NON-TIDAL WETLANDS
We oppose the present definition of Non-tidal wetlands as
set forth in the 1989 "Federal Manual for Delineating Jurisdictional Wetlands."
This definition would designate many acres of marginal wetlands that possess
minimal wetlands values. It would also include many acres of cropland that has
been farmed historically. ‘05
We support the revision of the "Federal Manual for
Delineating Jurisdictional Wetlands" to exclude:
(1) cropland that was farmed prior to
the enactment of any laws dealing with the regulation
(2) areas with woody or natural
vegetation that are not ponded for more than fifteen consecutive days during
some part of the growing season. ‘05
This definition should also be used for any existing or
proposed state legislation. It is imperative that the Army Corps of Engineers,
the Environmental Protection Agency, and the Natural Resource Conservation
Service review the definition of Non-tidal wetlands and evaluate its
implications on agriculture. Furthermore, it is our belief that all three of the
criteria should exist before land is considered a wetland and we hope the manual
will be amended accordingly. ’05
We support the designation of the Natural Resource
Conservation Service as the lead agency for the development of uniform wetlands
delineation.’06
Agriculture needs to be exempt from mitigation for
agricultural activities where the farmer has, and is carrying on good
agricultural practices. ’07
We recommend that when wetlands are identified, property
owners must be notified and an appeal or review process be developed.’07
The denial of a permit to alter wetlands, by either federal
or state government, should be deemed "the taking of private property" and the
landowner should be "justly compensated."
The state should not be more stringent than the federal
regulations concerning agriculture in its relationship to Non-tidal wetlands.
We recommend that public agencies be held completely
responsible for wetlands that they create due to water drainage and/or the
re-routing of water as a result of construction of public facilities such as
roads, schools, storm water management ponds, parking lots, etc. Cost of
litigation to protect the landowner should be borne by the public agency
involved.
We urge local control of regulations and permits limiting the
use of wetlands.’07