agencies including EPA. This early coordination is especially important for 

 controversial projects involving significant environmental impacts. 



In addition, EPA and Corps staff are encouraged to work together to resolve 

 differences regarding individual permit applications (e.g., project alternatives, mitigation 

 requirements, specific permit conditions) early in the review process. 



Coordination among agencies on the development of regional and general permits 

 under the Section 404 regulatory program creates additional opportunities to expedite 

 the permit process for projects with minor environmental impact. Guidance from EPA 

 and Corps Headquarters (e.g., Memoranda of Agreement, Corps Regulatory Guidance 

 Letters) reduces or eliminates confusion and controversy sometimes associated with 

 implementation of the Section 404 regulatory program that might otherwise lead to 

 delays during permit review. 



Finally, the Administration announced on August 9, 1991, a comprehensive plan for 

 improving the Section 404 regulatory program, including measures for effective 

 coordination among the agencies (see attached Fact Sheet on "Protecting America's 

 Wetlands"). EPA and the Corps will provide further guidance as we move in this 

 direction. 



What administrative steps other than the Federal Manual are EPA and the Corps 

 taking to respond to concerns being raised about the Section 404 program? 



The Administration announced on August 9, 1991, a comprehensive plan for improving 

 the protection of the nation's wetlands, including measures to improve the Section 404 

 regulatory program (see attached Fact Sheet on "Protecting America's Wetlands"). 

 EPA and the Corps will provide further guidance as we move in this direction. 



In addition, in response to specific regional and State concerns about timeliness and 

 complexity of the Section 404 regulatory program, EPA and the Corps have employed a 

 variety of administrative tools to respond to specific concerns without reducing our 

 ability to protect wetlands. 



Joint Policy Guidance - EPA and Corps Headquarters have issued policy guidance (e.g., 

 Memoranda of Agreement, Corps Regulatory Guidance Letters) intended to reduce or 

 eliminate confusion and controversy sometimes associated with implementation of the 

 Section 404 regulatory program. Such guidance has helped reduce delays during permit 

 review and clarified which activities or areas are subject to the Section 404 program. 

 For example, in response to concerns raised regarding activities in areas subject to 

 agriculture, the Corps issued Regulatory Guidance Letter 90-7 which clarified that prior 

 converted cropland (estimated up to 60 million acres) are NOT subject to Section 404 



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