Editors' Summary: Although the Army Corps of Engineers has the power to issue permits for discharge of dredge and fill materials under Clean Water Act §404, the Act directs EPA to establish guidelines for the permit program. The role of those guidelines and their legal effect has been a topic of debate recently among both administrative reformers and litigants. This Article examines the genesis of the guidelines, the intragovernmental debate over their role, and their application by the courts. It particularly considers the settlement in National Wildlife Federation v. Marsh, in which the Corps agreed to promulgate regulations accepting the guidelines as binding. The Article concludes that though the settlement has resolved a major issue in the debate, questions about the meaning of particular guideline provisions and administrative authority to interpret the guidelines remain.