Friday, October 9, 1998 6:30 PM

FROM THE CLEAN WATER NETWORK:

CONGRESS IS ATTEMPTING TO ADD THE JONES WETLANDS MITIGATION BANKING BILL
TO THE OMNIBUS APPROPRIATIONS BILL!

CALL YOUR REPRESENTATIVES AND THE WHITE HOUSE TO TELL THEM TO OPPOSE
EFFORTS TO ATTACH IT TO THE APPROPRIATIONS BILL

THEY WILL BE THERE ALL WEEKEND

President Clinton --message line is (202) 456-1111

Call and ask the Administration to veto any bills with anti-environmental
riders, and specify the Jones Mitigation Banking bill.

Congressman Jim Leach -- 202-225-6576
Congressman Leonard Boswell -- 202-225-3806
Congressman Greg Ganske -- 202-225-4426
Congressman Tom Latham -- 202-225-5476
Congressman Jim Nussle -- 202-225-2911

OR TRY:
 Dial toll-free, using 888-898-7717 or 800-335-4949 or call the Capital
 switchboard 202-224-3121 and ask for your Senators' and Representative's
 offices.
==
In a synical, 11th hour move, the forces of evil have attached the Jones
Wetlands Mitigation banking bill as a rider to the Omnibus
appropriations bill.  Right now, Congress is working into the wee hours
of the morning and all weekend to combine all of the remaining unpassed
appropriations bills into what is being called the Omnibus
Appropriations bill.  Appropriations bills must be passed so that the
Government won't shut down.  These types of bills are targets for a lot
of anti-environmental initiatives that wouldn't pass under the scrutiny
of public debate.

Remember the 1995 government shutdown?  In part, it was over 17
anti-environmental riders (that had nothing to do with appropriations)
being attached to a "must-pass" appropriations legislation.  That year,
Rep. Boehlert and 60 other moderate Republicans as well as most
Democrats opposed these riders.  Let's ask them to do it this year too.

The Jones (R-NC) Wetlands bill was debated this summer in the House
Water Resources Subcommittee and the debate was so heated and divisive,
that the full committee decided not to consider it or vote on it, so it
was stalled.  Now the mitigation bankers are trying to pull a fast one
by attaching it as a rider to a bill that they know Congress must pass
in the next few days.

Call your members of Congress immediately and tell them to oppose this
effort.  They will be working all weekend, so you can call them through
the Congressional Switchboard at 202-224-3121.  (They
may not even know that this rider got attached yet, so tell them about
it, why wetlands are important to you.).  Ask them their position and
urge them to oppose a bill with any anti-environmental riders, including
the Jones wetlands mitigation banking bill.

Also call the White House Hotline and leave a message that you want the
Administration to veto any bill that has the Jones Mitigation Banking
bill on it as a rider.

Here is an analysis of the Jones bill and our reasons for opposing it.
You all did a great job of killing this bill this summer.  Please find
the time to put in a call and bring it to your Representatives'
attention this time around.

---------------
Principal Objections to H.R. 1290 (Jones Wetlands Mitigation Banking
Bill), as Reported by the Subcommittee on Water Resources and
Environment on June 4, 1998

1.  Sequencing: Under the concept of "sequencing," wetlands are allowed
to be destroyed only as a last resort.  The bill fails to provide that
sequencing (the requirement that developers first avoid and then
minimize wetland impacts before mitigating for those impacts that cannot
be avoided or further minimized) be followed where mitigation banks are
used.  Without a clear sequencing requirement, mitigation banks can
easily be used as an excuse for permitting unnecessary and damaging
wetland destruction.

2.  Lack of Adequate Requirements for Bank Success: H.R. 1290 lacks
adequate provisions to ensure that mitigation banks are successful
ecologically.  For example, there is no requirement for the Army Corps
of Engineers to evaluate and make findings on the success or failure of
a bank, and there is no opportunity for public input in determining and
ensuring the success of a bank.

3.  Credit for Preservation: The bill would allow a mitigation bank to
sell credits for preserving wetlands (or even uplands).  Preservation
cannot compensate for wetland destruction in the nation's continuing
effort to achieve and move beyond no net loss of wetlands.  The bill's
restrictions on preservation credits do not apply if a mitigation bank
includes wetlands restoration, creation or enhancement.

4.  Moving Wetlands: H.R. 1290 establishes "service areas," the
geographic areas within which mitigation credits can be traded, that are
far too large.  As a result, the bill would allow developers effectively
to "move" wetlands by restoring or creating a wetland far away from the
wetland being destroyed.

11.  Squeezing the Federal Resource Agencies Out of the Process:
Presently, the Environmental Protection Agency, the U.S. Fish and
Wildlife Service, and the National Marine Fisheries Service contribute
vital expertise to the process of reviewing banks and setting their
ecological success standards.  H.R. 1290 significantly reduces the role
of these agencies, giving them little to do but comment on bank
proposals, and even then limiting their comments to a short comment
period.

12.  Failure to Address Real Wetlands Threats: H.R. 1290 fails to
confirm the Corps' jurisdiction over excavation activities by failing to
codify the "Tulloch Rule," a bipartisan wetland-protection provision
that was struck down by a federal appeals court in June 1998.  With the
loss of the Tulloch Rule, excavation activities are entirely unregulated
under the Clean Water Act and developers can drain wetlands without a
Clean Water Act permit and without any mitigation obligations
whatsoever. Codifying authority for mitigation banking without
confirming the Corps' jurisdiction over excavation would constitute a
major failure to address the real reasons why America is still losing
more than 100,000 acres of wetlands every year.

Prepared by
American Oceans Campaign
Center for Marine Conservation
National Audubon Society
National Wildlife Federation
Natural Resources Defense Council
Sierra Club

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