A Return to Ecological Concepts

The administration's proposed revisions to the 1989 Federal Manual for Identifying and Delineating Jurisdictional Wetlands will result in tremendous losses of wetland functions nationwide, and will cost both society as a whole as well as developers far more than previous manuals used by the Army Corps of Engineers to delineate wetlands.  This is because the manual is technically unsound, requires excessive field testing, does not provide field personnel with the ability to obtain repeatable results, and the delineations that result eliminate areas clearly possessing functions attributable to wetlands, such as stormwater retention, nutrient uptake, and waterfowl and fishery use. If we adopt a definition of wetlands that limits their full geographic range through subjective policy considerations, as is the growing trend, we can expect enormous losses of wetlands and functions.