provision provides. With regard to the first advantage, water 
quality, recreational uses, air quality, shoreline growth, and 
landslide activities are all related and should be managed as 
such. 
I think one of the aspects of the overall management of the 
estuary would ensure a certain degree of inefficiency. For 
example, as you probably know, early Federal efforts to manage 
the Chesapeake Bay were largely ineffective because they 
isolated only one aspect of estuarine management; in this case, 
the Chesapeake Bay's water quality. Now, to combat that 
approach, the EPA and the surrounding states are looking at the 
factors involved in Chesapeake Bay water quality degradation. 
They are looking at agricultural runoff, urban runoff, and other 
landslide activities and not just at industrial sources. As a 
result, we have a comprehensive approach which, I think all will 
agree, is more effective than the initial approach. 
With regard to the second advantage, it is most appropriate 
that state, regional, and local officials be the principal 
authors of any specific estuary management plan. The 
appropriate rule under the CZMA is to provide limited grants to 
assist in that effort, provide guidelines and technical 
assistance relative to national interests, and to approve a plan 
on development and implementation. 
With regard to the third advantage, Federal consistency, in 
the San Francisco Bay Plan has been implemented through a 
consistency procedure and jurisdiction granted to the BCDC. The 
relevant California state law, that is McAteer-Petris Act, has 
been approved by NOAA pursuant to the CZMA, as part of 
California's Federally-approved Coastal Management Program. 
BCDC has authority over all areas of the Bay, extending 
landward 100 feet, including Suisun Marsh and the surrounding 
wetlands. Permits are required for practically all work 
involving fill from the driving of a single pile to the 
development of larger scale projects. Permits are issued only 
if the proposed work is consistent with the McAteer-Petris Act 
and the Bay Plan. 
Let me give to you an example of what I think is good co¬ 
operation in the implementation of the Bay Plan. That is the 
relationship of the U.S. Army Corps of Engineers and the BCDC. 
Obviously, there are competing uses for the Bay and the shore¬ 
line. Probably the most critical has to be resolved in managing 
the Bay. Since the Corps has permitting authority for all 
proposals and the CZMA requires consistency certification for 
such a Corps permit where activities are within the legal coast¬ 
al zone, the Corps simply recognizes a BCDC permit as a consis- 
4 
