CRMC 



lots platted prior to the advent of contemporary zoning criteria create the potential for 

 concentrated development in hazard areas or in areas developed beyond carrying capacity. 



♦•Revise CRMC regulations to state specifically under what conditions 

 flood plain analyses will be required, referencing: a) effect on potential floodplain 

 areas; b) effect on existing watershed flood storage capability, c) effea on flood hazard 

 vulnerability of surrounding development 



V/axer Use Area Review Criteria 



With regard to resource protection, CRMC uses water quality certifications in 

 evaluation of development effects, but has little real authority to prohibit 

 development based on water quality impacts, except in cases where an activity is 

 specifically prohibited in die water type at issue. If a water quality certification can 

 be obtained, CRMC has little ability to deny a permit on water quality 

 grounds, because it is not involved in water quality monitoring activities. 



Applicants proposing new point discharges in Type 1 Areas must demonstrate that "no 

 reasonable alternative to the discharge exists, and that no significant adverse impact to the 

 receiving waters will result," but criteria for measuring effects are not specified. In Type 1 

 and 2 Waters, mitigation requirements are not specified. Similarly, although 

 cumulative impacts of runoff are stated to be "of particular concern" in 

 Type I waters, methods of measuring or addressing those impacts are not 

 outlined. 



Recommendations 



CRMC and DEM need to develop a water quality based approach to 

 pollution control and project evaluation, consistent with the objectives 

 articulated in the special area management plans. In order to address non-point 

 source impacts in a cohesive manner, it is necessary to develop specific programs to 

 achieve reductions in pollution discharges and improvements in the water quality of tidally 

 influenced rivers and otiier Bay areas affected by non-point source pollution. 



***Working with DEM, develop a water quality characterization process to 

 be used to link biological integrity with ejects of present use and potential 

 use to the maximum extent possible. Waste load allocations and effluent limits 

 should be established to coordinate the simultaneous imposition of point source discharge 

 limits and non-point source controls. 



***Use characterization results to establish detailed water quality goals to 

 guide non-point pollution efforts in specific areas and to develop a 

 planning process for these selected areas which clearly links defined water 

 quality goals to non-point pollution control programs and requirements. 



Guidelines should be developed setting specific standards to govern the siting and design 

 of development so as to consider water quality concerns as a basis for siting, operation, 

 and maintenance. 



♦♦♦In cooperation with DEM, develop a pre-development and post- 

 development water quality monitoring program for use in critical watershed 

 areas and estuarine waters. The agencies should jointiy define how water quality 



18S 



