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public investment in data collection and functional assessment. Costs for these efforts can be contained 

 if the functions of wetlands were given due consideration and incorporated in the course of current and 

 future publicly funded flood control, water quality, soil and forest survey and natural heritage 

 programs. Part of the reason that the nation has experienced massive loss of wetlands is that their 

 Kinctions and limitations have been poorly understood by engineers and agricultural land managers. 



Those who would develop or drain wetlands search for a simple value system that requires no 

 biological expertise and limited data collection or technical review. The Committee is concerned that 

 some categorization proposals would allow for categorization by non-wetland professionals, i.e., 

 developers or engineers. We do not believe that other disciplines are competent to evaluate wetlands 

 or wetland functional values and at this siage in the development of the science, we are opposed to 

 those efforts. 



The Committee advocates expanded use of planning level assessment by state and federal 

 agencies for the purpose of: 



a. Improving and standardizing application of current knowledge that is applicable to 



wetland evaluation; 



b. Encouraging a multi-disciplinary approach to wetland evaluation; 



c. Encouraging a systems approach to wetland evaluation, 



d. Improving agency consistency in the wetland permit review process, and 



e. Providing advance warning to the regulated community of wetland areas that will 



require more than a basic level of review. 



The Committee is wncerned that certain proposals for categorization for regulatory protection 

 purposes do not distinguish among the several functions of wetlands, and lump values, such as flood ^ 

 control and wildlife habitat that have different biological and physical bases, into a few simple value 

 classes. Schemes to put wetlands into nation-wide value classes without providing for an^ process to 

 distinguish between regional differences are similarly suspect. In addition, some categorization 

 pn)posals appear to have a strong element of triage, i.e., if wetlands were assigned to high (Tvpe A), 

 medium (Type B) and low value (Type C) categories, the Committee is a)ncerned that wetlands in the 

 low value category would receive less protection than they currently are provided. Low value 

 wetlands could easily fall under a nationwide permit, allowing development and subsequent loss ot 

 these so-called low value wetlands when in fact, their value is largely unknown. 



Finally the Committee recommends that high priority be given to funding research to develop 

 improved techniques and methodologies to quantify the functional values of wetlands and effects of 

 wetland alterations. This research should develop an objective, quantitative, sound evaluation process 

 that can be coupled with the National Wetlands Inventory and should be accomplished by joint private, 

 sute and federal action. Similar research is urgently needed to improve inadequate methods to create 

 compensatory wetlands that provide all of the identified wetland functions. 



TWSREPt:B.wps Augu»i30. 1M3 



