From Jane Clark:
Please take action on this urgent request.  Iowa has already lost most of
its wetlands and this change by the Corps sets up an "anything goes
approach" to wetland replacement.  The policy allows for wetland mitigation
to consist of preservation or enhancement of existing wetlands, small buffer
strips along streams, upland areas, ponds and other waters, or simply
deepening an existing wetlands for swimming or fishing.  "None of these
types of 'mitigation' can compensate for the loss of natural wetlands and
will contribute to a continued net loss of our nation's valuable wetlands,"
according to Robin Mann, Chair of the Sierra Club Wetlands Committee.

URGENT:  CONTACT PRESIDENT'S COUNCIL ON ENVIRONMENTAL QUALITY
TO OPPOSE THE CORPS' LATEST WEAKENING OF THE WETLANDS PROGRAM

On October 31, 2001 the Army Corps of Engineers issued a Regulatory
Guidance Letter changing the rules on wetlands mitigation in the nation's
Section 404 wetlands program in ways that abandon the no net loss policy on
wetlands that has been in place for a decade.  There was no advance notice
to the other federal agencies, let alone consultation, and no opportunity
for the public to comment. See
http://www.usace.army.mil/civilworks/hot_topics/rglmitigation.htm

The Corps' guidance is a unilateral response to the mitigation study of the
National Academy of Sciences issued last spring, which found serious
deficiencies in the mitigation program.  The Corps has responded to only a
few of the study recommendations, ignoring or counteracting others.  Under
the new guidance, replacement for destroyed wetlands could be provided by
preservation or enhancement of existing wetlands, small buffer strips along
streams, upland areas, ponds and other waters, or simply deepening an
existing wetland for swimming or fishing.

Please send an email message to James Connaughton, Chairman of the Council
on Environmental Quality, urging him to take action, c/o the following
address:   [log in to unmask]

Tell Mr. Connaughton:

1.  The Administration must have the guidance withdrawn.

2.  The Administration must require the Corps to undertake a joint
initiative involving the public and the academic community, as well as the
EPA and other federal agencies charged with responsibility for the Section
404 program, to develop improvements to the mitigation program that address
all of the NAS recommendations.

Questions, contact Robin Mann, [log in to unmask]

For background information on mitigation banking, please visit
http://www.sierraclub.org/wetlands/resources/mitigation.asp

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