CRMC 



ISDS Section; Water Quality Certifications and Wetiands permits are granted via DEM's 

 Division of Water Resources and Division of Groundwater and Freshwater Wetiands 

 approvals- all prior to request for a CRMC approval. As an example of inconsistency, 

 DEM has traditionally used criteria for evaluation of ISDS siting which were based on 

 system function, rather than on potential environmental impacts (corrections have been 

 proposed by the ISDS Task Force). 



As to broader impacts, dredged material disposal provides a useful example. The Corps 

 of Engineers, EPA, and DEM respond to the requirements of Section 404 of the Clean 

 Water Act and require compliance with water quality standards, while CRMC jurisdiction is 

 defined by its state-level enabling legislation. When DEM denies water quality certification 

 of disposal permit applications, citing its non-degradation policy with respect to classified 

 waters, applications do not reach CRMC, where a resource management mandate 

 encompasses evaluation of dredge disposal needs in the state. 



Recommendations 



***The permit review sequence should be revised to provide that 

 applications are submitted first and simultaneously to CRMC and DEM 

 Freshwater Wetlands, with copies of applications to the recommended local 

 environmental officer, who may provide advice as to the completeness of the 

 application, and discuss town requirements with the applicant. The towns should 

 review the applications following CRMC, so that local officials can have the benefit 

 of state-level analysis of impacts. 



MANAGEMENT INITIATIVES 



Special Area Management 



Findings and Concerns 



Although each Special Area Management Plan has been developed in a unique manner 

 and has moved on an individual path toward implementation, some common problems have 

 emerged. Although all of the individuals interviewed during the course of 

 the present research effort concurred that special area management 

 techniques can be useful in estuarine management, several individuals 

 expressed concern regarding the pace and direction of SAM plan 

 implementation. Concerns voiced by members of the committees and working groups 

 which were instrumental in preparing and monitoring implementation of the plans include: 



CRMC has not taken an aggressive role in urging towns to undertake 

 necessary revisions of local ordinances and by-laws to support the 

 objectives of the SAM plans. This is partly due to lack of staff available for outreach 

 activities, and partly due to a reluctance to intrude into town jurisdiction. 



Nor, as in areas outside SAM plan purview, has CRMC moved to 

 encourage and support vigorous protection of floodplain areas and coastal 

 high hazard areas except by revising SAM plan regulations to incorporate procedures 

 established by applicable post-hurricane mitigation plans. 



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