Wetlands Overview: Problems With Acreage Data Persist (Letter Report,
07/01/98, GAO/RCED-98-150).

Pursuant to a congressional request, GAO: (1) developed an inventory of
the federal agencies involved in wetlands-related activities and the
funding and staffing associated with their activities during fiscal
years (FY) 1990 through 1997; and (2) determined if the data on wetlands
acreage reported by these agencies are consistent and reliable.

GAO noted that: (1) at least 36 agencies conducted wetlands-related
activities during FY 1990 through FY 1997; (2) the total funding
associated each year with the agencies' efforts ranged from about $508
million in FY 1990 to about $787 million in FY 1997; (3) staffing
associated with the agencies' activities during this period ranged from
about 3,271 full-time-equivalent staff-years in FY 1993 to about 4,308
full-time-equivalent staff-years in FY 1997; (4) six agencies were
primarily involved in and responsible for implementing wetlands-related
programs; (5) these six agencies accounted for more than 70 percent of
the funding and 65 percent of the staffing associated each year with
such activities; (6) the consistency and reliability of wetlands acreage
data reported by the federal agencies are questionable; (7) the Fish and
Wildlife Service and the Natural Resources Conservation Service maintain
resource inventories that provide estimates of the nation's remaining
wetlands acreage, annual rates of wetlands gains and losses, and the
primary cause(s) for losses; (8) although both inventories have reported
that the rate of wetlands loss has declined, the inventories' estimates
are not completely consistent; (9) a single set of wetlands acreage
numbers that could be used to evaluate the progress made in achieving
the goal of no net loss of the nation's remaining wetlands is not
available; (10) officials from each of the agencies have questioned the
estimates made by the other, and the Environmental Protection Agency has
expressed concern about both inventories; (11) the agencies' current
reporting practices do not permit the actual accomplishments of the
agencies to be determined; (12) since 1989, several interagency groups
have attempted to improve wetlands data; (13) because their efforts have
not resolved these problems, the administration recently announced new
efforts to improve wetlands data; (14) in May 1998, the administration
issued a plan to accomplish a key action--the development of a single
wetlands status and trends report; and (15) as of June 10, 1998, details
have not yet been developed on how the other actions announced by the
administration will be accomplished.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-98-150
     TITLE:  Wetlands Overview: Problems With Acreage Data Persist
      DATE:  07/01/98
   SUBJECT:  Water resources conservation
             Reporting requirements
             Interagency relations
             Environmental research
             Data integrity
             Statistical data
IDENTIFIER:  USDA National Resources Inventory
             FWS National Wetlands Inventory
             Clean Water Action Plan
             
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Cover
================================================================ COVER


Report to the Chairman, Subcommittee on VA, HUD, and Independent
Agencies, Committee on Appropriations,
U.S.  Senate

July 1998

WETLANDS OVERVIEW - PROBLEMS WITH
ACREAGE DATA PERSIST

GAO/RCED-98-150

Wetlands Overview

(141088)


Abbreviations
=============================================================== ABBREV

  ARS - Agricultural Research Service
  BPA - Bonneville Power Administration
  DOE - Department of Energy
  EPA - Environmental Protection Agency
  ERS - Economic Research Service
  EQIP - Environmental Quality Incentives Program
  FEMA - Federal Emergency Management Agency
  FSA - Farm Service Agency
  FWS - Fish and Wildlife Service
  GAO - General Accounting Office
  NOAA - National Oceanic and Atmospheric Administration
  NRCS - Natural Resources Conservation Service
  NRI - National Resources Inventory
  NWI - National Wetlands Inventory
  USDA - U.S.  Department of Agriculture
  WRP - Wetlands Reserve Program

Letter
=============================================================== LETTER


B-279687

July 1, 1998

The Honorable Christopher S.  Bond
Chairman, Subcommittee on VA, HUD, and
 Independent Agencies
Committee on Appropriations
United States Senate

Dear Mr.  Chairman: 

According to estimates by the Fish and Wildlife Service, more than
half of the 221 million acres of wetlands that existed during
Colonial times in what is now the contiguous United States have been
lost.  These areas, once considered worthless, are now recognized for
the variety of important functions that they perform, such as
providing wildlife habitat, maintaining water quality, and aiding in
flood control.  However, the issue of wetlands protection and the
various federal programs that have evolved piecemeal over the years
to protect and manage this resource have been subjects of continued
debate.  Concerned about the lack of consolidated information on the
federal commitment to wetlands, you asked that we (1) develop an
inventory of the federal agencies involved in wetlands-related
activities and the funding and staffing associated with their
activities during fiscal years 1990 through 1997 and (2) determine if
the data on wetlands acreage reported by these agencies are
consistent and reliable. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

At least 36 federal agencies, to varying degrees, conducted
wetlands-related activities during fiscal years 1990 through 1997. 
These activities included acquiring, regulating, restoring,
enhancing, mapping, inventorying, delineating, and conducting
research relating to wetlands.  The total funding associated each
year with the agencies' efforts ranged from a low of about $508
million in fiscal year 1990 to a high of about $787 million in fiscal
year 1997 (in constant 1997 dollars).  Staffing associated with the
agencies' activities during this period ranged from a low of about
3,271 full-time-equivalent staff-years in fiscal year 1993 to a high
of about 4,308 full-time-equivalent staff-years in fiscal year 1997. 

Six agencies--the Army Corps of Engineers, the Department of
Agriculture's Farm Service Agency and the Natural Resources
Conservation Service, the Department of the Interior's Fish and
Wildlife Service, the Department of Commerce's National Oceanic and
Atmospheric Administration, and the Environmental Protection
Agency--were the primary agencies involved in and responsible for
implementing wetlands-related programs.  These six agencies accounted
for more than 70 percent of the funding and 65 percent of the
staffing associated each year with such activities.  The other 30
agencies' wetlands-related activities are generally limited to (1)
general monitoring or stewardship activities or (2) avoiding and
mitigating potential impacts to wetlands from their own projects and
activities.  (App.  II contains a brief discussion of each agency's
principal wetlands-related activities, and app.  III contains
detailed information on the funding and staffing associated with
these activities during fiscal years 1990 through 1997.)

The consistency and reliability of wetlands acreage data reported by
the federal agencies are questionable.  The Department of Interior's
Fish and Wildlife Service and the Department of Agriculture's Natural
Resources Conservation Service maintain resource inventories that
provide estimates of the nation's remaining wetlands acreage, annual
rates of wetlands gains and losses, and the primary cause(s) for
losses.  However, although both inventories have reported that the
rate of "wetlands loss" has declined, the inventories' estimates are
not completely consistent.  Consequently, a single set of wetlands
acreage numbers that could be used to evaluate the progress made in
achieving the goal of "no net loss" of the nation's remaining
wetlands is not available.  In addition, officials from each of the
agencies have questioned the estimates made by the other, and
officials from the Environmental Protection Agency have expressed
concern about the estimates of both inventories. 

Moreover, the agencies' current reporting practices do not permit the
actual accomplishments of the agencies--that is, the number of acres
restored, enhanced, or otherwise improved--to be determined.  These
reporting practices include inconsistencies in the use of terms to
describe and report wetlands-related activities and the resulting
accomplishments, the inclusion of nonwetlands acreage in wetlands
project totals, and the double counting of accomplishments. 

Since 1989, several interagency groups, established to better
coordinate federal wetlands programs, have attempted to improve
wetlands data.  However, because their efforts have not resolved
these problems, the administration recently announced new efforts to
improve wetlands data.  Among the actions planned by the
administration are (1) supporting a single status and trends report
by the year 2000, (2) developing a plan to track annual changes in
the nation's wetlands of less than 100,000 acres, and (3)
establishing an interagency tracking system that will more accurately
account for changes in wetlands.  In May 1998, the administration
issued a plan to accomplish a key action--the development of a single
wetlands status and trends report.  However, as of June 10, 1998,
details have not yet been developed on how the other actions
announced by the administration will be accomplished. 


   BACKGROUND
------------------------------------------------------------ Letter :2

"Wetland" is a generic term used to describe a variety of wet
habitats.  In general, wetlands are characterized by the frequent or
prolonged presence of water at or near the soil surface, soils that
form under flooded or saturated conditions (hydric soils), and plants
that are adapted to life in these types of soils (hydrophytes). 

The United States contains many different types of wetlands, from
swamps in Florida to peatlands in northern Minnesota to tidal salt
marshes in Louisiana.  Figures 1 and 2, respectively, show two types
of wetlands found in the United States--coastal salt marsh wetlands
commonly found along the East and Gulf coasts and prairie pothole
wetlands commonly found in the plains of the North Central United
States. 

   Figure 1:  Coastal Salt Marsh
   Wetlands

   (See figure in printed
   edition.)

   Source:  National Wetlands
   Research Center, United States
   Geological Survey.

   (See figure in printed
   edition.)

   Figure 2:  Prairie Pothole
   Wetlands

   (See figure in printed
   edition.)

   Source:  National Wetlands
   Research Center, United States
   Geological Survey.

   (See figure in printed
   edition.)

Wetlands were once regarded as unimportant areas to be filled or
drained for agricultural or development activities.  However,
wetlands are now recognized for a variety of important functions that
they perform, including

  -- providing vital habitat for wildlife and waterfowl, including
     about half of the threatened and endangered species;

  -- providing spawning grounds for commercially and recreationally
     valuable fish and shellfish;

  -- providing flood control by slowing down and absorbing excess
     water during storms;

  -- maintaining water quality by filtering out pollutants before
     they enter streams, lakes, and oceans; and

  -- protecting coastal and upland areas from erosion. 

Over 25 federal statutes have been enacted relating to wetlands. 
These laws have resulted in the (1) regulation of activities
undertaken in areas designated as wetlands; (2) acquisition of
wetlands through purchase or protective easements that prevent
certain activities, such as draining and filling; (3) restoration of
damaged wetlands or the creation of new wetlands; and (4)
disincentives to altering wetlands or incentives to protect them in
their natural states.  (App.  I contains a brief discussion of the
principal wetlands-related statutes.)

Despite the passage of numerous laws and the issuance of two
presidential executive orders protecting wetlands, no specific or
consistent goal for the nation's wetlands-related efforts existed
until 1989.  On February 9, 1989, President Bush, in response to
recommendations made by the National Wetlands Policy Forum,\1
established the national goal of no net loss of wetlands.  The
current administration has also supported wetlands protection.  In
its wetlands plan, issued in August 1993, the administration included
an interim goal of no overall net loss of the nation's remaining
wetlands and a long-term goal of increasing the quality and quantity
of the nation's wetlands.  In its Clean Water Action Plan, issued on
February 19, 1998, the administration included a strategy to achieve
a net gain of up to 100,000 acres of wetlands each year, beginning in
the year 2005. 


--------------------
\1 In 1987, at the request of the Environmental Protection Agency,
the Conservation Foundation convened the National Wetlands Policy
Forum to address major policy concerns about how the nation should
protect and manage its valuable wetlands resources.  The 20 members
of the Forum included three governors, a state legislator, heads of
state agencies, a town supervisor, chief executive officers of
environmental groups and businesses, farmers and ranchers, and
academic experts.  Senior officials from five principal agencies
involved in wetlands protection and management participated as
ex-officio members. 


   THIRTY-SIX FEDERAL AGENCIES, TO
   VARYING DEGREES, WERE INVOLVED
   IN WETLANDS DURING FISCAL YEARS
   1990 THROUGH 1997
------------------------------------------------------------ Letter :3

At least thirty-six federal agencies,\2 to varying degrees, conducted
wetlands-related activities during fiscal years 1990 through 1997. 
The activities conducted by these agencies included acquiring,
regulating, restoring, enhancing, mapping, inventorying, delineating,
and conducting research relating to wetlands.  Six agencies--the Army
Corps of Engineers, the Department of Agriculture's Farm Service
Agency and the Natural Resources Conservation Service (NRCS), the
Department of Commerce's National Oceanic and Atmospheric
Administration, the Department of the Interior's Fish and Wildlife
Service (FWS), and the Environmental Protection Agency--are the
primary agencies involved in and responsible for implementing
wetlands-related programs.  The involvement of the 30 other agencies
was generally limited to (1) general monitoring or stewardship roles
or (2) the avoidance and mitigation of potential impacts to wetlands
from their own projects and activities.\3 As figures 3 and 4 show,
the six primary agencies accounted for most of the funding and
full-time-equivalent staff-years associated each year with the
wetlands-related activities of federal agencies. 

   Figure 3:  Funding Associated
   With Federal Agencies'
   Wetlands-Related Activities,
   Fiscal Years 1990 Through 1997

   (See figure in printed
   edition.)

   Figure 4:  Staffing Associated
   With Federal Agencies'
   Wetlands-Related Activities,
   Fiscal Years 1990 Through 1997

   (See figure in printed
   edition.)

Appendix II provides a brief description of some of the principal
wetlands-related activities of each agency, and appendix III contains
detailed information on the funding and full-time-equivalent
staff-years associated with the agencies' activities during fiscal
years 1990 through 1997. 


--------------------
\2 For the purposes of this report, the term "agency" represents
executive departments, subagencies of executive departments, and
other federal organizations. 

\3 Although the Federal Highway Administration expended over $50
million each year on wetlands-related activities during the 8-year
period covered by our review, these funds were spent primarily for
mitigation purposes.  Therefore, we did not include it as an agency
primarily involved in wetlands. 


   CONSISTENCY AND RELIABILITY OF
   WETLANDS ACREAGE DATA REPORTED
   BY FEDERAL AGENCIES ARE
   QUESTIONABLE
------------------------------------------------------------ Letter :4

The consistency and reliability of wetlands acreage data reported by
federal agencies are questionable.  Although both the Department of
the Interior's FWS and the Department of Agriculture's NRCS maintain
inventories that produce estimates of the nation's remaining wetlands
acreage and rates of wetlands gains and losses, the two inventories'
estimates are not completely consistent.  In addition, the current
reporting practices of the agencies do not allow the wetlands-related
accomplishments of the agencies to be determined.  These reporting
practices include a lack of consistency in the use of terms, the
inclusion of nonwetlands acreage in wetlands project totals, and the
double counting of accomplishments.  Despite the efforts of several
interagency groups to address problems with wetlands data, the
problems persist.  In its Clean Water Action Plan, the administration
recently announced new plans to improve wetlands data.  As called for
by the administration, the Interagency Wetlands Working Group has
developed an action plan to guide its efforts to produce a single
wetlands status and trends report.  However, as of June 10, 1998,
strategies had not yet been developed to address the other actions
planned by the administration to improve wetlands data. 


      TWO AGENCIES' ESTIMATES OF
      THE NATION'S REMAINING
      WETLANDS ACREAGE AND ANNUAL
      GAINS AND LOSSES VARY
---------------------------------------------------------- Letter :4.1

No single set of numbers representing the nation's remaining wetlands
acreage and annual gains and losses is available.  Estimates made by
two federal resource inventories, the National Wetlands Inventory and
the National Resources Inventory, maintained by the FWS and NRCS,
respectively, are not completely consistent. 

The National Wetlands Inventory, established to generate information
on the characteristics, extent, and status of the nation's wetlands
and deepwater habitat, is to provide an update of the status and
trends of the nation's wetlands at 10-year intervals.  The broader
National Resources Inventory is an inventory of land cover and use,
soil erosion, prime farmland, wetlands, and other natural resource
characteristics on nonfederal lands in the United States.  It
provides a record of the nation's conservation accomplishments and
future program needs.  The National Resources Inventory has been
conducted at 5-year intervals to determine the conditions and trends
in the use of soil, water, and related resources nationwide and
statewide.  However, it is now making the transition to an annualized
inventory process. 

Each inventory uses the wetlands data it collects\4 to produce
estimates of the nation's remaining wetlands acreage and the rate of
wetlands gains and losses.  The estimates made by each inventory are
based on sampling.  However, the two inventories use different
sampling techniques\5 and their estimates cover different time
periods.  The inventories also have used different
land-cover/land-use classifications categories for the causes of
wetlands losses.  Although both reported that the rate of wetlands
loss has declined, as shown in table 1, the estimates produced by
FWS' National Wetlands Inventory and NRCS' National Resources
Inventory are not completely consistent. 



                                Table 1
                
                Estimates of the Nation's Wetlands Gains
                  and Losses Produced by the National
                  Wetlands Inventory and the National
                          Resources Inventory

                              Estimates of      Estimates of
                             FWS' National    NRCS' National
                                  Wetlands         Resources
                                 Inventory         Inventory
                             covering 1985     covering 1982  Differen
Category                      through 1995      through 1992        ce
------------------------  ----------------  ----------------  --------
Total wetlands acreage         100,900,000       112,000,000  11,100,0
                                                                    00
Gross gain in wetlands           2,146,364           768,700  1,377,66
                                                                     4
Gross loss in wetlands           3,357,053         1,561,300  1,795,75
                                                                     3
Net loss of wetlands             1,210,689           792,600   418,089
Gross loss of wetlands           1,427,598           309,000  1,118,59
 to agriculture                                                      8
Gross loss of wetlands              84,006           886,000   801,994
 to development
----------------------------------------------------------------------
Source:  Fish and Wildlife Service and the Natural Resources
Conservation Service. 

As the table shows, the two inventories differ, sometimes
substantially, in their estimates.  Although the two inventories'
estimates of the nation's total remaining wetlands acreage varied
only about 10 percent, their estimates in other categories varied
more significantly.  For example, FWS reported that agricultural
activities were responsible for the loss of over 1.4 million acres of
wetlands--more than 4 times the loss attributed to agriculture by
NRCS.  NRCS, on the other hand, estimated that development was
responsible for the loss of 886,000 acres--about 11 times the number
of acres that FWS reported. 

Questions have been raised about the validity of the wetlands acreage
estimates made by both inventories.  Officials from each of the
agencies responsible for the inventories have questioned the
estimates made by the other, and officials from the Environmental
Protection Agency (EPA) have expressed concern about the estimates of
both inventories.  The issues raised by officials of the two
inventories and EPA include the adequacy of quality control of the
data and of quality assurance procedures, the dates of the aerial
photography used, and the methods used to develop the estimates. 


--------------------
\4 The inventories collect wetlands data through a combination of
aerial photography and on-site field verification. 

\5 Although the use of statistical sampling techniques introduces
uncertainty into the estimates, the use of sampling techniques is a
cost-effective way of developing these estimates. 


      AGENCIES' ACCOMPLISHMENTS
      CANNOT BE DETERMINED
---------------------------------------------------------- Letter :4.2

The agencies use such terms as protection, restoration,
rehabilitation, improvement, enhancement, and creation in describing
and reporting their wetlands-related activities and the resulting
accomplishments.  However, federal agencies are not consistent in the
use of these terms.  Even when the same terms are used, the agencies
do not define them in the same way.  For example, depending upon the
agency, the term "restoration" has different meanings and different
results.  At Interior's FWS, restoration is considered the
reestablishment of a degraded wetland to its former state and
therefore generally would not result in a net gain of wetlands acres. 
At Agriculture's NRCS, restoration is considered to be the
reestablishment of a wetland where it previously existed and would
result in a gain of wetlands acres. 

The agencies also often include nonwetlands acreage when reporting
their accomplishments.  Nonwetlands acreage, such as adjacent
uplands, are often included in wetlands project totals but are not
identified or listed separately.  For example, the NRCS' Wetlands
Reserve Program, which acquires wetlands easements from landowners
and shares in the cost of restoration, might report that a wetlands
restoration project restored a total of 25 acres.  However, the 25
acres reported might include not only 10 acres of former wetlands
that were restored but also 10 acres of existing degraded wetlands
whose functions were enhanced and 5 acres of adjacent uplands.  The
FWS' North American Wetlands Conservation Program also includes
nonwetlands acreage in its project totals.  Program officials
estimate that about 75 percent of the acreage reported by habitat
restoration projects are uplands. 

Adding to these reporting problems is the double counting of
accomplishments.  Federal and state agencies and private conservation
organizations are often involved in joint projects.  When each
reports the accomplishments resulting from these joint projects, the
actual accomplishment is overstated.  For example, the total number
of wetlands acres that FWS' North American Waterfowl Management Plan
reports as restored includes the results of activities that involve
FWS and other federal agencies, such as the Forest Service and the
NRCS, and other state and private conservation organizations.  These
agencies would also report the acreage restored as the result of
these joint projects. 


      PAST EFFORTS HAVE NOT SOLVED
      WETLANDS DATA PROBLEMS, BUT
      NEW EFFORTS ARE UNDER WAY
---------------------------------------------------------- Letter :4.3

Since 1989, at least five interagency groups, established to better
coordinate federal wetlands programs, have attempted to improve
wetlands data.  These task forces and the purposes for which they
were established are described below. 

Inter-Agency Task Force on Wetlands.  On May 23, 1989, the White
House established an Inter-Agency Task Force on Wetlands under the
Domestic Policy Council's Working Group on Environment, Energy, and
Natural Resources to examine ways to achieve no net loss of wetlands
as a national goal.  The task force's objectives included (1)
providing clear direction to federal agencies for strengthening,
implementing, and enforcing wetlands protection, maintenance, and
restoration; (2) coordinating agencies' involvement in achieving the
no net loss goal; and (3) assessing implementation of the no net loss
goal by federal, state, and local governments to determine what
further steps might be necessary. 

Wetland Inventory Subgroup of the Domestic Policy Council 's
Interagency Wetlands Task Force.  The Domestic Policy Council's
Interagency Wetlands Task Force established a Wetland Inventory
Subgroup in October 1990.  Three agencies--Interior's FWS;
Agriculture's then-Soil Conservation Service, and Commerce's National
Oceanic and Atmospheric Administration--agreed to cochair the Wetland
Inventory Subgroup.  The subgroup was charged to evaluate existing
inventory programs as well as propose potential improvements. 

Interagency Federal Lands Wetlands Restoration and Creation
Committee.  As a result of President Bush's comprehensive plan for
improving the protection of the nation's wetlands, in August 1991 the
Interagency Federal Lands Wetlands Restoration and Creation Committee
was established.  This committee was charged with coordinating
federal restoration and creation projects and with establishing
criteria and recommendations for redirecting agencies' future
spending in restoring and creating wetlands. 

Wetlands Ad Hoc Integration Working Group of the Federal Geographic
Data Committee's Wetlands Subcommittee.\6 The Wetlands Ad Hoc
Integration Working Group was established in June 1992 at the request
of the White House's Domestic Policy Council to attempt to integrate
and reconcile the National Wetlands Inventory's Status and Trends and
the National Resources Inventory's reports on the amount of wetlands
lost and remaining. 

Interagency Working Group on Federal Wetlands Policy (White House
Wetlands Working Group).  In June 1993, this working group was formed
to address concerns about federal wetlands policy.  The working group
established five principles for federal wetlands policy that served
as the framework for the development of the administration's package
of wetlands reform initiatives.  The principles included (1) support
for the interim goal of no overall net loss of the nation's remaining
wetlands and the long-term goal of increasing the quality and
quantity of the nation's wetlands, (2) reduction of the federal
government's reliance on the regulatory program as the primary means
to protect wetlands resources and accomplish long-term wetlands gains
by emphasizing nonregulatory programs, and (3) basing federal
wetlands policy on the best scientific information available. 

With the exception of the last one, these working groups have been
disbanded.  However, because either the members of these interagency
groups could not agree on the actions needed or the adoption of their
recommendations was left to the individual agencies, the problems
with the consistency and reliability of wetlands acreage data
persist. 

Recognizing that these problems still exist, the administration
recently announced new plans to improve wetlands data.  In October
1997, the Wetlands Subcommittee of the Federal Geographic Data
Committee decided to develop consistent definitions for wetlands
gains, losses, and modifications for use by all federal agencies.  In
addition, the Wetlands Subcommittee proposed the development of a
reporting system that would standardize reporting procedures and
provide for a mechanism to collect and compile data on the agencies'
accomplishments.  Additional efforts to improve wetlands data were
included in the administration's Clean Water Action Plan, issued on
February 19, 1998.  These actions include the following: 

  -- Complete a plan to use existing inventory and data collection
     systems to support a single status and trends report by the year
     2000 and convene a peer review panel to evaluate, by June 1998,
     a plan to track annual changes in the nation's wetlands of less
     than 100,000 acres. 

  -- Issue technical guidance, by October 1999, on the restoration,
     enhancement, and creation of wetlands functions. 

  -- Establish an interagency tracking system, by October 1999, that
     will more accurately account for wetlands losses, restoration,
     creation, and enhancement.  This system will also establish
     accurate baseline data for federal programs that contribute to
     net wetlands gains. 

The administration's efforts to implement the actions contained in
the Clean Water Action Plan are under way.  In May 1998, the
Interagency Wetlands Working Group issued an action plan developed to
guide its efforts to produce a single wetlands status and trends
report in the year 2000.  However, much remains to be done before
such a report can be produced.  Many of these actions outlined in the
plan will not occur for more than a year and are dependent upon the
successful completion of other steps contained in the plan.  For
example, the plan calls for a three-stage quality assurance process
to be developed to ensure that the National Resources Inventory's
l997 data meet FWS' standards and needs for the year-2000 status and
trends report to the Congress.  Stage 3, which involves the review
and analysis of preliminary estimates, is not scheduled to be
completed until April 1999 and is dependent upon the successful
completion of stages 1 and 2.  In addition, a long-term commitment
and considerable time and effort from the agencies involved will be
required to successfully implement the plan.  (A copy of this plan
can be found in app.  VII.)

Details of the administration's plans to accomplish the other
actions, such as establishing an interagency tracking system and
issuing technical guidance on the restoration, enhancement, and
creation of wetlands functions, have not yet been drafted.  However,
according to the Chairman of the Interagency Wetlands Working Group,
the actions planned by the Wetlands Subcommittee to develop
consistent definitions and reporting standards for use in reporting
the wetlands-related accomplishments of federal agencies will be
folded into the administration's efforts. 


--------------------
\6 The Wetlands Subcommittee of the Federal Geographic Data Committee
was established in January 1992 to ensure the consistency of wetlands
data.  Chaired by the Department of the Interior, the subcommittee is
composed of representatives of all federal agencies involved in
wetlands mapping. 


   CONCLUSIONS
------------------------------------------------------------ Letter :5

Over $500 million each year is associated with the efforts of federal
agencies to protect and restore wetlands.  However, the consistency
and reliability of the estimates made of the nation's remaining
wetlands acreage and the data reported by the agencies on their
accomplishments are questionable.  Despite the efforts of five
interagency task forces established since 1989 to resolve them, these
problems persist.  As a result, the progress made toward achieving
the goal of no net loss of the nation's remaining wetlands, the
administration's new goal of gaining 100,000 acres of wetlands each
year beginning in the year 2005, or the contributions made by the
agencies in achieving these goals cannot be measured. 

In its recently issued Clean Water Action Plan, the administration
announced new efforts to improve the wetlands acreage data reported
by federal agencies.  Although a plan has been developed to
accomplish one of the actions--producing a single wetlands status and
trends report--much remains to be done before such a report can be
issued.  Many of the steps outlined in the plan are not scheduled to
occur for more than a year and are dependent on the successful
completion of other steps contained in the plan.  Furthermore, a
long-term commitment and considerable time and effort from the
agencies are crucial to the successful implementation of this effort. 
In addition, details of how the other actions announced by the
administration will be achieved have not been developed.  Unless
strategies are developed and implemented for all of the
wetlands-related actions contained in the administration's Clean
Water Action Plan, the latest attempts to improve wetlands data will
likely be no more successful than previous ones.  Without consistent
and reliable wetlands acreage data, decisionmakers (the Congress and
the administration) will be hampered in their ability to make sound
decisions about necessary adjustments to federal wetlands policies
and programs that would allow the nation's wetlands goals to be
achieved. 


   RECOMMENDATION
------------------------------------------------------------ Letter :6

To ensure that the consistency and reliability of wetlands acreage
data are improved, we recommend that the Secretary of the Department
of Agriculture and the Secretary of the Department of the Interior,
in consultation with the Chairman of the White House's Interagency
Wetlands Working Group, develop and implement a strategy for ensuring
that all actions contained in the Clean Water Action Plan relating to
wetlands data are adopted governmentwide.  Such actions should
include, in addition to the ongoing effort to develop a single set of
accurate, reliable figures on the status and trends of the nation's
wetlands, the development of consistent, understandable definitions
and reporting standards that are used by all federal agencies in
reporting their wetlands-related activities and the changes to
wetlands that result from such activities. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :7

We provided a draft of this report to the Army Corps of Engineers;
the departments of Agriculture, Commerce, and the Interior; EPA; and
the Chair of the Interagency Wetlands Working Group for review and
comment.  The Interagency Wetlands Working Group consolidated the
comments of the principal agencies involved in wetlands, except for
Commerce, and included the agencies' input to the working group in
its response.  The agencies commented on a variety of issues.  For
example, the Working Group and EPA expressed concern that our report
did not adequately clarify the level and nature of the involvement of
federal agencies in wetlands-related activities.  In addition, the
Working Group and EPA believe that we emphasized the differences in
the wetlands acreage estimates produced by FWS and NRCS without
adequately noting that both inventories generally agree that the rate
of wetlands losses has declined and that efforts are under way to
reconcile the differences. 

We believe that our report accurately characterizes both the level
and nature of the involvement of federal agencies in wetlands-related
activities and the differences in the estimates produced by the two
inventories.  We point out in the report that while 36 federal
agencies are involved in wetlands-related activities, 6 of these
agencies account for the majority of funding and staffing associated
with such activities.  We have added a statement to the report to
further clarify the roles of the various federal agencies in
wetlands-related activities.  In addition, while we report that the
wetlands acreage estimates produced by FWS and NRCS are not
completely consistent, we also acknowledge that both have reported
that the rate of wetlands losses has declined.  Furthermore, we have
included a discussion of the efforts recently undertaken by the
Interagency Wetlands Working Group to produce a single wetlands
status and trends report. 

With the exception of the Department of the Interior, which agreed
with our recommendation, neither the Working Group nor the other
principal agencies specifically commented on our recommendation. 

The Chair of the Working Group enclosed a copy of the action plan
recently developed by the group to guide its efforts to produce a
single status and trends report.  We revised our report to include a
discussion of the Working Group's plan.  This plan, which appears in
appendix VII, was referred to by several agencies in their individual
comments. 

A more complete discussion of the comments provided by the Working
Group and the agencies and our evaluation of their comments are
contained in appendixes IV, V, and VI. 


---------------------------------------------------------- Letter :7.1

We performed our work from July 1997 through June 1998 in accordance
with generally accepted government auditing standards.  A complete
discussion of our objectives, scope, and methodology appears in
appendix VIII. 

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 15 days after the date of this letter.  At that time, we will
send copies to the Secretaries of Agriculture, Commerce, Defense, and
the Interior; the Administrator of the Environmental Protection
Agency; the Chair of the Interagency Wetlands Working Group; and
other interested parties.  We will also make copies available to
others upon request. 

Please call me at (202) 512-3841 if you or your staff have any
questions about this report.  Major contributors to this report are
listed in appendix IX. 

Sincerely yours,

Barry T.  Hill
Associate Director, Energy,
 Resources, and Science Issues


WETLANDS-RELATED PRESIDENTIAL
EXECUTIVE ORDERS AND LAWS
=========================================================== Appendix I


   EXECUTIVE ORDERS
--------------------------------------------------------- Appendix I:1

Executive Order 11990, Protection of Wetlands, May 24, 1977. 
Executive Order 11990, as amended, directs each federal agency to
take action to minimize the destruction of wetlands and to preserve
and enhance the benefits of wetlands in carrying out certain
responsibilities.  These responsibilities include (1) acquiring,
managing, and disposing of federal lands and facilities; (2)
providing federally financed or assisted construction; and (3)
conducting federal activities and programs affecting land use,
including water and related land resources planning, regulating, and
licensing activities.  Each agency shall also, to the extent
permitted by law, avoid undertaking or providing assistance for new
construction located in wetlands unless (1) there is no practical
alternative and (2) all practical measures to minimize harm to
wetlands are included. 

Executive Order 11988, Floodplain Management, May 24, 1977. 
Executive Order 11988, as amended, directs each federal agency to
take action to reduce the risk of flood loss, to minimize the impact
of floods on human safety, health, and welfare, and to restore and
preserve the natural and beneficial values served by floodplains in
carrying out certain responsibilities.  These responsibilities
include (1) acquiring, managing, and disposing of federal lands and
facilities; (2) providing federally financed or assisted
construction; and (3) conducting federal activities and programs
affecting land use including water and related land resources
planning, regulating, and license activities.  Each federal agency
must evaluate the potential effects of any actions it may take in a
floodplain.  If an agency proposes to conduct, support, or allow an
action in a floodplain, it shall consider alternatives to avoid
adverse effects and incompatible development in the floodplains. 


   LAWS
--------------------------------------------------------- Appendix I:2

The Coastal Barriers Resources Act (16 U.S.C.  3501 et seq.).  The
Coastal Barriers Resources Act, as amended by the Coastal Barrier
Improvement Act, prohibits most new federal expenditures and
financial assistance for development of coastal barriers, included in
the Coastal Barrier Resources System, a major portion of which is
wetlands.  The purpose of the act is to minimize the loss of human
life, wasteful expenditure of federal revenues, and damage to fish,
wildlife, and other natural resources associated with the development
of coastal barriers. 

The Coastal Wetlands Planning, Protection and Restoration Act (16
U.S.C.  3951 et seq.).  This 1990 act authorizes spending for coastal
wetlands conservation and restoration projects and designated 18
percent of the total amount in the Sport Fish Restoration Account for
these projects.  The act created a task force, composed of the
Secretary of the Army, the Administrator of the Environmental
Protection Agency, the Governor of Louisiana, and the Secretaries of
Agriculture, Commerce, and the Interior, to develop a comprehensive
approach for protecting and restoring coastal wetlands in Louisiana. 
Seventy percent of the revenues go to restoring Louisiana's coastal
wetlands. 

The act also contains a provision for the remaining 30 percent of the
revenues.  The act created two coastal wetlands cost-sharing programs
open to all states.  Fifteen percent is for the National Coastal
Wetlands Conservation Grant Program for coastal habitat projects in
all coastal states, except Louisiana.  The remaining 15 percent is
for coastal-only North American Waterfowl Management Plan projects
that are approved under the North American Wetlands Conservation Act
Grant program.  These two programs are administered by FWS. 

The Coastal Zone Act Reauthorization Amendments of 1990 (16 U.S.C. 
1451 et seq.).  Under the Coastal Zone Act Reauthorization Amendments
of 1990 (subtitle C of the Omnibus Budget Reconciliation Act of
1990), the Secretary of Commerce sets guidelines and provides funding
for states to carry out coastal zone management programs.  The term
"coastal zone" includes wetlands.  For states without a coastal zone
management program, the act provides funding to develop such a
program.  It also provides coastal zone enhancement grants to coastal
states to improve (1) coastal wetlands protection, (2) natural
hazards management, (3) public beach access, (4) marine debris
management, (5) assessments of coastal growth and development, and
(6) environmentally sound siting of coastal energy facilities.  The
act amended the Coastal Zone Management Act of 1972. 

The Emergency Wetlands Resources Act of 1986 (16 U.S.C.  3901 et
seq.).  This act promotes the conservation of wetlands in order to
maintain the public benefits they provide.  The purpose is to
intensify cooperation and acquisition efforts among private interest
and local, state, and federal governments for the protection,
management, and conservation of wetlands.  The act authorized the
acquisition of wetlands consistent with a National Wetlands Priority
Conservation Plan.  It also (1) contains options for generating
revenues to acquire and protect wetlands, (2) requires that statewide
comprehensive outdoor recreation plans specifically address wetlands,
(3) directs the completion of the map inventory of the nation's
wetlands and the production, by September 30, 2004, of a digital
wetlands database, and (4) requires a study of the impacts of federal
programs on wetlands.  The act raised the price of duck stamps,
required entrance fees at selected units of the national wildlife
refuge system, and required that an amount equal to the annual duties
on imported firearms and ammunition be paid into the Migratory Bird
Conservation Fund.  The act requires FWS to complete its wetlands
inventory mapping of the contiguous United States by 1998. 

The Endangered Species Act (16 U.S.C.  1531 et seq.).  This act
prohibits any federal agency from undertaking or funding a project
that will threaten a rare or endangered species.  Some wetlands
development is restricted by this statute.  The act can be used to
prevent alterations of wetlands necessary to maintain a species'
critical habitat-- i.e., the geographical area that has the physical
or biological features essential to conserve the species and that may
require special management consideration or protection. 

The Everglades National Park Protection and Expansion Act of 1989 (16
U.S.C.  410r-5 et seq.).  This act provides for the acquisition of
107,600 acres to be added to Everglades National Park in southern
Florida and provides for an increase in the water flow to the park to
help restore and protect its water-dependent ecosystem.  The
additional acres would expand the size of the park to 1.5 million
acres. 

The Federal Agricultural Improvement and Reform Act of 1996 (1996
Farm Bill).  Established by section 334 of the 1996 Farm Bill, the
Environmental Quality Incentives Program (EQIP) (58 U.S.C.  3839aa et
seq.) combines four Department of Agriculture conservation programs: 
the Agricultural Conservation Program, the Water Quality Incentives
Program, the Great Plains Conservation Program, and the Colorado
River Basin Salinity Program.  EQIP offers farmers and ranchers
5-year to-10-year contracts that may make up to 100 percent incentive
payments and provide up to 75 percent cost-sharing for conservation
practices to combat serious threats to soil, water, and related
natural resources, including wetlands.  The Congress authorized $200
million annually for EQIP through fiscal year 2002 to be paid by the
Commodity Credit Corporation. 

The Federal Aid to Wildlife Restoration Act of 1937 (16 U.S.C.  669
et seq.).  The purpose of this act is to provide assistance to the
states and territories in carrying out projects to restore, enhance,
and manage wildlife resources and habitat. 

The Federal Water Pollution Control Act ("Clean Water Act").  Section
404 of the Clean Water Act (33 U.S.C.  1344) provides the principal
federal authority to regulate the discharge of dredged and fill
material to waters of the United States, including wetlands.  Under
section 404, landowners and developers must obtain permits to carry
out dredging and fill activities in navigable waters, which include
wetlands.  This act specifically exempts certain activities--normal
agriculture, silviculture (forestry), and ranching--provided they do
not convert areas of U.S.  waters to uses to which they were not
previously subject and do not impair the flow or circulation of such
waters or reduce their reach. 

Section 402 (33 U.S.C.  1342) authorizes a national system for
regulating sources of water pollution, which can affect wetlands,
either by the Environmental Protection Agency or through approved
state programs.  The Clean Water Act prohibits pollution discharges
without a permit.  Pollutant discharges are allowed subject to
statutory restrictions under this section. 

The Fish and Wildlife Act of 1956 (16 U.S.C.  742 et seq.).  This act
established the Fish and Wildlife Service and authorized the
Secretary of the Interior to take such steps as required for the
development, advancement, management, conservation, and protection of
fish and wildlife resources.  Such authority can be used to protect
wetlands vital to many fish and wildlife species. 

The Fish and Wildlife Coordination Act (16 U.S.C.  661 et seq.). 
This act requires that wildlife conservation be given consideration
equal to that given other purposes of water resources development
projects constructed by federal agencies.  This act empowers FWS and
the Department of Commerce's National Marine Fisheries Service to
evaluate the impact on fish and wildlife of all new federal projects
and federally permitted projects, including projects granted under
section 404 of the Clean Water Act. 

The Food, Agriculture, Conservation, and Trade Act of 1990 (1990 Farm
Bill).  Established by the 1990 Farm Bill, the Wetlands Reserve
Program (WRP) (16 U.S.C.  3837 et seq.) is a voluntary program to
restore and protect wetlands.  Under WRP, farmers can apply to enroll
prior converted wetlands, degraded wetlands, and buffer areas under
permanent easement.  Landowners are paid up to the agricultural value
of the land for granting the government a permanent easement or 75
percent of this value for 30-year easements.  They may also receive a
large part of the costs to carry out conservation measures and to
protect wetlands functions on lands subject to an easement. 

The 1990 Farm Bill established the Farmers Home Administration's
Conservation Easement Program (7 U.S.C.  1985), under which lands
that either have reverted or may revert to the Department of
Agriculture's Farmers Home Administration can be preserved or
restored, for example, wetlands.  The Secretary of Agriculture may
grant or transfer easements on land obtained from farm foreclosures
or voluntary conveyance to federal or state agencies. 

The Prohibition on Loans to Fill Wetlands (7 U.S.C.  2006(e))
provision of the 1990 Farm Bill prohibits the Secretary of
Agriculture from approving any loan to drain, fill, level, or
otherwise manipulate a wetland. 

The Food Security Act of 1985 (1985 Farm Bill).  Section 404 of the
Clean Water Act does not regulate activities such as drainage,
ditching, and channelization for agricultural production, which are
major causes of past losses of wetlands.  To fill this gap in
coverage, the Food Security Act of 1985 was authorized to reduce the
amount of wetland conversion directly related to agricultural
production and included two major wetlands-related provisions, the
Swampbuster and the Conservation Reserve Program. 

The Swampbuster Provision (16 U.S.C.  3821 et seq.) denies federal
farm program benefits to farmers who produce a commodity crop on a
converted wetlands.  Wetlands which were converted for agricultural
purposes prior to the passage of this act are exempt from this
provision.  Landowners who want to convert wetlands may offset losses
of wetlands through mitigation efforts, including enhancing,
restoring or creating wetlands.  Farmers can regain federal benefits
if they restore converted wetlands.  The Secretary of Agriculture has
discretion to determine for which program benefits violators are
ineligible and to provide good faith exemptions. 

The Conservation Reserve Program (16 U.S.C.  3831 et seq.) is a
voluntary program offering annual rental payments to farmers to
protect highly erodible and environmentally sensitive lands,
including wetlands, with grass, trees, and other long-term cover. 
The 1996 Farm Bill extended the program until fiscal year 2002,
capped overall enrollment at 36.4 million acres, and provided funding
through the Commodity Credit Corporation.  Annual rental payments are
based on the agricultural rental value of the land and can cover up
to 50 percent of a participant's costs.  Participants may also
receive an additional 25 percent of their costs for the restoration
of wetlands. 

The 1990 and 1996 Farm Bills modified these programs. 

The Great Lakes Fish and Wildlife Restoration Act of 1990 (16 U.S.C. 
941 et seq.).  Concerned about the damage done to the Great Lakes
Basin and its fish and wildlife resources, including the loss of 80
percent of the wetlands in the basin, the Congress passed legislation
to address this problem.  The Great Lakes Fish and Wildlife
Restoration Act directs the Director of the Fish and Wildlife Service
to seek to achieve several goals in administering the agency's
programs.  One of these goals is protecting, maintaining, and
restoring fish and wildlife habitat, including the enhancement and
creation of wetlands. 

Sections 1006(d) and 1007(a) Intermodal Surface Transportation
Efficiency Act of 1991 (33 U.S.C.  103 (i)(11) and 133 (b)(11)).  The
Intermodal Surface Transportation Efficiency Act of 1991 provides
that federal funds apportioned to a state for the National Highway
System and the surface transportation program may be used for
wetlands mitigation efforts related to projects funded under these
programs.  These mitigation efforts may include participation in
wetlands mitigation banks, contributions to statewide and regional
efforts to restore, conserve, enhance and create wetlands, and the
development of statewide and regional wetlands conservation and
mitigation plans.  Contributions toward these efforts, subject to
certain conditions, may take place before a project is constructed. 

The Land and Water Conservation Act of 1965 (16 U.S.C.  460l et
seq.).  This act supports the purchase of natural areas, including
wetlands, at federal and state levels.  The Emergency Wetlands
Resources Act of 1986 amended the Land and Water Conservation Act to
(1) permit the funds to be used to acquire wetlands and (2) require
the states to include the acquisition of wetlands as part of their
comprehensive outdoor recreation plans. 

The Magnuson-Stevens Act (16 U.S.C.  1801 et seq.).  Amended on
October 11, 1996 by the Sustainable Fisheries Act, the
Magnuson-Stevens Act calls for direct action to stop or reverse the
continued loss of fish habitat.  The act requires cooperation among
the National Marine Fisheries Service, eight Regional Fishery
Management Councils, fishing participants, federal and state
agencies, and others in achieving the essential habitat goals of
habitat protection, conservation and enhancement. 

The Migratory Bird Conservation Act (16 U.S.C.  715 et seq.).  This
act established a Migratory Bird Conservation Commission to approve
areas recommended by the Secretary of the Interior for acquisition
with Migratory Bird Conservation Funds.  The Commission also approves
wetlands conservation projects recommended by the North American
Wetlands Conservation Council under the North American Wetlands
Conservation Act. 

The Migratory Bird Hunting and Conservation Stamp Act (16 U.S.C.  718
et seq.).  Passed in 1934, this act requires waterfowl hunters aged
16 and older to purchase "duck stamps," the proceeds of which are
deposited into the Migratory Bird Conservation Fund to be used to
acquire small wetland and pothole areas and rights-of-way providing
access to such areas. 

The National Environmental Policy Act of 1969 (42 U.S.C.  4321 et
seq.).  This act provides that environmental impact statements be
prepared for major federal actions.  The statements must include
assessments of the environmental impacts of proposed actions, any
adverse environmental effects that cannot be avoided should the
proposals be implemented, and alternatives to the proposed actions. 
Assessments under this act have been applied to major federal actions
affecting wetlands. 

The National Flood Insurance Act of 1968 (42 U.S.C.  4001 et seq.). 
This act requires communities to develop federally approved
floodplain management programs.  Administered by the Federal
Emergency Management Agency, the act provides subsidized flood
insurance to property owners in communities with approved programs. 
Communities that do not adopt an approved program to regulate future
floodplain uses are ineligible for most federal financial assistance,
including federal disaster assistance in case of flood.  Property
owners whose land is in a floodplain cannot get federally guaranteed
mortgages, loans, or other forms of financial assistance unless the
property is covered by flood insurance.  In general, the programs
apply to structures in floodplains.  Although not the act's primary
focus, wetlands development is covered in the programs, since nearly
all coastal and most inland wetlands occur in floodplains. 

The National Wildlife Refuge System Administration Act of 1966 (16
U.S.C.  668dd et seq.).  This act established a National Wildlife
Refuge System by combining former "wildlife refuges, areas for the
protection and conservation of fish and wildlife threatened with
extinction, wildlife ranges, game ranges, wildlife management areas,
and waterfowl production areas" into a single refuge system.  The
system currently includes 513 national wildlife refuges.  FWS
estimates that about 33 percent is wetlands. 

The North American Wetlands Conservation Act of 1989 (16 U.S.C.  4401
et seq.).  The act encourages voluntary public-private partnerships
to conserve North American wetlands ecosystems and wetland-dependent
migratory birds in support of the North American Waterfowl Management
Plan in an effort to increase waterfowl populations.  The act
authorizes the Congress to appropriate up to $30 million annually for
its implementation.  The act is financed, in part, by funds received
from the investment of unobligated Federal Aid to Wildlife
Restoration Act funds, which are derived from excise taxes on
ammunition and sporting arms, handguns, and certain archery
equipment, as well as fines, penalties, and forfeitures associated
with Migratory Bird Treaty Act violations.  Between 50 and 70 percent
of the available funds are to be spent on wetlands conservation
projects in Canada and Mexico; the remaining funds are to be spent on
projects in the United States.  Projects are recommended to the
Migratory Bird Conservation Commission for funding, and costs are
shared with state and private organizations working toward the goal
of wetlands preservation. 

The Resources Conservation and Recovery Act of 1976 (42 U.S.C.  1342
et seq.).  This act, which is administered by the Environmental
Protection Agency, controls the disposal of hazardous waste and could
reduce the threat of chemical contamination of wetlands. 

The Rivers and Harbors Act of 1899 (33 U.S.C.  403).  Section 10 of
this act requires that permits be obtained from the Army Corps of
Engineers for dredge, fill, and other activities that could obstruct
navigable waterways, which can include wetlands. 

The Water Bank Act (16 U.S.C.  1301 et seq.).  Passed in 1970, this
act authorized the Water Bank Program to provide funds to purchase
10-year easements on wetlands and adjacent areas.  The act's
objectives were to preserve, restore, and improve the wetlands of the
nation and thereby (1) conserve surface waters, (2) preserve and
improve migratory waterfowl and other wildlife resources, (3) reduce
runoff and soil and wind erosion, (4) contribute to flood control,
(5) contribute to improved water quality and reduced stream
sedimentation, (6) contribute to improved subsurface moisture, (7)
reduce the number of new acres coming into production and retire
lands now in production, (8) enhance the natural beauty of the
landscape, and (9) promote comprehensive and total water management
planning.  Under the act, private landowners or operators enter into
agreements with the federal government in which they promise not to
drain, fill, level, burn, or otherwise destroy wetlands and to
maintain ground cover essential for the resting, breeding, or feeding
of migratory birds.  In exchange, the landowners or operators receive
annual payments. 

The Watershed Protection and Flood Protection Act (16 U.S.C.  1003a). 
The Secretary of Agriculture may provide cost share assistance to
enable project sponsors, often local flood control districts, to
acquire perpetual wetland or floodplain conservation easements.  The
easements would perpetuate, restore, and enhance the natural capacity
of wetlands and floodplains to retain excessive floodwater, improve
water quality and quantity, and provide habitat for fish and
wildlife.  Project sponsors must provide up to 50 percent of the cost
for acquiring such easements. 

The Water Resources Development Act of 1986 (33 U.S.C.  2294). 
Section 1135 of this act authorized the Secretary of the Army to
review water resources projects constructed by the Corps to determine
the need for modifications that would improve the quality of the
environment.  Projects that address the degradation of the quality of
the environment caused by the Corps may also be undertaken. 
Nonfederal parties must agree to provide 25 percent of a project's
cost and usually 100 percent of the operation, maintenance,
replacement, and rehabilitation costs.  Up to 80 percent of the
nonfederal share may be provided as work-in-kind. 

The Water Resources Development Act of 1990 (33 U.S.C.  2317). 
Section 307 of this act includes, as part of the Army Corps of
Engineers' water resources development program, (1) an interim goal
of no overall net loss of the nation's remaining wetlands base and
(2) a long-term goal to increase the quality and quantity of the
nation's wetlands.  The act also requires the Secretary of the Army
to develop--in consultation with the Environmental Protection Agency,
the Department of the Interior's Fish and Wildlife Service, and other
appropriate agencies--a wetlands action plan to achieve the goal of
no net loss of remaining wetlands.  This action plan, to be completed
by November 28, 1991, was never published.  The act also authorized
the Secretary of the Army to establish and implement a demonstration
program for the purposes of determining and evaluating the technical
and scientific long-term feasibility of wetlands restoration,
enhancement, and creation as a means of contributing to these goals. 

The Water Resources Development Act of 1992 (33 U.S.C.  2326). 
Section 204 of the act authorized the Secretary of the Army to carry
out projects for the protection, restoration, and creation of aquatic
and ecologically related habitat, including wetlands, in connection
with dredging for a navigation project.  Nonfederal parties must
agree to provide 25 percent of a project's construction cost and pay
100 percent of the operation, maintenance, replacement, and
rehabilitation costs of the project. 

The Water Resources Development Act of 1996 (33 U.S.C.  2330). 
Section 206 of this act authorized the Secretary of the Army to carry
out aquatic ecosystem restoration projects that will improve the
quality of the environment, are in the public interest, and are
cost-effective.  Individual projects are limited to $5 million in
federal cost.  Nonfederal parties must contribute 35 percent of the
cost of construction and 100 percent of the cost of operation,
maintenance, replacement, and rehabilitation. 


PRINCIPAL WETLANDS-RELATED
PROGRAMS OR ACTIVITIES OF FEDERAL
AGENCIES
========================================================== Appendix II

At least 36 federal agencies are, to varying degrees, involved in
wetlands-related activities.  This appendix briefly describes some of
the principal wetlands-related programs or activities of these
agencies. 


   DEPARTMENT OF AGRICULTURE
-------------------------------------------------------- Appendix II:1

The Department of Agriculture (USDA) has a number of programs
designed to promote wetlands protection.  Some of these, such as the
"Swampbuster" provision and the Conservation Reserve Program were
included in the 1985 Farm Bill and later modified in the 1990 and
1996 Farm Bills.  The Wetlands Reserve Program, also included in the
1990 Farm Bill, represents one of Agriculture's major programs to
restore wetlands.  These incentive-based conservation programs were
established to restore and protect wetlands and to minimize the
detrimental impacts to those wetlands already converted.  Although
other Agriculture agencies are also involved in wetlands-related
activities, the Natural Resources Conservation Service and the Farm
Service Agency are primarily responsible for administering the
Department's wetlands programs. 


      NATURAL RESOURCES
      CONSERVATION SERVICE
------------------------------------------------------ Appendix II:1.1

The mission of the Natural Resources Conservation Service (NRCS),
formerly the Soil Conservation Service, is to assist in the
conservation, development, and productive use of the nation's soil,
water, and related resources.  NRCS provides technical and financial
assistance to landowners to achieve conservation objectives; this
assistance includes the restoration and enhancement of wetlands. 
NRCS is responsible for delineating wetlands to implement the 1985
Farm Bill (Swampbuster); the 1990 Food, Agriculture, Conservation,
and Trade Act; and the 1996 Farm Bill.  In addition, it administers
the Wetlands Reserve Program, the Water Bank Program, and the
National Resources Inventory. 


         WETLANDS RESERVE PROGRAM
---------------------------------------------------- Appendix II:1.1.1

The Wetlands Reserve Program is a voluntary program to restore and
protect wetlands on private property.  Landowners have an opportunity
to receive financial incentives to enhance wetlands in exchange for
retiring marginal agricultural land.  A landowner voluntarily limits
future use of the land, yet retains private ownership.  The landowner
and NRCS develop a plan for the restoration and maintenance of the
wetlands.  According to agency officials, more than 600,000 acres had
been enrolled in the program as of April 15, 1998, at a cost of about
$500 million.  Although not more than 975,000 acres can be enrolled
in the program by the year 2000, the administration included a
proposal in its Clean Water Action Plan to expand the Wetlands
Reserve Program to allow the enrollment of up to 250,000 acres of
wetlands each year. 


         WATER BANK PROGRAM
---------------------------------------------------- Appendix II:1.1.2

The Water Bank Program was established by the Water Bank Act in 1970. 
This program provides funds to purchase 10-year easements on wetlands
and adjacent areas.  It provides annual rental payments to landowners
for preserving wetlands in important migratory waterfowl nesting,
breeding, or feeding areas.  The program focuses primarily on
contracts with landowners in several central and western flyway
states.  Over $80 million was spent on the program in fiscal years
1990 through 1997.  Although the last contract was awarded in 1995
and no new funding has been put into the program since then, a small
amount of funds becomes available each year because of landowners'
withdrawals.  These funds have been used to enroll a few new
easements in North Dakota during fiscal years 1996 and 1997.  Program
funding will expire in fiscal year 2005. 


         NATIONAL RESOURCES
         INVENTORY
---------------------------------------------------- Appendix II:1.1.3

The National Resources Inventory (NRI) is an inventory that
determines the conditions of land cover and use, soil erosion, prime
farmland, wetlands, and other natural resource characteristics on
nonfederal rural land in the United States.  Inventories have been
conducted at 5-year intervals by NRCS.  The program is currently
making the transition to an annualized inventory process.  The 1992
inventory covered some 800,000 sample sites representing the nation's
nonfederal land--some 75 percent of the nation's land area.  The
purpose of the NRI is to provide information that can be used for
effectively formulating policy and developing natural resource
conservation programs at the national and state levels. 


      FARM SERVICE AGENCY
------------------------------------------------------ Appendix II:1.2

The Farm Service Agency (FSA) manages the Conservation Reserve
Program.  The Conservation Reserve Program is a voluntary program
offering rental payments to farmers to protect highly erodible and
environmentally sensitive cropland.  Wetlands and land to be restored
to wetlands are enrolled through a competitive bid process in which
offers are evaluated on the basis of their relative environmental
benefits.  An estimated 692,000 acres of wetlands are currently
protected or have been restored by the program.  The Conservation
Reserve Program also protects a significant amount of upland acres
associated with wetlands.  The program provides an estimated $40
million each year for the protection of wetlands. 

In addition, the Farm Service Agency administers the Conservation
Reserve Enhancement Program under the Conservation Reserve Program. 
This program provides the opportunity to partner with state
governments to target the most environmentally critical areas. 

FSA also administers and enforces the Swampbuster provision of the
1985 Farm Bill.  FSA provides wetlands information to producers and
third parties, monitors compliance with regulations, responds to
public complaints and producers' appeals of FSA decisions, and deals
with violations of the regulations.  In each state, FSA's operations
are carried out in conjunction with a state committee appointed by
the Secretary of Agriculture.  In each of over 3,000 agricultural
counties throughout the United States, a county committee is
responsible for the local administration of FSA's operations. 


      FOREST SERVICE
------------------------------------------------------ Appendix II:1.3

The Forest Service administers over 191 million acres of land
containing an estimated 9.1 million acres of wetlands.  The majority
of these are in Alaska and in National Forests east of the
Mississippi.  The Forest Service is headed by a Chief who has six
deputies reporting to him.  Three of the six deputies have areas of
responsibilities that include wetlands program elements. 

The National Forest and Grasslands have an active wetlands
restoration program in wetlands assessment, restoration, and
compliance.  Many staff share these responsibilities:  Watershed and
Air Management; Wildlife, Fish and Rare Plants; and Range Management
are the most active in wetlands assessment and restoration.  The
Forest Service has recently joined in partnership with the Department
of the Interior's Bureau of Land Management in instituting an
assessment method called Proper Functioning Condition in the western
states to assess the condition of riparian (stream-side) areas and
wetlands. 

The Forest Service also provides USDA leadership for forestry on
nonfederal lands with an emphasis on management and protection of the
estimated 52 million acres of nonindustrial private forest lands,
including wetlands, in the contiguous United States.  The Forest
Service also works with other USDA agencies in implementing the
Wetlands Reserve Program. 

The Forest Service also has a program of research on forested
wetlands that emphasizes developing and testing management that
restores and maintains wetlands.  Riparian ecosystems and their
associated wetlands are studied in many parts of the country. 
Region-specific research focuses on southern coastal plain wetlands,
south-central bottomland hardwood swamps, northern peatlands in the
Great Lakes states, and wetlands in interior Alaska. 

Overall, the Forest Service employed 93 full-time-equivalent staff
for a total wetlands-related program cost of $16.5 million in fiscal
year 1997. 


      AGRICULTURAL RESEARCH
      SERVICE
------------------------------------------------------ Appendix II:1.4

The Agricultural Research Service (ARS) conducts research on the
cost-effective practices and environmental benefits associated with
maintaining and enhancing existing and constructed wetlands.  ARS
spent about $8.8 million (in 1997 constant dollars) and 20 scientific
years (similar to full-time-equivalent staff-years) from fiscal year
1990 through 1997 on wetlands-related research. 


      ECONOMIC RESEARCH SERVICE
------------------------------------------------------ Appendix II:1.5

The Economic Research Service (ERS) performs research and policy
analysis at the national level and identifies long-term trend
information.  ERS has studied wetlands-related issues since the
mid-1970s when a major conversion of wetlands to cropland occurred. 
Although ERS does not appropriate funds specifically for
wetlands-related research, an ERS official estimated that about 1.25
full-time-equivalent staff-years (about $120,000) are spent on
wetlands-related research each year. 


   DEPARTMENT OF COMMERCE
-------------------------------------------------------- Appendix II:2


      NATIONAL OCEANIC AND
      ATMOSPHERIC ADMINISTRATION
------------------------------------------------------ Appendix II:2.1

The National Oceanic and Atmospheric Administration's National Marine
Fisheries Service is responsible for protecting and conserving living
marine, estuarine, and anadromous fish resources and habitats.  In
addition to performing administrative, management, and regulatory
wetlands functions, the Service analyzes and comments on construction
proposals and applications for dredge and fill permits issued by the
Corps of Engineers.  It is also an active member along with the Army
Corps of Engineers, Department of Agriculture's Natural Resources
Conservation Service, Department of the Interior's Fish and Wildlife
Service, and the Environmental Protection Agency in projects funded
under the Coastal Wetlands Planning, Protection and Restoration Act
of 1990. 

Through its Damage Assessment and Restoration Program, the National
Oceanic and Atmospheric Administration uses monetary awards from
polluters and other responsible parties to "restore, replace, or
acquire the equivalent of" marine resources damaged by oil spills,
hazardous releases, or other human-induced environmental
disturbances.  To date, this program has initiated restoration
activities at over 25 sites around the country. 

The National Ocean Service, the Office of Oceanic and Atmospheric
Research, and National Environmental Satellite, Data, and Information
Service are also involved in wetlands-related activities. 
Wetlands-related responsibilities include implementing the Coastal
Zone Management Program, improving the health of the nation's
estuaries and coastal habitats, and performing coastal land and ocean
sensing mapping and monitoring.  For example, the National Ocean
Service's National Estuarine Research Reserve Program has placed
about 440,000 acres of estuarine waters, wetlands, and uplands into
active management and stewardship.  This is accomplished with the
cooperation of the coastal states and territories and of constituent
groups. 


   DEPARTMENT OF DEFENSE
-------------------------------------------------------- Appendix II:3


      DEPARTMENTS OF THE AIR
      FORCE, ARMY, AND NAVY
------------------------------------------------------ Appendix II:3.1

All three military services were involved in a variety of
wetlands-related activities in fiscal years 1990 through 1997. 
Although involved in restoration, creation/construction, research,
and other wetlands-related activities, enhancement, mapping,
inventorying, and delineation were the primary activities conducted
during this period. 


      U.S.  ARMY CORPS OF
      ENGINEERS
------------------------------------------------------ Appendix II:3.2

The U.S.  Army Corps of Engineers is the primary federal agency
responsible for regulating wetlands development under section 404 of
the Clean Water Act.  Section 404 authorizes the Corps to issue or
deny permits for the discharge of dredged or fill materials into U.S. 
waters.  Of the approximately 12,000 to 15,000 project-specific
permit applications the Corps evaluates each year, about 8,000 are
issued and 200 denied.  The remaining applications either qualify for
authorization under a general permit, are withdrawn by the applicant,
or are canceled by the Corps when the applicant fails to provide the
information required for a decision.  The Corps also verifies
authorization of approximately 75,000 minor activities each year
under the terms and conditions of regional and nationwide general
permits. 

Under the President's Wetlands Plan, issued in August 1993, the Corps
was to establish an administrative appeals program whereby the public
could appeal decisions of permit denials and jurisdiction
determinations.  The adoption of this program has been held up
because of funding limitations; however, a partial appeals program,
for denials, is expected to be in place in fiscal year 1999.  Without
such an appeals system, the public must resort to litigation to
challenge a regulatory decision by the Corps. 

Both the Corps and EPA have enforcement responsibilities under
section 404.  EPA has statutory enforcement authority to deal with
discharges of dredged or fill material where no permit has been
obtained.  The Corps has similar authority for dealing with
violations of permit conditions.  In January 1989, the Corps and EPA
entered into a memorandum of agreement that established the Corps as
the agency primarily responsible for initial investigations of
reported violations.  Both the Corps and EPA have authority to seek
civil or administrative remedies for unauthorized discharges in
wetlands.  In addition, the agencies can, under appropriate
circumstances, pursue criminal action in their enforcement cases. 
During fiscal year 1997, 6,300 unauthorized discharges were reported
to the Corps.  The Corps resolved 6,350 reported violations by
requiring restoration of the damage to wetlands or other actions. 
(Some of those were reported in fiscal year 1996.) Some violations
remained open at the end of fiscal year 1997.  In addition to the
unauthorized discharges, the Corps conducts compliance inspections of
about 7,000 permitted activities per year.  Almost 500 violations are
noted as a result of these inspections. 

The Corps is also involved in ecosystem restorations, many of which
address wetlands, riparian, and aquatic ecosystems.  The Corps'
restoration projects may be linked with modifications to the
operation or structure of existing projects.  Dredged material can
also be used to benefit aquatic ecosystems.  The Kissimmee River
project is one example of a major Corps effort to restore the
environmental value of an area.  The project will require over $247
million in federal funds and will enhance wetlands by establishing a
more natural timing and flow through the Kissimmee basin. 


         COASTAL WETLANDS
         PLANNING, PROTECTION AND
         RESTORATION ACT PROGRAM
---------------------------------------------------- Appendix II:3.2.1

Public Law 101-646 stresses the nation's concern for conserving and
restoring coastal wetlands.  Because Louisiana faces the most
alarming wetlands loss rates, the law's primary focus is on the
restoration and protection of those wetlands.  The law calls for a
Louisiana Coastal Wetlands Conservation and Restoration Task Force
made up of representatives from five federal agencies and the
Governor of Louisiana to develop a comprehensive plan for addressing
coastal Louisiana's severe wetlands loss problem.  Every year, this
task force approves and provides to the Congress priority lists of
projects.  Since 1991, this law has provided an average of over $38
million annually in federal funding for Louisiana restoration
projects. 


      OFFICE OF THE SECRETARY OF
      DEFENSE
------------------------------------------------------ Appendix II:3.3

In addition to the activities conducted by the military services, the
Strategic Environmental Research and Development Program funded a
study in 1993 to, among other things, identify installation
requirements relating to wetlands protection and management. 


   DEPARTMENT OF ENERGY
-------------------------------------------------------- Appendix II:4


      DEPARTMENT OF ENERGY PROGRAM
      OFFICES AND FACILITIES
------------------------------------------------------ Appendix II:4.1

A number of the Department of Energy's (DOE) programs were involved
in wetlands-related activities through field and operations offices,
national laboratories, and research facilities during fiscal years
1990 through 1997.\1 Although wetlands-related activities conducted
by these program offices and facilities ranged from complying with
regulations to education and public outreach, research and
restoration were the primary wetlands-related activities conducted. 
Over half the estimated $46 million (in 1997 constant dollars) spent
in fiscal years 1990 through 1997 were associated with these two
activities. 


--------------------
\1 Some of the DOE programs, offices, and facilities involved in
wetlands-related activities included the Environmental Restoration
Office, Defense Programs, Office of Energy Research, the Savannah
River Site, Rocky Flats Technology Center, Richland Operations
Office, Los Alamos National Laboratory, Lawrence Berkeley National
Laboratory, and Oak Ridge National Laboratory. 


      BONNEVILLE POWER
      ADMINISTRATION
------------------------------------------------------ Appendix II:4.2

Bonneville Power Administration (BPA), one of the five federal power
marketing agencies within DOE, supplies about half of the electricity
used in the Pacific Northwest.  Some of BPA's power projects affect
wetlands, and it has developed wetlands programs to protect,
mitigate, and enhance fish and wildlife.  BPA has spent about $10
million (in 1997 constant dollars) since 1990 on its wetlands-related
activities, primarily to acquire land for mitigation purposes. 


      FEDERAL ENERGY REGULATORY
      COMMISSION
------------------------------------------------------ Appendix II:4.3

The Federal Energy Regulatory Commission is an independent regulatory
agency within the DOE whose responsibilities include approving the
construction of natural gas pipelines; the rates for oil pipelines;
the licensing and inspection of private, municipal, and state
hydroelectric projects; and the overseeing of related environmental
matters.  The Commission's wetlands-related activities involved
reviewing proposed projects for environmental impacts, including
impacts to wetlands. 


      WESTERN AREA POWER
      ADMINISTRATION
------------------------------------------------------ Appendix II:4.4

Western Area Power Administration, a federal power marketing agency
within DOE, supplies hydroelectric power to over 600 wholesale power
customers.  Western Area Power's wetlands-related activities
consisted primarily of creating or constructing new wetlands as
mitigation for expansion projects that affected existing wetlands. 


   DEPARTMENT OF HOUSING AND URBAN
   DEVELOPMENT
-------------------------------------------------------- Appendix II:5

The Department of Housing and Urban Development has very little
involvement in wetlands-related activities.  However, in the few
cases in which its programs are used to assist housing and community
development for proposed projects that are located in wetlands, the
Department requires compliance with the National Environmental Policy
Act and Executive Order 11990.  The Department could not provide
information on the staffing and funding associated with these
activities. 


   DEPARTMENT OF THE INTERIOR
-------------------------------------------------------- Appendix II:6

The Department of the Interior has a number of programs addressing
various aspects of wetlands ranging from the protection, restoration
and enhancement efforts by the Fish and Wildlife Service to the
research efforts of the U.S.  Geological Survey. 


      U.S.  FISH AND WILDLIFE
      SERVICE
------------------------------------------------------ Appendix II:6.1

FWS is one of the primary agencies responsible for wetlands.  In
addition to reviewing section 404 permit applications and making
recommendations to the Corps of Engineers on whether to approve a
permit application and on any conditions that should be incorporated
into it, FWS is active in programs that protect, restore, and enhance
wetlands. 


         PARTNERS FOR FISH AND
         WILDLIFE PROGRAM
---------------------------------------------------- Appendix II:6.1.1

The Partners for Fish and Wildlife Program began in 1987, restoring
wetlands functions and values on private lands through voluntary
cooperative agreements.  Since then, the program has expanded to
include habitat restoration of other important wildlife habitat,
including native-grass prairie, riparian habitat, in-stream habitat,
and declining-species habitats.  The Partners for Fish and Wildlife
Program has entered into over 17,000 voluntary cooperative agreements
with private landowners for the purposes of restoring habitat.  The
program also provides technical assistance to other federal agencies
with conservation programs, primarily the Department of Agriculture. 
In fiscal years 1990 through 1997, the program received $123.4
million in funds.  To date, the Partners for Fish and Wildlife
Program has restored over

  -- 360,000 acres of wetlands,

  -- 128,000 acres of prairie grassland,

  -- 930 miles of riparian habitat, and

  -- 90 miles of in-stream aquatic habitat. 


         NORTH AMERICAN WATERFOWL
         MANAGEMENT PLAN
---------------------------------------------------- Appendix II:6.1.2

The North American Waterfowl Management Plan has the goal of
restoring continental waterfowl populations to numbers seen in the
1970s.  To do this, it joins the efforts of public agencies and
private conservation groups by applying the joint venture concept to
develop partnerships and matching grant funding arrangements to carry
out wetlands protection and restoration.  The initial plan was
created in 1986 involving Canada and the United States; it was
updated and expanded to include Mexico in 1994.  There are 11 habitat
joint ventures in the United States and 3 in Canada.  The plan calls
for 11.1 million acres of wetlands and associated uplands to be
protected and 14.7 million acres to be restored or enhanced.  Habitat
goals for each of the plan's joint ventures are identified in the
plan update.  Actual joint venture projects are funded individually
by the joint venture partners involved.  FWS receives some
appropriations for associated administrative efforts. 


         NORTH AMERICAN WETLANDS
         CONSERVATION ACT GRANT
         PROGRAM
---------------------------------------------------- Appendix II:6.1.3

The North American Wetlands Conservation Act Grant Program was
authorized by the North American Wetlands Conservation Act of 1989. 
The program encourages voluntary public-private partnerships to
conserve North American wetlands ecosystems.  Principal conservation
actions include the acquisition, creation, enhancement, and
restoration of wetlands and wetlands-associated habitat.  From fiscal
year 1991 through March 1998, 576 projects in the United States,
Canada, and Mexico, involving over 900 partners, have been approved
for funding.  Approximately 3.7 million acres of wetlands and
associated uplands have been acquired, restored, or enhanced in the
United States and Canada, while nearly 20 million acres have been
affected in large biosphere reserves through conservation education
and management plan projects in Mexico. 


         NATIONAL COASTAL WETLANDS
         CONSERVATION GRANT
         PROGRAM
---------------------------------------------------- Appendix II:6.1.4

National Coastal Wetlands Conservation Grants are authorized by the
Coastal Wetlands Planning, Protection and Restoration Act of 1990. 
The source of funding for the grant program is a portion of the
revenues deposited in the Sport Fish Restoration Account of the
Aquatic Resources Trust Fund.  Program eligibility extends to all
states bordering on the Atlantic, Gulf (except Louisiana), and
Pacific coasts, as well as states bordering the Great Lakes and U.S. 
territories, trust areas, and Puerto Rico.  The share of project
costs funded by the federal grant cannot exceed 50 percent, unless
the coastal state has established a trust fund or a fund derived from
a dedicated recurring source of moneys for the purpose of acquiring
coastal wetlands, other natural areas, or open spaces, in which case
the federal share may be increased to 75 percent.  Since 1992, the
program has protected almost 64,000 acres of wetlands and associated
uplands through acquisition and restoration. 


         NATIONAL WILDLIFE REFUGE
         SYSTEM
---------------------------------------------------- Appendix II:6.1.5

FWS administers the 92 million-acre National Wildlife Refuge System
for the benefit of fish, wildlife, and plants and their habitats. 
The Service estimates that about one-third of these acres are
wetlands, excluding tundra in Alaska.  The 513 national wildlife
refuges and 37 wetlands management districts, located in all 50
states, encompass a tremendous variety of wetland types providing
important habitat for migratory birds, anadromous fish, and species
threatened with extinction.  Refuge managers use water control
structures, moist soil management, prescribed burning, and other
techniques to restore, maintain, and enhance refuge wetland habitats. 


         NATIONAL WETLANDS
         INVENTORY
---------------------------------------------------- Appendix II:6.1.6

The National Wetlands Inventory (NWI) program began in 1978 and has
had two goals since its inception:  to produce (1) detailed maps for
the country and (2) comprehensive, statistically valid acreage
estimates of the nation's wetlands.  The Emergency Wetlands Resources
Act of 1986, as amended, required the Secretary of the Interior,
acting through the Fish and Wildlife Service, to complete maps for
the conterminous United States by September 30, 1998, and to update
the report on wetlands status and trends on a 10-year cycle.  To
date, three congressional reports have been generated by the status
and trends efforts. 


      NATIONAL PARK SERVICE
------------------------------------------------------ Appendix II:6.2

As the manager of more than 16 million acres of wetlands, the
National Park Service is a key participant in the preservation,
restoration, and management of wetlands habitats across the United
States.  Although many wetlands in National Park System units are in
essentially pristine condition, others have been damaged by drainage,
pollution, diking, and filling.  In 1991, the National Park Service
initiated a Service-wide program designed to enhance its wetlands
protection, restoration, inventory, applied research, and education
efforts.  This program is implemented through project funding and
technical assistance from the Service's Water Resources Division. 


      BUREAU OF LAND MANAGEMENT
------------------------------------------------------ Appendix II:6.3

The mission of the Bureau of Land Management is to sustain the
health, diversity, and productivity of the public land for the use
and enjoyment of present and future generations.  For
riparian-wetlands areas, this involves inventory/classification,
project development/maintenance, monitoring, protection/mitigation,
and acquisition/expansion of riparian-wetlands areas through Land and
Water Conservation Fund purchases and land exchanges.  Bureau of Land
Management field offices develop and carry out site-specific
management needs, proposals, and work plans for a variety of wetlands
projects, ranging from prescribed grazing management to protective
enclosures around small springs, to larger wetlands development
projects.  The Bureau is also engaged in several joint venture
partnerships that focus on regional wetlands protection and
development relative to the North American Waterfowl Management Plan. 


      BUREAU OF RECLAMATION
------------------------------------------------------ Appendix II:6.4

The Bureau of Reclamation's mission has evolved over the past 10
years from one focusing on the development of water resources and
civil works construction projects to one emphasizing water resources
management, protection, and development and maintenance and
enhancement of existing facilities.  The Bureau's wetlands activities
include compensatory mitigation required to address unavoidable
impacts caused by the construction and operation of projects. 
Compensatory mitigation may entail wetlands restoration, enhancement,
and/or development.  The Bureau also voluntarily participates with
cost-sharing partners in developing, restoring, and enhancing
wetlands to establish and improve wetlands functions and values
associated with its projects. 


      U.S.  GEOLOGICAL SURVEY
------------------------------------------------------ Appendix II:6.5

The U.S.  Geological Survey's wetlands-related activities are
predominately research and mapping; the agency does not directly
carry out restoration, protection or enhancement efforts.  Its
primary efforts are focused on obtaining an increased understanding
of the structure and function of wetlands, both as individual units
and components of large hydrologic systems.  In many cases, the
scientific information produced feeds directly into the wetlands
restoration and management activities of other agencies. 

Examples of research efforts include the following: 

  -- Inventorying and monitoring Louisiana's coastal wetlands.  The
     Survey documented wetlands loss through a time series of habitat
     maps and reports and provides spatial databases for planning and
     monitoring large-scale wetlands restoration projects of the
     Coastal Wetlands Planning, Protection and Restoration Act. 

  -- Science for the restoration of the south Florida, San Francisco
     Bay, and Chesapeake Bay ecosystems.  Most of the wetlands work
     of the Integrated Natural Resources Science Program (formerly
     Ecosystem Program) was conducted in south Florida.  The
     program's costs were $3.7 million, $7.4 million, and $7.3
     million for fiscal years 1995, 1996, and 1997 respectively. 


      BUREAU OF INDIAN AFFAIRS
------------------------------------------------------ Appendix II:6.6

The Bureau of Indian Affairs administers and manages approximately 52
million acres of land held in trust by the United States for Native
Americans.  Most Indian land is located in arid regions not known for
their wetlands values; however, approximately one million acres of
trust land contain wetlands that possess significant fish and
wildlife resources.  Approximately 400,000 acres of wetlands are
located on 18 Indian reservations in Minnesota, Michigan, and
Wisconsin.  Tribes in these three states, in conjunction with the
North American Waterfowl Management Plan, have developed a
consolidated set of wetlands management and development project
proposals for their reservations.  According to a Bureau official,
there is no other budget or program for addressing wetlands located
on reservations in other states.  Approximately 34,000 acres of
wetlands were restored, enhanced, created or constructed through
1997.  The Bureau has no staff funded for this work. 


      OFFICE OF SURFACE MINING
------------------------------------------------------ Appendix II:6.7

The Office of Surface Mining's mission is to carry out the
requirements of the Surface Mining Control and Reclamation Act of
1977, as amended, in cooperation with the states and tribes.  The
Office is responsible for ensuring that any wetlands that may be
affected by mining are addressed in the permitting process,
coordinated with the Corps of Engineers, and mitigated if necessary. 
Furthermore, the Corps' nationwide permits require the Office of
Surface Mining or the state regulatory authority to approve wetlands
mitigation plans prior to submission.  In addition, the abandoned
mine land program has encouraged the construction and enhancement of
wetlands as part of the Federal Reclamation Program and the abandoned
mine land program's state grant process.  In fiscal years 1990
through 1997, the Office spent a little over $1 million dollars on
wetlands-related activities. 


      MINERALS MANAGEMENT SERVICE
------------------------------------------------------ Appendix II:6.8

The Minerals Management Service manages the Outer Continental Shelf
oil and gas program.  The Service's responsibilities, as set forth in
the Outer Continental Shelf Act, include assessing the potential
impacts of oil and gas activities on the coastal environment,
including wetlands, and managing oil and gas activities to minimize
any impacts.  Most of the major wetlands studies sponsored by the
Service were funded prior to fiscal year 1990, although, in fiscal
years 1990 through 1997, approximately $507,000 was spent on wetlands
research in the Gulf of Mexico.  Furthermore, in fiscal year 1997,
the Service initiated a cooperative study of coastal wetlands impacts
related to pipeline canal widening rates with the Biological
Resources Division of the U.S.  Geological Survey.  The Minerals
Management Service funding of this 4-year study was $106,000. 


   DEPARTMENT OF JUSTICE
-------------------------------------------------------- Appendix II:7

Within the Department of Justice, lawyers in the Environment and
Natural Resources Division and the 94 United States Attorney Offices
handle all wetlands-related litigation, including affirmative and
defensive civil cases and prosecution of criminal violations.  This
work includes litigation to enforce the law when individuals and/or
companies fill wetlands without a permit, to defend legal challenges
to section 404 permits that have been issued by the government, and
to defend inverse condemnation cases filed against the government
because of permit decisions.  An Environment Division official
estimated that in fiscal years 1990 through 1997, its attorneys
addressed 1,010 cases at an expense of $19 million (in 1997 constant
dollars).  In fiscal years 1992 through 1997, the U.S.  Attorney
Offices addressed 67 section 404 cases. 


   DEPARTMENT OF STATE
-------------------------------------------------------- Appendix II:8

The Department of State supports the Ramsar Wetlands Convention
through voluntary contributions to (1) the Ramsar Bureau's core
budget, (2) Conference of Parties meetings, and (3) wetlands
projects.  The Convention on Wetlands, adopted in Ramsar, Iran, in
1971, is the only international accord dedicated to the protection of
wetlands.  The 106 nations that are parties to the Ramsar Convention
have designated over 900 wetlands sites of international importance
to promote their sustainable use and management.  The United States
contributes about 25 percent of the total Ramsar Bureau's budget. 

The Department of State also provides funding for the Wetlands for
the Future project, whose goals are to train wetlands managers and
improve their expertise in wetlands conservation in the Western
Hemisphere.  The Department spent about $4.3 million (in constant
1997 dollars) on its wetlands-related activities in fiscal years 1991
through 1997. 


   DEPARTMENT OF TRANSPORTATION
-------------------------------------------------------- Appendix II:9


      UNITED STATES COAST GUARD
------------------------------------------------------ Appendix II:9.1

The United States Coast Guard must comply with the provisions of
sections 404 and 401 of the Clean Water Act and Executive Order
11990.  According to the Coast Guard, consideration is given to the
impacts on wetlands before any new real property acquisition, new
construction projects, or maintenance projects for its shore
facilities is undertaken.  However, although the Coast Guard
conducted a number of wetlands-related activities in fiscal years
1990 through 1997, including restoration, enhancement, and creation
as mitigation, it does not keep records of such activities or track
the funding or staffing associated with them. 


      FEDERAL HIGHWAY
      ADMINISTRATION
------------------------------------------------------ Appendix II:9.2

The Federal Highway Administration administers the Federal Aid and
Federal Lands Highway Program.  As part of the highway development
process, state departments of transportation carry out components of
the wetlands management and compliance process, including
identification, delineation, and mitigation of highways' impacts on
wetlands.  Neither the Federal Highway Administration nor the state
departments of transportation regulate wetlands.  However, time is
spent in the regulatory compliance process performing tasks primarily
for the section 404 process.  Most of the over $523 million (in
constant 1997 dollars) spent by the Federal Highway Administration in
fiscal years 1990 through 1997 was related to mitigation for highway
construction. 


   ENVIRONMENTAL PROTECTION AGENCY
------------------------------------------------------- Appendix II:10

As one of the primary agencies responsible for wetlands, the
Environmental Protection Agency has regulatory and enforcement
responsibilities under section 404 of the Clean Water Act.  EPA also
has regulatory functions that include the control of discharges of
pollutants in all waters of the United States, including wetlands. 
In addition, EPA performs wetlands-related research.  EPA also has
established programs that improve wetlands protection by increasing
the emphasis on watershed or ecosystem management approaches; support
and improve capabilities of state, tribal, and local wetlands
programs; provide technical assistance, including scientific
information and tools; and support outreach and education to meet the
needs of its partners.  As part of these programs, EPA provides
wetlands grants to assist state, tribal, and local government
organizations in building their wetlands expertise, capabilities, and
programs.  EPA has spent $241 million (in constant 1997 dollars) and
over 1,450 full-time-equivalent staff-years on its wetlands-related
activities in fiscal years 1990 through 1997. 


   FEDERAL EMERGENCY MANAGEMENT
   AGENCY
------------------------------------------------------- Appendix II:11

The Federal Emergency Management Agency (FEMA) has no specific
wetlands programs, but it does operate programs that affect wetlands,
such as the Hazard Mitigation Grant Program, the Public Assistance
Program, and the National Flood Insurance Program. 

FEMA's Public Assistance Program provides funding to state and local
governments and nonprofit entities to repair damaged facilities and
also funds other disaster response and recovery activities, such as
debris removal and disposal.  The Hazard Mitigation Grant Program
assists states and local communities to implement long-term hazard
mitigation measures that substantially reduce the risk of future
damage.  In addition, FEMA's National Flood Insurance Program maps
flood hazard areas and makes flood insurance available only in those
communities that adopt and enforce floodplain management ordinances
that meet or exceed minimum standards.  Many of these floodplains are
also wetlands.  The National Flood Insurance Program's Community
Rating System provides discounts on flood insurance premiums that
take actions beyond the program's minimum requirements. 

Federal Emergency Management Agency staff also review some of the
Corps' permitting decisions relative to section 404 of the Clean
Water Act and other agencies' National Environmental Policy Act
documents. 


   GENERAL SERVICES ADMINISTRATION
------------------------------------------------------- Appendix II:12

The General Services Administration's wetlands-related activities are
related to fulfilling the "only practical alternative" requirement of
Presidential Executive Order 11988, Floodplain Management.  Agency
officials responsible for leasing actions or for site acquisitions
must certify that the site selected is the only practical alternative
despite the impacts on wetlands.  In fiscal years 1990 through 1997,
the administration spent about $90,000 (in constant 1997 dollars) and
no identified full-time-equivalent staff-years on wetlands-related
activities. 


   INTERNATIONAL BOUNDARY AND
   WATER COMMISSION (U.S. 
   SECTION)
------------------------------------------------------- Appendix II:13

The International Boundary and Water Commission is a bi-national
commission created by the governments of the United States and Mexico
to apply the provisions of various boundary and water treaties and to
settle differences arising from such applications.  The U.S. 
Section's wetlands responsibilities include maintaining the Lower Rio
Grande Flood Control Project by mowing and clearing brush growing
within the river floodway, where needed.  The Commission's U.S. 
Section is also creating a wildlife refuge primarily focused on
waterfowl habitat in a moist soil managed wetlands in El Paso, Texas. 
About $834,000 and six full-time-equivalent staff-years were
associated with these wetlands-related activities in fiscal year
1997. 


   NATIONAL AERONAUTICS AND SPACE
   ADMINISTRATION
------------------------------------------------------- Appendix II:14

The National Aeronautics and Space Administration is involved in a
number of wetlands-related activities.  These activities include
restoration, construction, research, mapping, delineation, and
education.  In fiscal years 1990 through 1997, the agency spent about
$1.6 million (in constant 1997 dollars) and six full-time-equivalent
staff-years on these activities. 


   NATIONAL SCIENCE FOUNDATION
------------------------------------------------------- Appendix II:15

The National Science Foundation was involved in a number of wetlands
research and research-related activities.  Although research accounts
for a majority of its activities, the National Science Foundation was
also involved in wetlands mapping, restoration, and education/public
outreach activities.  In fiscal years 1990 through 1997, the National
Science Foundation spent almost $47 million (in constant 1997
dollars) and 27 full-time-equivalent staff-years on its wetlands
research and research-related activities. 


   THE SMITHSONIAN INSTITUTION
------------------------------------------------------- Appendix II:16

The Smithsonian Institution's wetlands-related activities range from
acquiring easements to education/public outreach efforts.  The
Smithsonian Environmental Research Center provides public education
and professional training on the tidal and freshwater wetlands of the
Chesapeake Bay region. 


   TENNESSEE VALLEY AUTHORITY
------------------------------------------------------- Appendix II:17

The Tennessee Valley Authority has been involved primarily in
wetlands research and, to a limited extent, other activities such as
restoration, mapping, inventorying, and delineation.  In fiscal years
1990 through 1997, the Tennessee Valley Authority spent about $15
million (in constant 1997 dollars) and 115 full-time-equivalent
staff-years on its wetlands-related activities. 


FUNDING AND STAFFING ASSOCIATED
WITH FEDERAL AGENCIES'
WETLANDS-RELATED ACTIVITIES,
FISCAL YEARS 1990 THROUGH 1997
========================================================= Appendix III

                                                                         (Constant 1997 dollars in millions)

                                                Fiscal Year                                                                       Fiscal year
                   ----------------------------------------------------------------------  -----------------------------------------------------------------------------------------
                         1990              1991              1992              1993              1994              1995              1996              1997              Total
                   ----------------  ----------------  ----------------  ----------------  ----------------  ----------------  ----------------  ----------------  -----------------
                                                                                                                                                                             Average
                                                                                                                                                                              annual
                              Full-             Full-             Full-             Full-             Full-             Full-             Full-             Full-              full-
                               time              time              time              time              time              time              time              time               time
                              staff             staff             staff             staff             staff             staff             staff             staff              staff
                   Fundin  equivale  Fundin  equivale  Fundin  equivale  Fundin  equivale  Fundin  equivale  Fundin  equivale  Fundin  equivale  Fundin  equivale  Fundin  equivalen
Agency                  g       nts       g       nts       g       nts       g       nts       g       nts       g       nts       g       nts       g       nts       g         ts
-----------------  ------  --------  ------  --------  ------  --------  ------  --------  ------  --------  ------  --------  ------  --------  ------  --------  ------  ---------
Department of
 Agriculture
Agricultural        $ .84         1   $ .81         1   $ .90         1   $ .88         1  $ 1.39         4  $ 1.36         4  $ 1.33         4  $ 1.30         4  $ 8.80       2.50
 Research Service
Economic Research     .14       1.2     .14       1.2     .13       1.2     .13       1.2     .13       1.2     .13       1.2     .12       1.2     .12       1.2    1.05       1.20
 Service
Farm Service        71.55       404   69.02       359   69.85       384   76.56       297   97.00       313   50.42       213   49.18       209   46.20       166  529.78     293.13
 Agency \a
Forest Service      17.77        89   17.11        89   16.65        89   16.21        89   16.60        89   16.18        89   15.82        89   16.50        93  132.83      89.50
Natural Resources   88.36     1,635   45.14       817     .84        16     .82      14.5  104.07        36   28.97     117.5  118.83       219  125.80     782.7  512.83     454.71
 Conservation
 Service \a,\b
Department of
 Commerce
National Oceanic    32.65       105   31.56       105   32.73       115   35.16       121   41.11       122   50.73       127   35.00       128   36.00       127  294.95     118.75
 and Atmospheric
 Administration
Department of
 Defense
Department of the     N/A        28     .63        28     .65        28    7.50     29.01    1.45     29.51    1.91     30.73    1.69     28.99    1.03     28.47   14.87      28.84
 Air Force
Department of the     .02        .3     .30       3.8     .81       5.1    1.98       4.3    1.08       9.1    2.11      12.7    3.03      14.2    2.44      16.2   11.76       8.21
 Army (excluding
 the Corps of
 Engineers)
Department of the     .39      6.98     .95      4.92    2.69     13.76    6.09     13.32    2.32     23.62    3.43     24.18    3.46     38.38    4.47     26.15   23.80      18.91
 Navy
U.S. Army Corps     90.70     956.3  102.84  1,023.69  181.70  1,121.26  157.39  1,111.84  186.31  1,176.44  196.76  1,198.71  205.90  1,154.87  172.04  1,094.91  1,293.   1,104.75
 of Engineers \c                                                                                                                                                       64
Other DOD               0         0       0         0       0         0     .49       2.5       0         0       0         0       0         0       0         0     .49        .31
 components
Department of
 Energy
DOE components       3.45      4.36    4.26      4.66    5.94      8.56    6.14      6.39    5.58      6.72   12.03      6.94    5.55      7.75    3.46      5.08   46.39       6.31
Bonneville Power      .09         0     .02        .5     .61        .5    1.35        .5    1.62        .5    2.16        .5    3.40        .5    1.12        .5   10.37        .44
 Administration
Federal Energy        .01        .2     .01        .2     .06       .87     .02        .3     .11      1.42     .03       .37     .02       .32     .04       .55     .30        .53
 Regulatory
 Commission
Western Area          .27         0     .03        .4     .03        .4     .03        .4     .12        .4     .03       .55      \d        .5     .02        .2     .54        .36
 Power
 Administration
Department of         N/A       N/A     N/A       N/A     N/A       N/A     N/A       N/A     N/A       N/A     N/A       N/A     N/A       N/A     N/A       N/A     N/A        N/A
 Housing and
 Urban
 Development
Department of the
 Interior
Bureau of Indian        0         0     .69         0     .34         0     .44         0     .64         0     .63         0     .61         0     .60         0    3.95          0
 Affairs
Bureau of Land        N/A       N/A   15.52       221   16.51       273   17.99       261   27.77       402   29.86       438   27.04       354   39.65       509  174.34     307.25
 Management
Bureau of             N/A       N/A    2.30        20    3.43        20    4.39        20    2.96        20    5.61        20    8.42        20    6.94        20   34.05      17.50
 Reclamation
Fish and Wildlife   88.50       479  110.64       501  139.48       551  135.50       553  136.02       585  155.38       574  122.04       590  165.00   596.2\e  1,052.     553.65
 Service                                                                                                                                             \e                56
Minerals              .08       N/A     .07       N/A     .10       N/A     .48       N/A     .07       N/A     .07       N/A     .07       N/A     .17       N/A    1.10        N/A
 Management
 Service
National Park       11.38       199   13.97       201   17.55       246   17.36       222   18.33       240   23.09       230   14.13       235   20.06       230  135.87     225.38
 Service
Office of Surface     .03        .3     .09        .3    1.01        .3     .02        .3     .02        .3     .02        .3     .02        .3     .02        .3    1.23        .30
 Mining
U.S. Geological     10.64       119   15.86       166   16.31       198   16.90       201   18.91       205   22.23       253   26.42       254   25.67       255  152.93     206.38
 Survey
Department of        1.58      12.7    1.99      15.1    2.22      16.3    2.52      17.2    2.72      18.3    3.20      20.4    2.68      16.4    2.44      14.3   19.35      16.34
 Justice \f
Department of
 Transportation
Coast Guard           N/A       N/A     N/A       N/A     N/A       N/A     N/A       N/A     N/A       N/A     N/A       N/A     N/A       N/A     N/A       N/A     N/A        N/A
Federal Highway     70.55     80.75   67.94     80.75   66.39     82.75   64.61     85.75   63.21     86.25   51.19     86.25   70.00     93.75   70.05     98.75  523.95      86.88
 Administration
Department of           0         0     .40       0 .      28       0 .    89 .      03 .    80 0         .      81       0 .    41 .       1 .    75 0         4   .33 .         02
 State
Environmental       13.57     115.9   22.54     169.2   29.92     187.2   33.41     193.2   32.23     193.8   37.37     195.3   36.43     199.3   35.60       199  241.06     181.61
 Protection
 Agency
Federal Emergency     .26      3.38     .25      3.38     .25      3.38     .24      3.39     .24       3.4     .23       3.4     .23       3.4     .23       3.5    1.92       3.40
 Management
 Agency
General Services        0         0       0         0       0         0     .09         0       0         0       0         0       0         0       0         0     .09          0
 Administration
International           0         0       0         0       0         0       0         0       0         0       0         0       0         0     .83         6     .83        .75
 Boundary and
 Water Commision
National              .07      1.02     .14      1.26     .10      1.28     .33      1.15     .29       .27     .27       .38     .22       .12     .16       .32    1.59        .73
 Aeronautics and
 Space
 Administration
National Science     4.41         3    4.17         3    5.63         3    7.01         3    7.15         3    6.24         4    6.58         4    5.67         4   46.86       3.38
 Foundation
Smithsonian           .12         5     .12         5     .11         5     .16         5     .16         5     .16         5     .84         8     .25         5    1.92       5.38
 Institution
Tennessee Valley      .53      5.75    5.15     16.15    1.25     13.05    1.22     12.85    1.20      13.3    1.44      14.4    2.17      19.2    2.18      20.4   15.15      14.39
 Authority
====================================================================================================================================================================================
Total              $507.9  4,256.14  $534.6  3,841.51  $614.4  3,384.91  $614.2  3,271.13  $771.6  3,588.53  $704.0  3,670.81  $761.6  3,693.28  $786.8  4,307.73  $5,295   3,751.76
                        5                 9                 7                 9                 1                 5                 3                 1               .51
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Note:  The information shown for the funding and staffing represents
the expenditures and full-time-equivalent staff- years associated
with the agencies' wetlands-related activities in a given fiscal
year.  However, because many of the wetlands-related activities of
the agencies are integrated into other programs, the agencies could
not always document their expenditures.  In most of these instances,
the agencies provided estimates of the expenditures and staffing
associated with their efforts.  In addition, because not all agencies
provided information on their wetlands-related funding and staffing,
the total funding and staffing may be understated. 

Totals may not add because of rounding. 

N/A indicates that the agencies did not provide the requested
information. 

\a With the reorganization of the Department of Agriculture in 1994,
the management of some programs, such as the Water Bank Program, were
transferred from the Farm Service Agency (formerly the Agricultural
Stabilization and Conservation Service) to the Natural Resources
Conservation Service (formerly the Soil Conservation Service). 

\b Funding associated with NRCS' wetlands-related activities do not
include the cost of performing wetlands delineations under the
Swampbuster provision from fiscal year 1992 through 1996.  According
to NRCS officials, the costs of performing wetlands delineations were
not tracked during this period.  The costs of wetlands delineations
are reflected in the totals shown for the remaining years.  Funding
associated with these efforts in 1990, 1991, and 1997 was $73.6,
$38.1, and $33.8, respectively. 

\c The funding data shown includes the expenditures associated with
the Corps' regulatory program.  Although most of the Corps'
regulatory funding is devoted to the section 404 program, the costs
of regulating other activities are also included.  However, the Corps
does not separately track the costs of regulating wetlands.  The
staffing data shown for the Corps are primarily for the regulatory
program and do not include staff involved in the Corps' other
wetlands-related activities. 

\d Less than $.01 million

\e Includes $40 million in funding and 8.2 full-time-staff
equivalents associated with Everglades ecosystem restoration
activities in south Florida. 

\f These numbers represent the resources associated with the efforts
of the Environment and Natural Resources Division's headquarters
staff.  Although United States Attorney Offices are also involved in
prosecuting and defending section 404 cases, the Executive Office of
United States Attorneys could not provide funding and staffing data. 




(See figure in printed edition.)Appendix IV
COMMENTS FROM THE CLINTON
ADMINISTRATION INTERAGENCY
WETLANDS WORKING GROUP INCLUDING
INPUT FROM INDIVIDUAL AGENCIES
========================================================= Appendix III



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(See figure in printed edition.)



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The following are GAO's comments on the Clinton Administration's
Interagency Wetlands Working Group's letter dated May 15, 1998. 


   GAO'S COMMENTS
------------------------------------------------------- Appendix III:1

1.  The report notes that the agencies are involved in
wetlands-related activities to varying degrees.  Not only do we point
out that 6 of the 36 agencies\1 are the primary agencies involved in
and responsible for implementing wetlands-related programs, but we
state that these 6 agencies account for more than 70 percent of the
funding and 65 percent of the staffing associated with such
activities.  In addition to the five agencies cited by the
Interagency Wetlands Working Group as the primary wetlands agencies,
we included the Department of Agriculture's Farm Service Agency. 
During the period covered by our review, the Farm Service Agency
accounted for a significant amount of the funding and staffing
associated with wetlands-related activities because of its
involvement in such programs as the Conservation Reserve Program and
Swampbuster. 

In addition, appendix II of the report contains detailed information
on the types of wetlands-related activities that each agency
conducts.  However, to further clarify the roles of the various
federal agencies in wetlands-related activities, we revised the
caption in the report to highlight that agencies are involved to
varying degrees and included a statement in this section to indicate
the nature of the wetlands-related activities of the other 30
agencies. 

2.  We reviewed the administration's national wetlands plan during
the course of our work and made several references to it in our
report.  However, we did not include a more in-depth discussion of
the plan because the administration's national wetlands plan dealt
primarily with streamlining and improving the wetlands regulatory
program, not improving wetlands data. 

3.  The report acknowledged not only the different mandates and
methods used by the National Wetlands Inventory and the National
Resources Inventory, but also recognized that both have reported a
decline in the rate of wetlands loss.  However, as we point out, the
estimates of wetlands acreage made by the two inventories are not
completely consistent--a fact also recognized in the administration's
Clean Water Action Plan.  Furthermore, the previous efforts of
interagency task forces as well as the current efforts by the
Interagency Wetlands Working Group, taken in response to the Clean
Water Action Plan, emphasize the need to reconcile the differences in
the estimates of the two inventories. 

We added information to the report recognizing the effort undertaken
by the Interagency Wetlands Working Group to reconcile the two
inventories and produce a single wetlands status and trends report. 
We also included a copy of the Interagency Wetlands Working Group's
May 1998 action plan in appendix VII. 

4.  The agencies provided editorial changes, technical corrections,
and clarifying information that have been incorporated in our final
report where appropriate. 

5.  We revised the report to reflect the development of the
Interagency Wetlands Working Group's May 1998 action plan.  This plan
addresses how one of the three actions intended to improve wetlands
data contained in the administration's 1998 Clean Water Action Plan
will be accomplished.  Details of how the other actions will be
accomplished have not been developed. 

6.  We did not revise the title or first sentence of this section as
suggested by EPA.  However, its comment indicates that EPA generally
agrees that the consistency and reliability of wetlands acreage data
reported by federal agencies are questionable. 

7.  We revised this sentence to clarify our point that the estimates
produced by the two inventories are not completely consistent.  As we
previously noted, the report already acknowledges the different
mandates and methods used by the National Wetlands Inventory and the
National Resources Inventory as well as recognizing that both have
reported a decline in the rate of wetlands loss. 

8.  The numbers shown in table 1 were provided by FWS and NRCS,
respectively.  The numbers shown in this table served as the basis
for FWS' September 17, 1997, news/press release in which the Service
reported that the annual rate of wetlands loss had declined to about
117,000 acres.  Subsequent to receiving agency comments on our draft
report, we contacted FWS and were told that the FWS numbers shown in
the table were correct and had not been withdrawn.  However, FWS
noted that in its final report only one wetlands loss number will be
shown.  The losses attributed to the various causes, e.g.,
agriculture, development, etc., will not be reported.  In addition,
as we have previously noted, we revised our report to reflect the
recent efforts undertaken by the Interagency Wetlands Working Group
to reconcile the differences in the two inventories' estimates and
produce a single wetlands status and trends report. 

9.  The information presented in this section is merely to provide
the purpose(s) for which the various task forces were established. 
Therefore, we did not add the additional material provided by EPA. 

10.  We did not revise the title of our report because we believe
that it accurately reflects the current situation.  Although we
recognize that the administration has recently undertaken efforts to
resolve the wetlands data problems identified in our report, these
actions will not be completed for several years. 

11.  The estimates presented in our report for the NRI are the
1982-1992 NRI wetlands estimates.  As noted in our report, questions
and concerns about the NRI's 1992 estimates were raised by officials
from both the National Wetlands Inventory and EPA. 

12.  The section in question provides supporting details for our
finding that the consistency and reliability of the estimates made by
the two federal resource inventories and the data reported by the
agencies on their accomplishments are questionable.  USDA may be
correct in its assertion that users of inventory data incorrectly add
figures to the inventory estimates and cause overstating of
accomplishments.  However, as this section points out, the current
reporting practices of the agencies include the double counting of
accomplishments as well as a lack of consistency in the use of terms
and the inclusion of nonwetlands acreage. 

13.  We revised the report to reflect the development of an action
plan by the Interagency Wetlands Working Group.  However, although
the action plan addresses one of the actions contained in the
administration's Clean Water Action Plan--the development of a single
wetlands status and trends report--it does not address how the
administration plans to accomplish the other actions it announced. 
In addition, the success of the Working Group's efforts will require
a long-term commitment as well as considerable time and effort by the
agencies.  We have therefore revised our conclusions to reflect that
although the administration has undertaken efforts, much remains to
be done before the administration has resolved the wetlands data
problems identified in our report. 

14.  As we point out in our report, not only did EPA express concern
about the estimates of both inventories, but officials from each of
the agencies responsible for the inventories have questioned the
estimates of the other. 



(See figure in printed edition.)Appendix V

--------------------
\1 The Department of State informed us that we should identify the
International Boundary and Water Commission as a separate agency,
thereby increasing the number of agencies from 35 to 36. 


COMMENTS FROM THE DEPARTMENT OF
THE INTERIOR
========================================================= Appendix III




(See figure in printed edition.)Appendix VI
COMMENTS FROM THE DEPARTMENT OF
COMMERCE
========================================================= Appendix III



(See figure in printed edition.)



(See figure in printed edition.)


The following are GAO's comments on the Department of Commerce's
letter dated May 15, 1998. 


   GAO'S COMMENTS
------------------------------------------------------- Appendix III:2

1.  Appendix I is an update of the statutes presented in our previous
report Wetlands Overview:  Federal and State Policies, Legislation,
and Programs (GAO/RCED-92-79FS, Nov.  22, 1991).  Because the purpose
of the appendix is to highlight major statutes dealing with wetlands
issues, we did not revise our report. 




(See figure in printed edition.)Appendix VII
ACTION PLAN:  DEVELOPING A UNIFIED
WETLANDS STATUS AND TRENDS REPORT
========================================================= Appendix III



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


OBJECTIVES, SCOPE, AND METHODOLOGY
======================================================== Appendix VIII

Concerned about the lack of consolidated information on the federal
commitment to wetlands, you asked us to (1) develop an inventory of
the federal agencies involved in wetlands-related activities and the
funding and staffing associated with their activities during fiscal
years 1990 through 1997 and (2) determine if the wetlands data
reported by these agencies are consistent and reliable. 

To develop an inventory of federal agencies involved in
wetlands-related activities, we reviewed studies and reports on
wetlands-related policies and programs.  We also contacted officials
from six agencies--the Army Corps of Engineers, the U.S.  Department
of Agriculture's Farm Service Agency and the Natural Resources
Conservation Service, the Department of Commerce's National Oceanic
and Atmospheric Administration, the Department of the Interior's Fish
and Wildlife Service, and the Environmental Protection Agency.  These
agencies were identified in a prior GAO report\9 as the federal
agencies primarily responsible for administering wetlands-related
programs.  We asked officials from these agencies to identify other
federal agencies that had either requested technical assistance or
had been involved in joint wetlands projects.  Thirty additional
federal agencies were identified through these efforts. 

To identify the funding and staffing associated with federal
agencies' wetlands-related activities in fiscal years 1990 through
1997, we contacted officials from the Army Corps of Engineers, five
U.S.  Department of Agriculture agencies, eight Department of the
Interior agencies, the Department of Justice, the Environmental
Protection Agency, the Federal Emergency Management Agency, and the
National Oceanic and Atmospheric Administration.  We obtained and
reviewed documentation on the wetlands-related activities conducted
and the funding and staffing associated with these efforts.  We also
surveyed 18 other federal agencies identified as being involved in
wetlands-related activities to determine the extent of their
involvement and to obtain information on the funding and staffing
associated with their efforts. 

We attempted to obtain information on the actual expenditures and
full-time-staff equivalents associated with the agencies'
wetlands-related activities.  However, because some of the agencies
do not track their wetlands activities separately or have integrated
their wetlands-related activities into other program activities, the
agencies were not always able to document the resources expended.  In
most of these instances, the agencies provided estimates of funding
and staffing associated with their efforts.  Because the volume of
data collected would have required a significant investment of time
and resources, we did not verify the completeness, accuracy, and
reliability of the data provided.  We attempted to reconcile
inconsistencies in the data provided.  However, reconciliation was
not always possible because many of the agencies do not have a focal
point for wetlands or, in some cases, a clear understanding of all
wetlands-related activities occurring within the agency and the
associated funding and staffing. 

To determine the consistency and reliability of wetlands acreage data
reported by the agencies, we interviewed officials and obtained and
reviewed documentation on two federal resource inventories--the
National Wetlands Inventory and the National Resources Inventory
maintained by Interior's Fish and Wildlife Service and Agriculture's
Natural Resources Conservation Service, respectively.  In addition,
we discussed and reviewed documentation on the practices used by the
federal agencies to report their wetlands accomplishments.  We also
discussed recently announced initiatives to improve wetlands data
with officials of the Federal Geographic Data Committee's Wetlands
Subcommittee and the Deputy Assistant Secretary of the Army (Civil
Works) who chairs the White House's Interagency Wetlands Working
Group. 

To obtain additional perspectives on the various wetlands-related
activities, we visited Coastal Wetlands Planning, Protection and
Restoration Act projects in Louisiana and met with responsible
federal and state officials to discuss the program's operations. 


--------------------
\9 Wetlands Overview:  Federal and State Policies, Legislation, and
Programs (GAO/RCED-92-79FS, Nov.  22, 1991). 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IX


   ENERGY, RESOURCES, AND SCIENCE
   STAFF
-------------------------------------------------------- Appendix IX:1

Lloyd L.  Adams
Alfred T.  Brown, Jr.
James R.  Hunt
Sherry L.  McDonald
Victor S.  Rezendes


   OFFICE OF GENERAL COUNSEL
-------------------------------------------------------- Appendix IX:2

Alan R.  Kasdan


*** End of document. ***