development. If there has been lit- 

 tle consideration of estuarine needs 

 amid all this construction, it is not 

 for lack of law on the books. It is 

 for lack of coordination. These com- 

 peting agencies must be brought under 

 a unified plan if development is to 

 be balanced with preservation. But, 

 no one yet has been appointed to do 

 the balancing. So, development goes 

 on upstream without regard to down- 

 stream, and now without regard to 

 latter. 



This call for national coor- 

 dination and farsightedness harks 

 back to the provisions of the Coast- 

 al Zone Management Act. CZMA could 

 provide the necessary focus. How- 

 ever, CZMA is limited in its effec- 

 tiveness for a number of reasons. 

 First, the program is voluntary. 

 Second, the requirements are pro- 

 cedural not substantive. The com- 

 bination of these two factors tends 

 to encourage states to take the money 

 and run. Many of the participating 

 states have succeeded in designating 

 only one "area of particular con- 

 cern." This kind of compliance is 

 the means to no end. 



States must be encouraged to 

 view the national interest. Some may 

 do so simply by looking to a neigh- 

 boring state. One of the most press- 

 ing needs in the administration of 

 CZMA is for improved coordination be- 

 tween or among two or more states 

 which share a common watershed. Sec- 

 tion 309 of CZMA added in 1976, 

 amendments which provide for inter- 

 state grants to coordinate state 

 coastal zone planning with respect to 

 contiguous area--but it has never 

 been funded. The problem of fresh- 

 water inflow cannot even be approach- 

 ed until there is provision for in- 

 terstate planning. Fortunately, a 

 few states are beginning to request 

 that Section 306 administrative 



grants be made available for inter- 

 state planning. For example, Pacific 

 Northwest states, through the medium 

 of the Title II river basin commis- 

 sion, have requested interstate funds 

 for the benefit of the Columbia River 

 Estuary. The Great Lakes and New 

 England River Basins Commissions have 

 also been the recipients of Section 

 306 funding. 



In reviewing the obstacles which 

 OCZM faces in carrying out its man- 

 date, I have mentioned the lack of 

 coordination among states and the 

 lack of coordination among Federal 

 agencies. There remains a third 

 obstacle which also should be obvious 

 --the lack of coordination between 

 the states and Federal agencies. 

 Section 307 of the act is entitled, 

 "Interagency Coordination and Coop- 

 eration." This section requires that 

 Commerce coordinate its activities 

 with other Federal agency activity. 

 It also requires that each Federal 

 agency operating within a state 

 coastal zone be consistent to the 

 maximum extent practicable with that 

 state's coastal zone management pro- 

 gram. As of this moment, these words 

 have a hollow ring. Because there is 

 little coordination of agency activi- 

 ty at the Federal level, it would 

 seem to follow that there can be lit- 

 tle or no coordination of that activ- 

 ity at the state level. These polit- 

 ical realities make it difficult for 

 OCZM to keep the goal of protection 

 and wise use of the estuary at the 

 forefront of its management program. 



In addition, the provisions of 

 the Coastal Zone Management Act, as 

 they are now interpreted, cannot ade- 

 quately treat the freshwater inflow 

 problem. For instance, Section 315 

 of the act makes grant money avail- 

 able for the acquistion of estuarine 

 sanctuaries. Florida is one state 

 which has taken advantage of this 



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