CRMC 



to define pollution control goals with increased precision, based on use and evaluation of 

 work plans. 



♦♦Review Special Area Management plans every two years (at a minimum) to measure 

 progress toward meeting specific goals and objectives specified in annual work plans. 



Buffer Areas 



At present, CRMC's policy with regard to imposition of buffer areas is 

 insufficiently clear. Citizens, developers and agency staff familiar with the program 

 stated that decision criteria regarding buffers were unspecified, negotiating fiexibility too 

 broad, scientific evidence insufficiendy applied in deriving buffer dimensions, and 

 maintenance and protection responsibilities unstated. Especially with respect to non-point 

 source impacts, these perceived program implementation problems are of concern. If the 

 inverse condemnation issue is contributing to CRMC's difficulties in establishing adequate 

 buffer areas, then the need for regulatory clarity is further emphasized. Although 

 recommended buffers take precedence over set-backs as a matter of CRMC practice, this 

 policy is not stated in the Red Book. 



Recommendations 



***Revise CRMC regulations to include clear policy statements and review 

 criteria to be applied to proposed development in coastal areas, regarding: 



a) definitions of applicable buffer area jurisdictions and all areas affecting buffers 

 including areas: within 50 feet of the edge of a marsh, pond or bog; within 100/200 

 fect4>f tidally-influenced riverbank weUands depending on the size of the 

 watercourse (as consistent with Freshwater Wetland regulations); 



b) definitions of the term "minimal or no disturbance" to be allowed in such areas; 



c) specific means and methodologies to be used in deciding which applications will be 

 subject to review of cumulative effects; what means and measurements will be used 

 to evaluate cumulative effects; and what mitigating measures will be required. 

 Criteria should include clear standards of evaluation regarding hydrologic 

 modification, loadings of sediment/turbidity, and input of toxics which would 

 facilitate evaluation of cumulative effects. (Methodologies currentiy applied in 

 Maine, in Falmouth, Massachusetts, and in other jurisdictions). 



d) specific technical issues to be considered in drawing distinctions between Category 

 A and Category B Assent applications with regard to work that may affect the 

 setback area of coastal buffer areas or may affea floodplains. Technical criteria 

 should include clear standards of evaluation regarding hydrologic modification, 

 loadings of sediment/tiutidity, and input of toxics which would facilitate 

 classification of alterations and evaluation of cumulative effects. 



Implementation of Non-point Source Controls 



CRMC considers non-point source impacts in its permit evaluation process, and 

 regularly requires use of specific control practices. Technical guidance and specifications 

 are included in the Red Book, but these provide limited detail, and are not accompanied by 



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