CRMC 



proper use of design criteria. The inspection process is expected to be labor 

 intensive, and to very heavily involve engineering expertise. 



Hire teciinicai planning and resource management staff to support to full 

 implementation of the SAM plans and to undertake the recommended 

 subcommittee activities, necessary outreach activities, and provide 

 technical assistance to communities as needed. 



LEGAL SUPPORT 



For some time, the lack of staff legal support at CRMC has been a subject of concern. 

 Members of the advisory committees involved in preparation of the SAM plans, in 

 particular, have stressed the need for development of an in-house legal department in 

 CRMC where attorneys would be exclusively concerned with promoting the objectives of 

 the CRMP. Several individuals interviewed during the course of this research effort 

 expressed concern that a retainer arrangement with a general practice law firm tends to place 

 the Council in a position which involves exclusive reliance on outside opinion in choosing 

 enforcement actions and strategies. 



In addition, CRMCs ecosystem management and protection mandate involves the 

 Council and staff in issues of great technical complexity. Because of the role which 

 technical issues play in jurisdictional determinations, and in evaluation of both permit 

 conditions and adequacy of compliance, staff need to work closely with attorneys on a 

 regular basis. 



At the same time, the attorneys on retainer who argue coastal resource protection issues 

 in administrative hearings and judicial proceedings depend heavily upon technical advice 

 provided by staff in presenting and responding to technical questions. If in-house legal 

 staff were devoted to exclusive duty within CRMC, to work in concert with 

 retained legal support, enforcement efforts could be effectively 

 strengthened. 



Recoinmendations 



**Hire in-house legal staff to strengthen CRMC enforcement capability, and to enhance 

 enforcement coordination among agencies. 



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