decides that the application is not complete for its purposes, it may decide to delay the public 

 notice until more information is obtained from the applicant (R. Bosenburg, U.S. Army Corps, of 

 Engineers, New Orleans, LA; pers. comm.). In that case the other agency may decide to go ahead 

 with its processing of the permit application including an independent public notice. 



State Permitting Network 



The State permitting network for activities in the coastal zone including marsh management 

 activities consists of the permitting agency, CMD or the local (parish) coastal management 

 program, and the State commenting agencies. Under this system, decisions to issue a coastal use 

 permit are based not only on the guidelines and regulatory policies of the lead agency but also on 

 compliance with the regulatory requirements and policies of the commenting agencies. CMD has 

 memoranda of understanding with seven other State agencies: the Office of Conservation and 

 Division of State Lands of the Department of Natural Resources, the Department of 

 Environmental Quality, the Department of Health and Hospitals, the Department of Culture 

 Recreation and Tourism, the Department of Agriculture, and the Department of Wildlife and 

 Fisheries (DWF). These memoranda of understanding provide for notification from CMD of 

 activities which may fall under the jurisdiction of the various agencies and give the agencies 

 authority to comment on the proposed activity. Additionally, the memoranda provide that for all 

 the agencies listed above, with the exception of the Department of Agriculture and DWF, CMD 

 will condition the approval of coastal use permits on compliance with the rules and regulations of 

 these commenting agencies and upon the applicant obtaining any permits required by these 

 agencies. Under this system, for example, if an archaeological or historical site or park would be 

 impacted, the Department of Culture Recreation and Tourism is notified and may comment to 

 CMD. The comments may establish conditions or object completely to the proposed activity. 



The Department of Agriculture may comment on or object to activities, including the use of 

 pesticides, which impact agricultural resources, and CMD must respond to these comments to the 

 maximum extent practicable in their permit decisions. The memorandum of understanding does 

 not require that CMD condition CUP's to be consistent with the regulatory requirements of the 

 Department of Agriculture. 



The DWF memorandum of understanding with CMD provides that DWF's comments on coastal 

 use permit applications will be "given full consideration in the coastal use permit decision process 

 and summarized and responded to in the actual permit document." Comments about policy 

 concerns by the other agencies not involving violations of their regulatory authority are evaluated 

 by CMD for consistency with the CRMA and may or may not be acted upon by CMD. Also, 

 CMD reviews comments of other State and Federal agencies and incorporates those that don't 

 conflict with the CRMA (J. Rives, CMD; pers. comm.). 



An in-lieu permitting system has been established by the CRMA and further developed in a 

 memorandum of understanding between CMD and the Office of Conservation of the Department 

 of Natural Resources. This system divides permitting authority for oil and gas related activities 

 between the two agencies. For example, the siting and drilling of oil or gas wells require permits 

 from the Office of Conservation instead of a CUP. However, if access to the drill site requires 

 dredging a canal or building a board road in the coastal zone a CUP is required for that activity 

 in addition to the Office of Conservation permit. 



The CRMA also establishes local coastal management programs under which the local program 

 may assume the permitting authority for activities in the coastal zone defined by the CRMA as uses 



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