy for our nation. We recognize the environmental value 

 of wetlands and are concerned by the recent estimates of significant wetland loss. ABC 

 wholeheartedly supports efforts to protect legitimate wetlands but believes a more 

 streamlined and efficient process is in order. 



WETLANDS DELINEATION 



ABC is pleased that the Administration's wetlands policy provides for the continued 

 use of theM987 Wetlands Delineation Manual until the National Academy of Sciences 

 (MAS) report on wetlands is completed. ABC has advocated that any changes in the 

 delineation guidelines be open to public comment, which the Administration plan allows 

 for. When the delineation policy was last revised in 1989, the Federal Manual for 

 Identifying and Delineating Jurisdictional Wetlands dramatically extended areas regulated 

 as wetlands and expanded the jurisdiction of the Environmental Protection Agency (EPA) 

 and the U.S. Army Corps of Engineers (Corps) over an already poorly functioning 

 program. The manual went into effect without public notice, without an opportunity for 



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