    [From the U.S. Government Printing Office, www.gpo.gov]

                           MANAGING
                  CUMULATIVE IMPACTS
                              IN THE
                      NORTH CAROLINA
                       COASTAL AREA

                                                                                 . ....... ........

                                                                A REPORT OF THE

                                                              STRATEGIC PLAN
                                                                       FOR
                                                  IMPROVING COASTAL MANAGEMENT
                                                                        IN
                                                              NORTH CAROLINA

                        Performed Under the Coastal Zone Enhancement Grants Program

                                            Division of Coastal Management
                          North Carolina Department of Environment, Health and Natural Resources

                                     COVER GRAPHIC: This GIS map of the North Carolina Coastal Area shows
                                     boundaries of counties and small watersheds, or hydrologic units.   These
                                     hydrologic units are the focus of analytical and planning components of the
                                     Strategic Plan for Improving Coastal Management in North Carolina.

                                          MANAGING CUMULATIVE IMPACTS
                                                                IN THE
                                         NORTH CAROLINA COASTAL AREA

                                                      James E. Wuenscher
                                          North Carolina Division of Coastal Management
                                    Department of Environment, Health and Natural Resources

                                                             June 15, 1994

                    The preparation of this report was financed by funds provided by the Off ice of Ocean and Coastal
                    Resources Management, NOAA, under the Coastal Zone Enhancement Grants Program. The
                    views expressed herein are those of the author and do not necessarily reflect the views of NOAA
                    or any of its sub-agencies or those of the North Carolina Department of Environment, Health and
                    Natural Resources.

           Z3-

                                                                   ENT OF

                    A publication of the North Carolina Department of Environment, Health and Natural Resources
                    pursuant to National Oceanic and Atmospheric Administration Award No. NA270ZO332-01.

                                                      TABLE OF CONTENTS

                    Section                                                                                     Page

                    1.      INTRODUCTION           ...........................................                      1

                                     Defining Cumulative and Secondary Impacts         ....................         2
                                     Assessment vs. Management of Cumulative
                                     and Secondary Impacts      ....................................                3
                                     Risk Assessment       ........................................                 4
                                     Establishing Cumulative Impact Management Goals          ...............       7
                                     Implementation of Cumulative Impact Management Goals           ...........     8

                    2.      THE NORTH CAROLINA CONTEXT                  ............................               10

                                     Statutory Mandates     ......................................                 10
                                     Organization and Capability     ................................              12

                    3.      A CUMULATIVE IMPACTS MANAGEMENT MODEL                         ................         14

                                     Relative Risk Assessment      .................................               15
                                     Classification of Risks   ....................................                17
                                     Goal Setting    ...........................................                   19
                                     Identification of Appropriate
                                     Implementation Mechanisms       ...............................               20
                                     Implementation     .........................................                  22

                    4.      POSSIBLE TYPES OF HIGH RISK AREAS                   .......................            24

                                     Areas with Impaired Water Quality      ...........................            24
                                     Areas with High Potential for
                                     Water Quality Impairment      .................................               27
                                     Areas with Present or Potential
                                     Air Quality Impairment    ....................................                27
                                     Areas with Historic Rapid Growth     ............................             28
                                     Anticipated High-Growth Areas       .............................             29
                                     High Value Resource Areas       ................................              30
                                     Productive and Aesthetic Resource Areas        .....................          32

                    5.      ALTERNATIVE MANAGEMENT STRATEGIES                       ....................           34

                                     The CAMA Regulatory Program         .............................             35
                                     Land Use Planning      ......................................                 38
                                     Inter-Agency Coordination     .................................               41
    k                                Special Area Management Planning        ..........................            44

    -72

                                                TABLE OF CONTENTS

                   6.     SUMMARY AND CONCLUSIONS            ...............................          45

                                 The North Carolina Model   .................................         46
                                 Management Strategies    ...................................         47
                                 Conclusions    ...........................................           48

                          REFERENCES CITED          ......................................            51

                          APPENDICES        ............................................              55

                                 Cumulative Impacts Indicators in PC-Based
                                 Population/Development/Resources Information System    ...........   55
                                 GIS Databases in Information System    ........................      57

                            .. ... . .....
                                                                    ...............
                                                                    ..............
                                                                                               The coastal area of North Carolina is
                                     ............. ..... .. ..
                                                                                      being affected by the kind of rapid growth and
                             ...........         ..........
                         .. . ............. . ..........
                                              . .......
                                                                                      development typical of the nation's coastal areas.

                                                ...............
                                                                                      As a whole, the coastal area is the fastest growing
                                                                                      region in the state. During the 1980s, four of the
                                                                                      five fastest growing counties in the state were
                                                                                      located in the coastal area, and that trend has
                                                                                      continued into the 1990s.

                                                                                               One of the primary purposes of the North
                                                                                      Carolina Coastal Management Program (NC
                                                                                      CMP) is "to guide growth and development and to
                                                                                      minimize damage to the natural environment"
                                                                                      (NCGS 113A-102) that makes the coastal area
                                                                                      productive and attractive. It has been recognized
                                                                                      since the passage. of CAMA that commercial and
                                                                                      residential development and the development of
                                                                                      water dependent facilities such as piers and
                                                                                      marinas may adversely impact biological resourc-
                                                                                      es and coastal water quality. Both the CAMA
                                                                                      permitting program and local land use planning
                                                                                      requirements, as well as other state and federal
                                                                                      regulatory programs applicable to the coastal
                                                                                      area, have been designed to minin-dze these
                                                                                      adverse impacts while allowing coastal develop-
                                                                                      ment to occur.

                                                                                               Most regulatory programs are designed to
                                                                                      minimize the impacts of individual projects on the
                                                                                      resources they directly affect. When development
                                                                                      becomes concentrated, however, the cumulative
                                                                                      and secondary, or indirect, impacts of the develop-
                                                                                      ment may be significant, even though the direct
                                                                                      effects of each individual project are minimal.
                                                                                      Runoff from one specific development on the
                                                                                      estuarine shoreline may not, in itself, result in a
                                                                                      significant decline in water quality, but the
                                                                                      cumulative runoff from many such developments
                                                                                      may.     The possibility of adverse cumulative
                                                                                      impacts has been recognized since the develop-
                                                                                      ment of the original CAMA use standards and
                                                                                      land use planning guidelines, but the lack of
                                                                                      specific statutory authority or straight-forward
                                                                                      methods for assessing cumulative impacts made
                                                                                      it difficult to address this possibility. Instead, the
                                                                                      approach taken was to attempt to minimize
                                                                                      individual impacts to such an extent that cumula-
                                                                                      tive impacts would not be significant.

                                                                                               After nearly twenty years of experience
                                                                                      with the CAMA regulatory and land use planning
                                                                                      programs, the continued appropriateness of this
                                                                                      approach is being questioned. Environmental
                                                                                      degradation has occurred, in spite of CAMA and
                                                                                      other state and federal environmental protection
                                                                                      programs. Although the situation would be much

                                                                                               Cumulative Impacts Management- Page 1

                   worse without these programs, the public often                                          11 .. the impact on the environment which
                   perceives them as inadequate so long as any                                             results from the incremental impact of the
                   noticeable environmental degradation occurs.                                            action when added to other past present,
                   Seventy percent of public comments received in                                          and reasonably foreseeable future ac-
                   the CZMA �309 Assessment of the NC CMP                                                  dons, regardless of what agency or
                   performed in 1991 indicated that adverse cumula-                                        person undertakes such other actions.
                   tive impacts were a problem that should be                                              Cumulative impacts can result from
                   add  'ressed through program enhancements (DCM,                                         Individually minor but collectively signifi-
                   1992a). During a series of public meetings held                                         cant actions taking place over a period of
                   in the spring of 1993, declines in coastal water                                        Ohio- (40 CFR Sect 15U.7).
                   q uality and fisheries and closure of areas to                               This definition of cumulative impacts defines
                   shellfishing were the symptoms most often cited                              them as the "additive" result of all individual
                   as evidence of adverse cumulative impacts of                                 impacts of a series of actions occurring over time
                   growth and development.                                                      and space, including those of the past and the
                              As part of its Four Year Strategic Plan                           foreseeable future. The impacts of any single
                   for Enhancing Coastal Management, the North                                  action may be negligible, but the cumulative
                   Carolina Division of Coastal Management (DCM)                                effect of many actions may result in the gradual
                   is developing methods for assessing and manag-                               and incremental degradation of a resource over
                   ing adverse cumulative impacts in a more holistic                            time.
                   fashion than has been used in the past. This                                            There are other ways of considering
                   report is a technical introduction to the DCM                                cumulative impacts than as simply additive. In
                   approach. Section 1 summarizes the results of                                many cases environmental impacts are interactive
                   initial research on cumulative and secondary                                 or synergistic so that the total effect of an inter-
                   impacts, discussing their definition and consider-                           action between two or more impacts is greater
                   ations necessary for their assessment and man-                               than the sum of the individual effects (Beanlands,
                   agement. Section 2 discusses the North Carolina                              et al., 1986). The cumulative impact of synergis-
                   context and assesses the strengths and weakness-                             tic actions is greater than the additive impact of
                   es of the NC CMP in managing cumulative                                      each action. Considering the complexity of ecolog-
                   impacts. Section 3 describes the cumulative                                  ical systems, it is likely that synergistic cumula-
                   impacts management model being applied in the                                tive impacts occur more frequently than additive
                   NC coastal area. Sections 4 and 5 discuss the                                impacts. The greater degree of complexity in-
                   types of high risk areas likely to be present in the                         volved in synergistic impacts, however, make
                   coastal area and alternative cumulative impacts                              them even more difficult to assess or manage.
                   management strategies that may be applied to
                   them.                                                                                   Still another approach toward cumulative
                                                                                                impacts is to include all possible impacts of a
                   Deflning Cumulative and Secondary                                            given action, including not only its direct impacts
                   Impacts                                                                      but also those of additional actions which the first
                                                                                                may stimulate. Examples include highway and
                              While the existence of cumulative and                             bridge construction, in which the direct impacts
                   secondary impacts has long been recognized, the                              of construction itself may not be as great as the
                   difficulty of identifying and dealing with them                              impacts of additional growth and development
                   has prevented specific action within planning and                            that may result from the new highway or bridge.
                   regulatory programs. It is easy to talk in general                           The cumulative impact of such a project may be
                   terms about cumulative impacts, but much more                                considered as the total impact of the project itself
                   difficult to specifically identify them. The first                           plus the impacts of all resulting development
                   critical step is to agree on a definition.                                              To avoid further confusing an already
                              While there are a variety of ideas about                          difficult subject, however, it is preferable to
                   cumulative impacts and what they include, the                                consider this situation an example 'of secondary
                   most widely accepted definition is that given by                             rather than cumulative impacts. In this case
                   the Council on Environmental Quality (CEQ) in                                there is only one project or activity, and the
                   its guidelines for implementation of the National                            potential impacts being considered include its
                   Environmental Policy Act (NEPA) of 1969. Those                               indirect, or secondary, effects. Cumulative im-
                   duidelines    .define a cumulative impact as:                                pacts, on the other hand, are the overall effects of
                                                                                                multiple activities, whether these activities are

                   Cumulative Impacts Management- Pago 2

                       related to one another or not. For the purposes of            activities are often confused, it is helpful to
                       DCM`s consideration of cumulative impacts, then,              distinguish them in planning an approach to
                       one activity at one place and occurring at one                cumulative impacts.
                       point in time can never be considered to have
                       cumulative impacts. It is only when an activity                       Ideally, cumulative impacts assessment
                       is considered together with other activities affect-          includes an analysis of the complex relationships
                       ing the same resources that cumulative impacts                between multiple disturbances and valued envi-
                       are relevant. This approach is consistent with                ronmental functions (Leibowitz, Abbbruzzese, et
                       the CEQ definition of cumulative impacts.                     al., 1992). It seeks to identify, understand, and,
                                                                                     if possible, quantify the actual cause and effect
                               Secondary impacts, then, may be defined               relationships among multiple human-induced
                       as the indirect effects of an activity resulting from         activities and the functional characteristics of the
                       the activity's role in influencing other systems.             ecosystems they effect. This requires a very
                       Other systems influenced may include the local                complex analysis that is fraught with scientific
                       economy, as in the highway or bridge example in               difficulties and uncertainties. Trying to deal
                       which the improved access resulting from the                  definitively with cause and effect relationships in
                       highway or bridge creates new markets by elimi-               a complex and inter-related web of causal path-
                       nating previously existing constraints. Or the                ways is extremely difficult, expensive and time-
                       activity may influence natural systems, e.g., a               consuming. It stretches the current state of
                       development adjacent to a wetland may decrease                ecological understanding to its limits. Attempting
                       certain of the wetland's functions, resulting in de-          to perform this type of analysis in a regulatory
                       graded water quality or declines in fish productiv-           context probably exceeds those limits.
                       ity. The development itself did not directly cause
                       these ultimate impacts, but without the develop-                      This does not mean that site or project-
                       ment's effect on other systems the secondary                  specific cumulative impacts analysis should not
                       impacts would not have occurred. Secondary                    be attempted. It must be in those cases in which
                       impacts occur whenever one activity results in                laws, such as NEPA, require that it be performed.
                       far-reaching, indirect, and often unexpected,                 It does mean, however, that it is an impractical
                       effects mediated by the operation of other sys-               approach upon which to base a government
                       tems.                                                         environmental management or regulatory pro-
                                                                                     gram. While rudimentary techniques for cumula-
                               Both natural ecosystems and human-                    tive impacts assessment exist, our current state
                       generated systems such as the economy are                     of knowledge limits the results to either qualita-
                       extremely complex, transcending complete under-               tive professional judgements or the output of
                       standing or predictability. Due to this complexi-             complex mathematical models. This may not be
                       ty, it is likely that every activity has at least             an adequate basis upon which to justify why a
                       some secondary impacts and that any time there                landowner will not be allowed to do the same
                       are two or more activities, they have cumulative              thing his neighbor has already done. Detailed,
                       impacts. The question is not whether these                    cause-and-effects cumulative impacts assessment
                       impacts exist, but at what point they become                  is too complex, imprecise, and difficult to under-
                       sufficiently significant and adverse to warrant               stand and explain to form an acceptable basis for
                       specific consideration and action.                            public policy and regulatory decision-making.

                       Assessment vs. Management of                                          Another approach is simply to accept the
                       Cumulative and Secondary                                      complexity of the cause-effect relationships and
                                                                                     focus instead on the causes and effects them-
                       impacts                                                       selves. Instead of attempting to understand and
                                                                                     specify complex ecological relationships, this
                               The CEQ definition of cumulative impacts              approach identifies the activities that result in
                       was developed to provide guidance for implement-              impacts and the status of resources that are
                       ing NEPA!s requirement to assess cumulative                   affected. Two implicit assumptions are involved.
                       impacts. Most of the subsequent literature on the
                       subject deals with the topic of cumulative impacts
                       assessment. There is a difference, however,
                       between cumulative impacts assessment and
                       cumulative impacts management (Institute for
                       Environmental Negotiation, 1991). Since the two

                                                                                              Cumulative Impacts.Management- Page 3

                   (1)   If a system is already exhibiting                  ecological thresholds, even for one system, re-
                         symptoms of degradation (i.e.,                     quires large amounts of research and data.
                         adverse effects exist), the degra-                 Nevertheless, considerable progress is being made
                         dation is the result of the cu.                    on identifying natural limits and applying them
                         mulative impacts of all the                        to management and regulatory decisions. Dickert
                         factors influencing the system.                    and Tuttle (1985) used hydrologic and erosion
                  ,(2)   Ifenvironment-impactingactiv-                      models to establish land disturbance thresholds
                         ities (causes of impacts) become                   for the Elkhorn Slough watershed in California.
                         intensive enough in a limited                      These thresholds were incorporated into a land
                         area, there will be adverse                        use planning framework. The whole basin ap-
                         effects resulting/rom, the cumu-                   proach to water quality management being
                         lative impacts of the many                         implemented by the NC Division of Environmen-
                         causes.                                            tal Management (DEM, 1991) uses total maxi-
                                                                            mum daily loads (TMDLs) derived from models
                         The first assumption is intuitively obvi-          based on assimilative capacity, existing loading,
                ous and, therefore, not difficult to justify. The           and other basin characteristics. These TMDLs
                second assumption is more difficult, since it               are applied to both the NPDES regulatory pro-
                entails determining the point at which distur-              gram and to planning of voluntary BMPs for
                bance becomes "intense enough" to result in                 nonpoint sources to limit the total discharge of
                adverse cumulative impacts. This point is the               pollutants in the basin to a level below the thres-
                limit of the local systerns tolerance or buffering          hold of water quality impairment.
                capacity for the particular disturbance or combi-
                nation of disturbances involved. This limit is                       Whether or not a natural threshold level
                sometimes called the system's "carrying capacity,"          can be   reliably quantified, the concept is well
                although that term and the well-documented                  accepted: when the cumulative effects of multiple
                phenomenon of limits to population densities                human activities exceed a certain threshold,
                upon which the carrying capacity concept is based           significant environmental damage becomes evi-
                do not really apply to multiple disturbances and            dent. Several useful general propositions can be
                cumulative impacts.                                         derived from this concept.
                         With engineered public facilities such as            (1)    Ifenvironmental degradation is
                roads, water systems, and sewage treatment                           not evident, the threshold has
                works, the determination of maximum capacity is                      presumably not been exceeded.
                straightforward (Dickert, et al., 1976). Similarly,                  (Although it may simply mean
                                                                                     that we are not monitoring the
                if the available supply of a consumptive natural                     appropriate parameters of
                resource, such as groundwater or assimilative                        degradation.)
                capacity, can be determined, the maximum
                human population it can support can be calculat-              (2)    Even though the exact thresh-
                ed. A 1983 study of the carrying capacity of part                    old level may be unknown, the
                of Currituck County, NC, (Bell, et al.) concluded                    more pressure that exists in a
                that its human population was limited by the                         given area, the closer the sys-
                amount of land suitable for septic tanks, since no                   tem is likely to be to its limits.
                wastewater treatment plant existed. Construc-
                tion of a sewage treatment plant would effectively            (3)    The more sensitive the re-
                remove this limitation and, thus, change the                         sources of an area are to dis.
                area@s carrying capacity and the limiting factor on                  turbance, the lower their thres-
                which it depends. Any capacity determined by                         hold level is likely to be.
                engineered facilities or by resources that can be
                substituted for, therefore, is not an absolute              Risk Assessment
                carrying capacity intrinsic to the area, since it
                can always be changed (Institute for Environmen-
                tal Negotiation, 1991).                                              Even though we cannot define ecological
                                                                            thresholds with certainty, these propositions
                         Determining natural limits or ecological           provide a basis for what might be termed "cumu-
                thresholds is more difficult, since they are deter-         lative impacts risk assessment." Ecological risk
                mined by complex and often poorly understood                assessment has been applied for some time to
                ecosystem dynamics. Definitive determination of             analyses of the effects of specific environmental

                Cumulative Impacts Management- Page 4

                      hazards (Barnthouse and Suter, 1986;) and has                solving. The classical rational planning approach
                      been more recently applied to cumulative impacts             replaces the complexities of ecological analysis.
                      (Hunsaker, et al., 1990; Hunsaker, 1993). The                Risk management decisions can be made through
                      objective of ecological risk assessment is to pro-           the consideration of priority problems in light of
                      vide a quantitative basis for comparing risks and            available management options, resources, admin-
                      a systematic means of improving the estimation               istrative and legal structures, etc. This results in
                      and understanding of those risks (Hunsaker, et               an approach more amenable to and more accept-
                      al., 1990). It is not necessary to fully understand          able in public policy-making.
                      and quantify all the relevant parameters in order
                      to compare the relative risks of different hazards                   Gosselink and Lee (1989) proposed an
                      or to compare different areas subject to different           approach to cumulative impacts management that
                      conditions. Relative risk assessment can be used             can be generalized from the specific instance in
                      to determine which risks are greater or which                which they applied it to a generally applicable
                      areas are at higher risk (Leibowitz, Preston, et             management model. Their model has three
                      al., 1992; Leibowitz, Abbruzzese, et al., 1992).             components, summarized below with Gosselink
                      While it may not provide precise answers, relative           and Lee's definitions of each component.
                      risk assessment does provide far better informa-
                      tion than is currently available. This information           Assessment - 77he characterization of cumu-
                      can be used in making informed decisions and                         lative effects on both the ecological
                      protecting or managing the environment at large                      structure and the functional ecological
                      geographic scales (Hunsaker, 1993).                                  processes in a designated landscape
                                                                                           unit.
                              A study by EPA!s Science Advisory Board              Goal-Setting - Agreement by public consensus
                      (1990) recommended that environmental manage-                        on environmental goals for the assess-
                      ment and protection efforts be focused on areas in                   ment area, based on the assessment and
                      which the greatest risk reduction could be                           consistent with statute* and regula-
                      achieved. Risk assessment is the necessary first                     tions.
                      step in identifying those areas of focus, whether
                      they be specific environmental hazards or geo-               Implementation - The development of specific
                      graphic areas. After high risk areas have been                       plans to implement the goals, based on
                      identified, risk management can be applied                           the landscape structure and function of
                      through the development and implementation of                        the area.
                      specific management strategies to control and
                      manage the most serious risks.                                       The assessment component in this model
                                                                                   consists of an analysis of thecurrent status of the
                               This approach shifts the focus of atten-            landscape unit in comparison to its historic
                      tion from cumulative impacts assessment to                   condition to determine the degree of degradation
                      cumulative impacts management. The emphasis                  resulting from the cumulative impacts of past
                      changes from analyzing complex cause-effect                  actions. Rather than attempting to analyze the
                      relationships to assessing relative risks and                cumulative impacts of specific projects on specific
                      developing management approaches to risk                     ecological parameters, this assessment approach
                      control. There is also a shift in spatial and                uses a limited number of landscape indices, or
                      temporal horizons. Cumulative impacts assess-                relatively simple, measurable properties that
                      ment of individual activities is carried out on the          reflect ecological structure and important func-
                      scale of a particular development project or                 tions. While Gosselink and Lee (1989) used
                      discharge; cumulative impacts management is                  wetland-related indices, the specific indices could
                      performed on the landscape-level scale at which              vary, depending upon assessment objectives, and
                      cumulative impacts occur (Gosselink, et al., 1990).          could include socio-economic as well as ecological
                      Cumulative impacts assessment focuses on the                 parameters.
                      time horizon from the past to the present, while
                      cumulative impacts management focuses on the                         Applying a risk assessment approach to
                      time horizon from the present to the future                  the Gosselink and Lee model results in an assess-
                      (Williamson, 1992).                                          ment that uses the same type of landscape indices
                                                                                   to compare the status of different landscape units.
                               The cumulative impacts management                   Instead of a comparison of past with present
                      approach also allows the application of standard             conditions to determine ecological degradation, a
                      pla nning and management techniques of problem-              comparison of current conditions and stressors in

                                                                                            Cumulative Impacts Management- Page 5

                 different spatial units can be used to determine                     In their assessment of the ecological
                 the relative risks of significant adverse cumula-           status of the Tensas River Basin in Louisiana,
                 tive impacts among these areas. The areas at                Gosselink, Shaffer, et al. (1990) emphasized
                 highest risk then become the focus of risk reduc-           wildlife habitat, hydrology, and water quality.
                 tion management in the goal-setting and imple-              Landscape indicators included forest area and
                 mentation phases.                                           distribution, breeding bird surveys, Christmas
                                                                             bird counts, stream stage and discharge records,
                         This method has been called a "synoptie             and water quality records. Landscape indices
                 approach (Leibowtiz, Abbruzzese, et al., 1992),             were the changes in values of the indicators over
                 since it provides a broad overview of environmen-           time. They found these data sets, supplemented
                 tal conditions. It's objective is not to provide a          with land-cover data and maps, to be sufficient to
                 precise, quantitative assessment of cumulative              identify the major structural and functional
                 impacts within an area nor to assess the cumula-            changes related to the cumulative impacts of
                 tive impacts of specific projects, but to provide a         human activities. This information was used to
                 relative rating of the significance of cumulative           formulate specific management goals and imple-
                 impacts among areas. The critical choices to be             mentation strategies.
                 made in designing the risk assessment are the
                 environmental indices to be used and the identifi-                   Leibowitz, Abbruzzese, et al., (1992)
                 cation of appropriate landscape units and time              applied the synoptic approach to assessment of
                 scales for analysis.                                        cumulative impacts on wetlands in Louisiana,
                                                                             Washington, and Illinois. Their objectives were to
                        Landscape Indicators and Indices                     identify those areas where either wetland protec-
                                                                             tion (Washington) or wetland restoration efforts
                         Landscape indicators are actual data or             (Louisiana and Illinois) should be focused. Land-
                 measurements that reflect some aspect of land-              scape indicators included data on wetland area,
                 scape condition. A landscape index is a calculat-           measures of stream water quality, land use and
                 ed value derived from the values of landscape               human population. From these indicators, a
                 indicators and used as a basis for comparing                series of landscape indices were calculated, based
                 landscape units (Leibowitz, Abbruzzese, et al.,             on the management objectives for each case.
                 1992). In a risk analysis of nonpoint source                Indices of wetland hydrologic, water quality, and
                 pollution, for example, acreage of agricultural             habitat functions, wetland values, replacement
                 cropland might be used as a landscape indicator.            potential, and future risk of wetland loss were
                 Nitrogen and phosphorus loadings calculated from            used to assess relative risks and significance of
                 average agricultural runoff figures might be a              various landscape units for management efforts.
                 derived landscape index. The landscape indicator
                 is a relatively easy to obtain data set for the                      Since the goal of risk-based cumulative
                 landscape units. The landscape index translates             impacts assessment is the assignment of relative
                 the indicator value into an approximation of its            risk or priority for management action, not
                 functional significance.                                    precise measurement or prediction, relatively
                                                                             simple landscape indicators and indices are
                         The parameters used as landscape indica-            sufficient. It is not necessary to mathematically
                 tors and indices should adequately reflect both             describe exactly how conversion of forest land or
                 the pertinent environmental stressors and the               wetlands to agricultural or urban uses leads to
                 pertinent measures of environmental quality that            declines in habitat or water quality in order to
                 indicate the effects of stress. The specific param-         assess the relative risk of such impacts among
                 eters chosen will depend largely on the availabili-         different landscape units. Thus, a risk-based
                 ty of data, as well as on the objectives and intend-        approach to cumulative impacts assessment can
                 ed use of the assessment. It is rarely feasible to          greatly simplify data-gathering and analysis and
                 engage in extensive raw data acquisition for areas          still provide accurate guidance to management
                 as large as those appropriate for cumulative                decision-making.
                 impacts management (Leibowitz, Abruzzese, et
                 al., 1992). Given limitations in time, resources,                   Spatial and Temporal Boundades
                 and information, it is necessary to use landscape
                 indicators that are readily available and to calcu-                  Cumulative impacts, by definition, are
                 late from them first order landscape indices that           landscape-level, long-term phenomena that occur
                 are as meaningful as possible* in the context of            as the consequences of numerous activities over
                 the particular assessment.                                  time. Focusing on individual sites or projects
                                                                             necessarily misses these larger scale and longer-

                 Cumulative Impacts Management- Page 6

                       term patterns (Bedford, 1990). Each individual                the system in question has not entirely recovered,
                       project has its site-specific effects, but cumulative         no matter how long ago the disturbance occurred
                       impacts affect natural processes that occur within            (Clark, 1986). What future activities are "foresee-
                       interacting ecosystems across the landscape. The              able" may be more a question for the courts to
                       'water quality or productivity of a local portion of          defme than a question amenable to objective
                       a larger waterbody is the result not only of what             analysis.
                       occurs at or adjacent to that portion, but also of
                       what has occurred throughout the drainage basin.                      Since cumulative impacts management is
                                                                                     more oriented toward future than past impacts,
                               The appropriate spatial scale for manag-              identifying a discrete historical time boundary is
                       ing cumulative impacts, then, must be large                   probably not necessary. The current ecological
                       enough to include all individual impacts that                 status of a spatial management unit is an ade-
                       significantly influence the natural resource or               quate measure of the cumulative impacts of
                       process of interest. From a water quality perspec-            historic actions. Some historic analysis may be
                       tive, entire drainage basins form an appropriate              useful, however, to provide an accurate assess-
                       scale. From a wildlife management perspective,                ment of present ecological "health." Comparing
                       the management area must be large enough to                   current with past conditions can provide a mea-
                       satisfy the home range and habitat requirements               sure of the extent to which historic degradation
                       of the farthest-ranging animal species of interest            has occurred.
                       (Gosselink, et al., 1990). If habitat of wide-rang-
                       ing migratory species is of interest, a very broad                    Future projections are limited by our
                       landscape boundary may be necessary. Ideally,                 level of understanding of many long-term natural
                       space and time scales for cumulative impact                   processes such as sea level rise and the response
                       management should be developed for each re-                   of ecosystems to disturbances over time. The
                       source being managed. From the viewpoint of                   level and type of future impacts is subject to
                       overall environmental management, however, a                  unpredictable economic and market conditions
                       single scale that best fits most of the resources             determined by forces often far distant from the
                       and impacts is more practical.                                management unit. While ideal cumulative im-
                                                                                     pacts management would include a time scale at
                               The choice of landscape units for cumula-             least one to two human generations into the
                       tive impacts management must be based not only                future (Befford, 1990), practicality often limits
                       on ecological considerations, but also on manage-             the horizon of reliable projections to much shorter
                       ment objectives and data availability. The unit               periods.
                       boundaries should correspond as closely as possi-
                       ble to natural process boundaries, but may also               EStabilshing Cumulative Impact
                       be influenced by pragmatic considerations such as             Management GoalS
                       political jurisdictions, map scales, and analytical
                       methods (Leibowitz, Abbruzzese, et al., 1992).
                       Since water quality is an important environmen-                       An essential, but often difficult, compo-
                       tal management consideration and watershed                    nent of cumulative impacts management is estab-
                       boundaries are relatively easy to delineate,                  lishing goals for the resources of interest (Lee and
                       watershed units of various sizes have been used               Gosselink, 1988; Bedford and Preston, 1988).
                       most often as the basis for cumulative impacts                Specific goals or objectives are necessary to
                       analysis and management (Bedford, 1990; John-                 provide direction to any type of management. For
                       ston, et al., 1988; Gosselink, et al., 1990; Leibo-           cumulative impacts management, goals provide
                       witz, Abbruzzese, et al., 1992). Watersheds may               the link between the regional scale and site
                       also be divided into smaller sub-basins for more              specific plans and regulatory decisions. Rather
                       detailed analyses or aggregated into regional                 than trying to assess the impacts of a specific
                       basins for broad-scale management consider-                   action at the landscape level or focusing merely
                       ations.                                                       on local impacts because they are more readily
                                                                                     predictable, regulatory consideration of cumula-
                                Appropriate temporal boundaries for                  tive impacts can be made in light of the goals for
                       cumulative impacts management are more diffi-                 the landscape unit potentially affected. The
                       cult to identify. The CEQ definition refers to                effects of the proposed action in relation to estab-
                       "past" and "reasonably foreseeable future actions,"           lished cumulative impacts management goals can
                       but leaves these terms undefined. Relevant past               provide an objective basis for regulatory consider-
                       disturbances might include all those from which               ation of cumulative impacts.

                                                                                              Cumulative Impacts Management- Page 7

                        While goals should be based on scientific           jurisdictions of federal, state, and local govern-
                information, they are often more dependent on               ments can complicate goal implementation.
                values than on facts and, thus, are policy deci-            Cumulative impacts are regional phenomena that
                sions to be made within the context of the specific         can be addressed only through regional planning
                cumulative impacts management program.                      and cooperation. Even the most well-developed
                Cumulative impacts management goals will                    efforts to manage cumulative impacts within a
                normally be based on compliance with existing               series of jurisdictions can be hampered by inac-
                statutes and a balance between a healthy envi-              tion by a single governmental entity within the
                ronment and economic development.                           region (Contant and Wiggins, 1991).

                        Assun-dng, however, that the over-riding                     Goal implementation, that is, the actual
                goal is the maintenance of some acceptable level            management of cumulative impacts, requires as
                of environmental "health," goals for a specific             holistic an approach as the assessment and
                management unit should be based on the "pat-                analysis components. This step includes develop-
                ient's" current condition. If the current environ-          ment of specific plans to implement the goals for
                ment is considered "healthy" according to some              each landscape unit and enforceable policies to
                objective measure ofrelative well-being, then goal          carry out the plans. The specific nature of plans
                setting should focus on protecting a sufficient             and policies depends upon the resources or envi-
                level of existing resources to maintain that                ronmental characteristics of concern, the nature
                health. Impact minimization, while still allowing           of the situation within each landscape unit, and
                some decline from current conditions, may be an             the statutory context of the regulatory and man-
                acceptable strategy. Where the current condition            agement programs involved.
                is about equal to acceptable standards, a strategy
                of impact avoidance to prevent further deterio-                      If the goal is to manage cumulative
                ration is appropriate. If, on the other hand, the           impacts on one particular resource (water, air,
                patient is already in bad health, that is, signifi-         wildlife, wetlands, forest resources, etc.), then
                cant environmental impairment is present, appro-            goal implementation may be within the purview
                priate goals might include prevention of any                of a single-purpose agency. Cumulative impacts,
                further significant impacts, amelioration of                however, are more often than not cross or multi-
                existing impacts, and environmental restoration             media phenomena (Institute for Environmental
                (Gosselink, et al., 1990; Williamson, 1992).                Negotiation, 1991). That is, one class of activities
                                                                            may impact air and water quality, or wetlands,
                                                                            wildlife, and forest productivity.        Managing
                Implementation of Cumulative                                cumulative impacts on one resource while ignor-
                Impact Management Goals                                     ing others is contrary to the whole purpose of
                                                                            cumulative impacts management. If the goal is to
                        Dealing with cumulative impacts has                 manage cumulative impacts to the environment
                been constrained by reluctance to accept responsi-          as a whole, or even to more than one environmen-
                bility for cumulative impacts assessment and                tal medium, then goal implementation is beyond
                management planning, the first two steps of the             the capabilities of any single-purpose agency or
                cumulative impacts management model (William-               program and requires extensive inter-agency and
                son, 1992). These are large tasks, requiring a              inter-governmental coordination and cooperation.
                holistic approach that is often considered beyond
                the mandate of individual environmental agen-                        Landscape units may be found to be at
                cies.                                                       high risk of adverse cumulative impacts for
                                                                            various reasons. The appropriate means of goal
                        An even greater constraint to cumulative            implementation will depend upon the specific
                impacts management may be lack of an adequate               causative factors and environmental effects
                                                                            present. For example, degraded water quality
                management structure for goal implementation.
                Fragmentation of regulatory and resource man-               may be the cumulative result of a few industrial
                agement efforts into single-purpose agencies with           activities or of widely dispersed residential devel-
                responsibility for only parts of the environment            opment. In the former case, regulatory programs
                (water, air, wetlands, etc.) or narrow segments of          dealing with industrial practices maybesufficient
                human activity (agriculture, forestry, industrial           for goal implementation. In the latter case, land
                development, etc.) limits the extent to which any           use controls by local governments may be neces-
                one agency can address cumulative impacts and               sary. In the more common situation in which
                their causes. Similarly, multiple over-lapping              both industry and residential development are
                                                                            involved, inter-agency and inter-governmental

                Cumulative Impacts Management- Page 8

                      coordination is, once again, the key to successful
                      goal implementation.

                             Throughout this discussion, cumulative
                      impacts management goal implementation is
                      assumed to be a function of government. Since
                      cumulative impacts are a classic example of the
                      -
                      tragedy of the commons" (Hardin, 1968), govern-
                      mental action is probably the only feasible ap-
                      proach. But government is constrained in cumu-
                      lative impacts management by its statutory basis
                      and its organizational structure.       Structural
                      deficiencies can be compensated for by inter-
                      agency and inter-government coordination and
                      cooperation as discussed above, but all involved
                      agencies must act within their mandates and
                      statutory authorities. An appropriate combina-
                      tion of mandates and legal authorities, then,
                      must exist or be constructed for the implementa-
                      tion of cumulative impacts management goals.

                              Successftil cumulative impacts manage-
                      ment, then, requires assessment techniques,
                      holistic planning, and coordinated action of sorts
                      that have not been used in the past. Minimum
                      requirements include two specific elements: (1) a
                      lead agency with the legal mandate, technical
                      ability and willingness to assume the responsibili-
                      ty of on-goingcumulative impacts assessment and
                      management planning; and (2) a commitment and
                      structure appropriate to coordination and cooper-
                      ation in goal implementation by all the agencies
                      and governmental levels involved. The ability of
                      the North Carolina Coastal Management Program
                      to meet these minimal requirements and assume
                      the task of cumulative impacts management is
                      the subject of the next section.

                                                                                          Cumulative Impacts Management- Page 9

                                                                                             Statutory Mandates of the North
                                                                                             Carolina Coastal Management
                                                                             .... ...        Program

                            ................... ..
                                   .........                                ...... ...

                                               ..................
                        . . .... .......
                                                                                                        The NC CMP operates under the statuto-
                             ..........
                             ..........
                                                  ..............
                                                                                                authority and mandates of the North Carolina
                                                                                             Coastal Area Management Act (CAMA, - N.C.G.S.
                                                                                             113A, Article 7) and the Federal Coastal Zone
                                                                                             Management Act (CZMA - 16 U.S.C. 1451 et seq.).
                                                                                             Both of these acts set forth broad mandates for
                                                                                             the overall management of coastal lands and
                                                                                             resources. Several key provisions of these acts
                                                                                             provide the capabilities for management of cumu-
                                                                                             lative impacts.

                                                                                                        In light of the discussion of cumulative
                                                                                             impacts management in Section 1, the statement
                                                                                             of legislative findings in CAMA (G.S. 113A-
                                                                                             102(a)) sounds as if it were written specifically to
                                                                                             accomplish that end.

                                                                                                        In recent years the coastal area has been
                                                                                                        subjected to increasing pressures which
                                                                                                        are the result of the often-conflicting
                                                                                                        needs of a society expanding in industrial
                                                                                                        development in population, and in the
                                                                                                        recreational aspiradons of its citizens.
                                                                                                        Unless these pressures are controlled by
                                                                                                        coordinated management the very fee-
                                                                                                        tures of the coast which make it economi-
                                                                                                        cally, aesthetically, and ecologically rich
                                                                                                        will be destroyed The General Assembly
                                                                                                        therefore finds that an immediate and
                                                                                                        pressing need exists to establish a comi-
                                                                                                        prehensive plan for the protection, pres-
                                                                                                        ervation, orderly development and man-
                                                                                                        agement of the coastal area of North
                                                                                                        Carolina.

                                                                                             If the term "cumulative impacts" had been in as
                                                                                             common use in 1974 as it is today, it surely would
                                                                                             have been included in that statement of findings!

                                                                                                        CAMXs statement of goals (G.S. 113A-
                                                                                             102(b)) also sounds like the general goal state-
                                                                                             ment of a cumulative impacts management
                                                                                             program.

                                                                                               (1)      To provide a management system cap&-
                                                                                                        ble of preserving and managing the natu-
                                                                                                        ral ecological conditions of the estuarine
                                                                                                        system, the barrier dune system, and
                                                                                                        beaches, so as to safeguard and perpetu-
                                                                                                        ate their natural productivity and their
                                                                                                        biological, economic and aesthetic val-
                                                                                                        u9s;
                                                                                                (2)     To insure that the development orpreser-
                                                                                                        vation of the land and water resources of

                 Cumulative Impacts Management- Page 10

                                        the coastal area proceeds in a manner                               113(b)) is broad enough to include essentially all
                                        consistent with the capability of the land                          environmentally sensitive areas. Part 4 of CAMA
                                        and water for developmen4 use, or pres.                             (G.S. 113A-116 et seq.) establishes the CAMA
                                        ervation based on ecological consider-                              regulatory program to require a permit for all
                                        ations;                                                             development proposed within AECs. The list of
                               (3)      To insure the orderly and balanced use                              grounds upon which permits shall be denied (G.S.
                                        andpreservation of our coastal resources                            113A-120) includes the following-
                                        on behalf of the people of North Carolina
                                        and the nation;                                                                .-that the proposed development would
                               (4)      To establish policies, guidelines and                                          contribute to cumulative effects that
                                        standards for:                                                                 would be inconsistent with the guidelines
                                        (a) Protection, preservatior; and conser-                                      set forth in subdivisions (1) through (9) of
                                        vation of natural resources including but                                      the subsection. Cumulative effects are
                                        not limited to water use, scenic vistas,                                       impacts attributable to the collective
                                        end fish and wildlife; and management of                                       effects of a number of projects and
                                        transitional or intensely doveloped areas                                      include the effects of additional projects
                                        and areas especially suited to intensive                                       similar to the requested permit In areas
                                        use or development; as well as areas of                                        available for developnvnt in the vicinity.
                                        significant natural value;
                                        (b) The economic development of the                                 Subdivisions (1) through (9), referred to in regard
                                        coastal area, including but not limited to                          to cumulative impacts, contain other grounds for
                                        construcdor4 location and design of                                 permit denial, most of which relate to significant
                                        industries, port facilities, comnwrcial                             adverse envirom-nental impacts. This part of
                                        establishments and other developments;                              CAMA provides clear statutory authority for a
                                        (c) Recreation and tourist facilities and                           state-administered regulatory program to manage
                                        parklands;                                                          cumulative impacts.
                                        (d) Transportation end circulation pat
                                        terns for the coastal area including major                                     The second cumulative impacts manage-
                                        thoroughfares, transportation routes,
                                        navigation channels and harbors, and                                ment tool provided by CAMA is its land use
                                        other public utilities and facilities;                              planning requirement (G.S. 113A-109 et seq.).
                                        (9) Preservation and enhancement of the                             Development and adoption of a land use plan is
                                        historic, cultural, and scientific aspects of                       required for each county in the coastal area If a
                                        the coastal area,                                                   county fails to develop its own plan, the State
                                        (f) Protection ofpresent common4aw and                              must prepare a plan for it. All local land use
                                        statutory public rights in the lands and                            plans must be consistent with guidelines estab-
                                        waters of the coastal area:                                         lished by the Coastal Resources Commission
                                        (g) Any other purposes deemed neces-                                consisting of "statements of objectives, policies,
                                        sary or appropriate to effectuate the                               and standards to be followed in public and private
                                        policy of this Article.                                             use of land and water areas within the coastal
                                                                                                            area" (G.S. 113A-107(a)). The land use planning
                             It would be difficult to           develop a more          broad-              provision of CAMA, together with the authority to
                             based and complete statement of environmental                                  establish state guidelines, establishes statutory
                             management goals. Surely these goals incorpo-                                  authority for a coordinated state-local system of
                             rate a broad enough basis for cumulative impacts                               land use planning capable of including a strong
                             management. While this section of CAMA does                                    cumulative impacts management program.
                             not include specific reference to cumulative
                             impacts, the mandate for their management                                                 The third tool provided by CAMA for the
                             seems clear. Three more specific provisions of                                 implementation of cumulative impacts manage-
                             CAMA establish the tools necessary for cumula-                                 ment addresses the need for inter-agency and
                             tive impacts management.                                                       inter-governmental coordination. This is the
                                                                                                            requirement for consistency between local and
                                        The first of these is the CAMA regulatory                           state governments and among all state agencies.
                             program. Part 3 of CAMA (G.S. 113A-113 et seq.)                                Section 113A-111 requires that all CAMA permits
                             establishes Areas of Environmental Concern                                     be consistent with the applicable local land use
                             (AECs) as critical resource management areas in                                plan, which, in turn, must be consistent with the
                             which the full regulatory authority of the State                               State Guidelines. While seemingly circular, this
                             will be applied. The list of categories of areas                               important provision establishes the basis for a
                             that may be designated as AECs (G.S. 113A -                                    coordinated management system between state

                                                                                                                       Cumulative Impacts Management- Page 11

                    and local governments. Neither level of govern-                            sary structure and the willingness to pursue this
                    ment can legally violate the policies established                          difficult task.
                    by the other.
                              Section 113A-125 provides the basis for                          Organization and Capability
                    coordination among state agencies. It requires
                    that all regulatory permits issued by any state                                      Cumulative impacts management re-
                    agency for activities within the coastal area be                           quires a lead agency that will assume the respon-
                    administered in coordination and consultation                              sibility of on-going assessment and management
                    with the Coastal Resources Comn-dssion. Execu-                             planning and that will perform the inter-agency
                    tive Order 15, issued by Governor Hunt in 1977,                            and inter-governmental coordination necessary for
                    undergirds this requirement for inter-agency                               goal implementation. The legal mandates and
                    consistency by stating-                                                    programs of the NC CMP put it in a unique
                                                                                               position to perform this task. Some changes in
                                         All State agencies shall take                         emphasis will be necessary, however, to meaning-
                              account of and be consistent to the marl-                        fully implement a cumulative impacts manage-
                              mum extent possible with the coastal                             ment program in the North Carolina coastal area.
                              policies, guidelines and standards con-                          All of the provisions of CAMA and the CZMA will
                              tained in the State guidelines, with the                         need to be brought to bear in a coordinated
                              local land use plans developed under the                         fashion to achieve successful implementation.
                              mandate of the Coastal Area Management
                              Act; and with the North Carolina Coastal                                      CAMA Regulatory Program
                              Plan .. in all regulatory programs, use and
                              disposition of state-owned lands, finan-                                   The CAMA regulatory program is a
                              cial assistance for public facilities, and                       strong tool that already possesses the authority to
                              encouragement and location of major                              deny permits based on adverse cumulative im-
                              public and private growth-inducing facifi-                       pacts. It can be used as a mechanism for goal
                              fles.                                                            implementation in those areas in which activities
                    this is exactly the kind of inter-agency coordina-                         in AECs play a significant role in causing cumu-
                    tion required for implementation of a holistic                             lative impacts. Potential roles for the CAMA
                    cumulative impacts management program.'                                    regulatory program in managing cumulative
                                                                                               impacts are discussed in more detail later in this
                              Statutory authority for inter-agency                             report. Cumulative impacts, however, are land-
                    coordination is extended to federal agencies as                            scape-level phenomena that must be managed on
                    well by the consistency provisions of the Federal                          a regional basis. A regulatory program that
                    CZMA. Section 307 of the CZMA requires that                                applies to less than 5 percent of the land area
                    all federal activities, federally permitted activi-                        cannot be sufficient in itself to manage cumula-
                    ties, federally funded activities, and Outer Conti-                        tive impacts.
                    nental Shelf activities that affect any land or                                      Although the CAMA regulatory program
                    water use or natural resource of the coastal area                          applies to only a very small percentage of the
                    must be consistent with the state coastal manage-                          coastal area, it has historically been the subject of
                    ment program. Between CAMA and the CZMA,                                   a very high proportion of Coastal Resources
                    the inter-agency and inter-governmental coordi-                            Commission and Division of Coastal Management
                    nation required for cumulative impacts manage-                             time and attention. Of the 215 pages of rules in
                    ment is statutorily mandated and does not have                             Chapter 7 of the North Carolina Administrative
                    to depend entirely on voluntary cooperation.                               Code (the Chapter dealing with coastal manage-
                              The statutory authority of the NC CMP                            ment), 150 pages deal specifically with the regula-
                    to develop and implement a complete cumulative                             tory program. The demands and responsibilities
                    impacts management program appears to be                                   of the regulatory program, both in specificity of
                    entirely adequate. While some aspects of imple-                            rules required and staff time to conscientiously
                    mentation of these statutory provisions may need                           review permits, have necessarily resulted in a
                    to be changed from the way they have been                                  heavy emphasis on this aspect of the NC CMP.
                    interpreted in the past, the necessary legal au-                           Both the CRC and DCM will need to take a
                    thorities are in place. The remaining question is                          broader approach to management of the entire
                    whether the NC CMP and DCM have the neces-                                 coastal area in order to deal with cumulative
                                                                                               impacts.

                    Cumulative Impacts Management- Page 12

                               Although CAMA states that the State                          Federal agencies must also act in full
                       Guidelines for the coastal area "shall give particu-         cooperation and consistency with cumulative
                       lar attention to the nature of development which             impact management goals and policies. The
                       shall be appropriate within the various types of             federal consistency requirements of the CZMA are
                       areas of environmental concern," the Guidelines              meant to accomplish this, and the federal consis-
                       are defined in a much broader sense. as "objec-              tency program of the NC CMP is well-developed
                       tives, policies, and standards to be followed in             and fully operational. It will be necessary, how-
                       public and private use of land and water areas               ever, to develop enforceable policies for cumula-
                       within the coastal area" (G.S. 113A-107(a)). The             tive impacts management and to have them
                       CRC clearly has the authority to develop policies            incorporated into the federally-approved NC CMP
                       that apply to lands and waters throughout the                in order for federal consistency to apply.
                       coastal area, although that authority has been
                       used to only a very limited extent. Cumulative                       The NC CMP has the necessary legal
                       impacts management will require policies applica-            authorities to develop a comprehensive cumula-
                       ble to all of the coastal area that can be imple-            tive impacts management program and, with
                       mented through local land use planning and state             some changes to increase their effectiveness, the
                       and federal consistency.                                     necessary tools for goal implementation. The
                                                                                    next section describes what a cumulative impacts
                                       Land Use Planning                            management program in the NC CMP might
                                                                                    consist of and the actions DCM is taldng to
                                While cumulative impacts assessment                 develop the necessary capabilities.
                       and management planning are best addressed at
                       the regional scale, control of impacts is often best
                       achieved at the local scale (Hunsaker, 1993). The
                       state-local partnership basis of the NC CMP and
                       the land use planning program provide a strong
                       basis for managing cumulative impacts at the
                       local level. Current land use planning guidelines
                       (15A NCAC 7B) call for some degree of cumula-
                       tive impacts assessment by local governments in
                       preparing plan updates. There is no guidance on
                       how this is to be done, however, and, to date, no
                       adequate cumulative impacts analysis has been
                       included in any CAMA land use plan. There will
                       need to be some changes in the guidelines and in
                       the way land use plans are reviewed and certified
                       by the CRC in order to make the land use plan-
                       ning program an effective part of a cumulative
                       impacts management program.

                                     Consistency Provisions

                                As quoted in the previous section, CAMA
                       and Executive Order 15 require that permits
                       granted and actions carried out by all state
                       agencies be consistent with the policies of the
                       Coastal Management Program, including those
                       stated in local land use plans. Full implementa-
                       tion of this requirement is absolutely essential for
                       successful cumulative impacts management. All
                       involved agencies, as well as the local govern-
                       ment, must act in concert to implement cumula-
                       tive impacts management goals. If they do not,
                       even the most well-developed efforts to control
                       cumulative impacts will be thwarted (Contant
                       and Wiggins, 1991).

                                                                                            Cumulative Impacts Management- Page 13

                                                                                      The following model is proposed as the
                                                                              basis for development of cumulative impacts
                                                                              I
                                                                               anagement in the North Carolina coastal area.
                                                                              n
                    .....                               . ... .. .. ....      It is a modification of the Gosselink and Lee
                                                                               989) approach described in Section 1, incor-
                              ......................      ...... . .

                                   ...... .......
                                                                              porating risk assessment as the first step and the
                                                                              mandates and management tools of the NC CMP
                                                                              into the implementation phases.

                                                                                        Relative Risk Assessment

                                                                                      Comparing conditions in relative-
                                                                                      ly small landscape units to iden-
                                                                                      tify specific areas at highest risk
                                                                                      of adverse cumulative impacts.

                                                                                          Classification of Risks

                                                                                      Identifying specific classes of
                                                                                      high risk areas based on current
                                                                                      conditions and causative factors
                                                                                      present in each landscape unit
                                                                                      and categorizing the landscape
                                                                                      units based on each area's partic-
                                                                                      ular class of risk.

                                                                                                Goal Setting

                                                                                      Establishing speciftc manage-
                                                                                      ment goals for each high risk
                                                                                      class based on the nature of the
                                                                                      risks and conditions present.

                                                                                      Identification of Appropriate
                                                                                      Implementation Mechanisms

                                                                                      Choosing from among the man-
                                                                                      agement tools available in the
                                                                                      NC CMP the most applicable
                                                                                      alternative or combination of
                                                                                      alternatives for each high risk
                                                                                      class.

                                                                                              Implementation

                                                                                      Development of specific policies,
                                                                                      rules, etc., applicable to each
                                                                                      class of high risk area that will
                                                                                      serve as implementation mecha-
                                                                                      nisms for cumulative impacts
                                                                                      management.

                                                                                      The remainder of this Section discusses
                                                                              each step of the cumulative impacts management
                                                                              model in more detail and describes specific
                                                             F

                    CC7

                                                                              actions to be taken to apply the model to the
                                                                              North Carolina coastal area.

                Cumulative Impacts Management- Page 14

                      Relative Risk Assessment                                             Although cumulative impacts on coastal
                                                                                   resources include the effects of activities outside
                               Comparing conditions in relatively                  of these twenty counties, direct management by
                               small landscape units to identify spe.              the NC CMP is limited to this region. A cumula-
                               cific areas at high Fish ofadverse cu-              tive impacts management program must, similar-
                               mulative impact&                                    ly, be limited to the statutorily defined coastal
                                                                                   area if it is to follow the legal mandate of CAMA
                               The concept of relative risk assessment             and utilize the management tools discussed in the
                      has been discussed in Section 1. The method has              previous section. Any cumulative impacts man-
                      been fairly well developed and applied in pilot              agement goals that include areas outside of the
                      studies to several areas by the EPA (Leibowitz,              twenty coastal counties would have to be imple-
                      Abbruzzese, et al., 1992), although the EPA pilot            mented through cooperative agreements with
                      studies were more narrowly focused on specific               other agencies.
                      types of cumulative impacts or on specific man-
                      agement purposes than the North Carolina                             The coastal area defined by CAMA is
                      application. The relative risk assessment ap-                certainly large enough and homogeneous enough
                      proach being applied to the North Carolina                   in its links to the ocean and sounds to form a
                      coastal area is an adaptation of the synoptic                logical region for cumulative impacts assessment.
                      approach developed by the EPA Environmental                  The total land area of the twenty coastal counties
                      Research Laboratory, although the general ap-                is 5,984,853 acres, or about 19 percent of the total
                      proach was proposed by DCM prior to its knowl-               land area of the state. Total water area of the
                      edge of the EPA methodology (DCM, 1992b).                    twenty counties is 2,236,912 acres, or about 87.5
                                                                                   percent of the total open water area of the state.
                               In the North Carolina model  ' the relative         The relative risk assessment approach requires
                      risk assessment consists of four steps: (1) dividing         that this large region be divided into smaller
                      the assessment region into discrete landscape                units for risk assessment.
                      units that can be compared with one another; (2)
                      gathering data for each landscape unit that will                     Historically, subdivisions of the coastal
                      serve as indicators of environmental quality and             area have been based on political jurisdictions:
                      of the risk of adverse cumulative impacts; (3)               the twenty counties and their constituent munici-
                      developing a series of indices based on the indica-          palities. These are the geographic units of local
                      tor data to quantify relative risk; and (4) applying         government operation and land use planning as
                      the indices to identify landscape units at high              established by CAMA. Using these same subdivi-
                      risk compared with other units.                              sions as the landscape units for cumulative
                                                                                   impacts risk assessment would have the advan-
                                       Landscape Units                             tages of familiarity, historical precedent, data
                                                                                   availability, and congruence of analytical units
                               CAMA defines the coastal area of North              with government management units. There
                      Carolina as consisting of the twenty counties                would, however, be significant disadvantages as
                       adjacent to, adjoining, intersected by or bounded           well. Using county boundaries would divide the
                      by the Atlantic Ocean or any coastal sound" (G.S.            area into only twenty units, a scale too coarse for
                      113A-103(2)). Together with a specific definition            adequate analysis. Several of the coastal counties
                      of coastal sound, this defines an area with clear            are quite large, and conditions vary widely within
                      boundaries that includes all coastal shorelands              them. Most of the municipalities in the coastal
                      and those areas directly linked to coastal water             area, on the other hand, are small, and much of
                      quality. Although the definition is based on                 the land area is not included within any munici-
                      political boundaries, it generally coincides with            pal boundary. Perhaps the most significant
                      accepted geological and biological boundaries.               disadvantage is that political boundaries do not
                      The coastal area includes that region of the state           coincide with the natural processes and functions
                      designated as the tidewater region on physio-                that are affected by cumulative impacts.
                      graphic and geologic maps and that was inundat-
                      ed by the last Pleistocene sea level rise. The                       Watersheds are ecological landscape units
                      counties included are those where elevations are             that correspond to the operation of water-based
                      generally less than 30 to 40 feet above sea level,           natural processes.     Since water quality and
                      where drainage is poor, and where there are                  fisheries are major concerns of the NC CMP and
                      discernible effects of salt water (NOAA, 1978).              both are dependent on water-based processes,
                                                                                   watershed units are congruent with existing

                                                                                           Cumulative Impacts Management- Page 15

               n@anagement objectives. DEM's basinwide plan-                 Analysis (CGIA) for digitization of hydrologic unit
               ning is based on watersheds, and analyses have                (HU) boundaries for the coastal area.
               been performed in the APES program for several
               coastal sub-basins (Dodd, McMahon, & Stichter,                        Digitization was completed in early 1993,
               1992; Dodd, Cunningham, et aL, 1992). Using                   resulting in division of the twenty coastal coun-
               watersheds as landscape units would provide                   ties into 348 hydrologic units which will be the
               congruence with existing state management                     basic landscape units for cumulative impacts
               programs and would take advantage of data that                assessment and management. As the boundaries
               have already been collected. Water quality is an              of these HUs were being delineated, representa-
               integrating indicator of the cumulative impacts of            tives of DEM, SCS, and CGIA met regularly to
               all activities in a watershed. A watershed-based              review the boundaries and ensure that they were
               approach to data gathering and analysis provides              consistent with DEM sub-basin boundaries and
               an ecologically sound framework for many aspects              USGS cataloging unit boundaries. The fourteen-
               of coastal management.                                        digit HUs are subsets of eleven-digit HUs, which
                                                                             are subsets of USGS cataloging units. Data
                       Watershed units have been used in                     pertinent to cumulative impacts will be gathered
               several cumulative impacts assessments (Bedford,              and analyzed for each fourteen-digit HU, but can
               1990; Johnston, et al., 1988; Gosselink, et al.,              be aggregated into larger watershed units as
               1990; Leibowitz, Abbruzzese, et al., 1992). These             needed for analytical or management purposes.
               have varied in size from river basins of several
               hundred square miles to small creek watersheds                       Landscape Indicators and Indices
               of a few thousand acres. If watersheds are to be
               the basic landscape units for cumulative impacts                      Landscape indicators are estimable
               assessment in the coastal area, several possible              values  that reflect some aspect of landscape
               breakdowns exist. There are seventeen major                   condition or status. In cumulative impacts risk
               river basins in North Carolina, seven of which                assessment, indicators are needed for both causes
               include portions of the coastal area (DEM, 1991).             and effects of cumulative impacts, as well as for
               River basins are divided by the U.S.Geological                the relative sensitivity of landscape units to
               Survey (USGS) into cataloging units, identified by            disturbance. Causes include all forms of human-
               an eight-digit code. There are sixteen cataloging             induced disturbance to natural processes, and
               units included in whole or in part in the twenty              effects include all forms of response of natural
               coastal counties. River basins were divided more              processes to the imposed disturbances. Land-
               finely into sub-basins by DEM in the 1970s for                scape indicators are not necessarily measure-
               tracking point source discharge information. For              ments of the actual causes and effects themselves,
               the APES portion of the coastal area, these sub-              but of some parameter that indicates the intensi-
               basins have been divided into still smaller sub-              ty of causes and effects.
               basins (Dodd, McMahon, and Stichter, 1992). The
               Soil Conservation Service (SCS) also divided                          For example, the water quality of some
               USGS cataloging units into smaller watersheds                 coastal streams is degraded by agricultural
               f6r its watershed management programs, desig-                 runoff. Actual causes of the degradation are
               nating each of these watersheds by an eleven                  specific quantities of nutrients, toidns, and sedi-
               digit code.                                                   ment that enter the water in runoff. Useful
                                                                             indicators of these causes may include the rela-
                       All of these existing watershed break-                tive area of agricultural land in the watershed,
               downs were considered staff as possible landscape             the proportions of this land under various agricul-
               units for cumulative impacts analysis, and even               tural management practices, annual fertilizer
               the smallest units, the SCS eleven-digit water-               purchases, numbers of different types of livestock,
               sheds, were determined to be too large to be                  etc. The actual direct effects of the causes are
               adequate. During 1992, coincident with DCM`s                  specific concentrations of the various substances
               initial planning for cumulative impacts analysis,             in the water. Useful indicators may include such
               SCS began a statewide project to map still small-             things as the relative length of the stream classi-
               er watersheds, or hydrologic units of 5,000 to                fled as non-supporting of designated uses, num-
               50,000 acres designated by a fourteen-digit code              bers of algal blooms or fish kills, area or time of
               (SCS, 1992). Since this scale seemed appropriate              shellfish closures, etc.
               for cumulative impacts risk assessment, DCM
               participated in this project and provided funds to                    The causes of cumulative impacts include
               the NC Center for Geographic Information and                  all human disturbances in the landscape unit. In
                                                                             an area as large as the North Carolina coastal

               Cumulative Impacts Management- Page 16

                       area, many different human activities occur that               Resources Information System (PDRIS), was
                       have the potential for disturbing natural process-             developed by DCM in cooperation with Research
                       es, It would be impossible to specify and develop              Triangle Institute- The PDRIS was developed
                       indicators for every possible activity. It is neces-           primarily for the purpose of tracking, analyzing
                       sary, instead, to use broad indicators of the                  and reporting trends in population growth, devel-
                       intensity of major land uses and human-induced                 opment, and environmental quality in the coastal
                       pressures. Such indicators as population size and              area. The database is interfaced with a GIS so
                       growth rate, percentage of total area in various               that information can be viewed and analyzed
                       land uses, intensity of management of land areas,              spatially. The database is designed to allow
                       numbers of specific impact-inducing activities                 periodic updating so that it can be kept current
                       present, etc., can be used to compare the intensity            and used for trends analysis over time.
                       of human-induced pressures among landscape
                       units.                                                                  This database will contain detailed
                                                                                      information about conditions and trends in each
                                Likewise, the effects of cumulative im-               HU. Since the PDRIS is meant to serve several
                       pacts include all changes in environmental condi-              purposes, not necessarily all of the parameters
                       tions, species populations, and ecosystem dynam-               will be used as indicators for cumulative impacts
                       ics that have occurred as a result of human                    risk assessment. A subset will be chosen for their
                       actions. It is not possible to develop an indicator            value in adequately reflecting conditions and
                       for every effect. Broad indicators of environmen-              trends in each HU in regard to land use, natural
                       tal quality, such as water and air quality mea-'               resources, environmental quality, and population
                       surements, proportion of the landscape in a                    growth and development pressure.
                       disturbed vs. natural state, and condition of
                       wildlife populations, must be used to reflect the                       In raw form, the indicators would be
                       many specific effects that may exist.                          difficult to compare in a straight-forward fashion
                                                                                      to identify HUs at highest risk of significant
                                The extent to which a landscape unit is               cumulative impacts of development. A series of
                       at risk of degradation by human activities de-                 indices will be developed to summarize the signif-
                       pends upon the sensitivity, or buffering capacity,             icance of the indicators and to facilitate relative
                       of the landscape to disturbance.           Sensitivity         risk assessment. These risk indices will be used
                       depends upon such factors as the types of ecosys-              as the basis for a quantitative assessment of each
                       tems present and their distributions, soil types,              HU to determine the relative risks and nature of
                       slope, water source, primary and secondary                     the risks present. High risk HUs identified by
                       productivity, etc. Once again, it is impractical to            this method will then be classified into different
                       develop indicators for every factor contributing to            categories based on the nature of the risk that
                       landscape sensitivity. The presence and relative               resulted in their high risk status.
                       concentrations of resources known to be sensitive
                       to disturbance, such as endangered species habi-               Classiftation of Risks
                       tat and submerged aquatic vegetation, or of
                       resources recognized as being of particular impor-
                       tance, such as nursery areas, important wetlands,                       Identifying specific categories ofhigh
                       high quality waters, etc., can be used as indica-                       risk areas based on conditions and
                                                                                               causative factors present in each
                       tors of relative sensitivity.      The presence of                      landscape unit and classifying the
                       characteristics known to buffer the effects of                          landscape units based on each area's
                       human disturbance, such as vegetated streamside                         particular type of risk.
                       buffers, can also indicate relative landscape
                       sensitivity.                                                            Many combinations of natural environ-
                                                                                      mental   conditions and human activities may
                                Based on these considerations, data                   result   in environmental degradation.          Thus,
                       availability, and potential usefulness, a list of              different areas may be at high risk of experienc-
                       indicators has been developed for the North                    ing significant adverse cumulative impacts for
                       Carolina coastal area. Indicators are summarized               different reasons.     Choice of an appropriate
                       in Table I, and a complete list of indicators is               cumulative impacts management strategy will
                       included in Appendix A. These parameters are                   depend upon the specific conditions in a given
                       included in a database containing indicator values
                       for each Hydrologic Unit and each coastal county.
                       This database, the Population/Development/

                                                                                               Cumulative Impacts Management- Page 17

                                        TABLE 1. SUMMARY OF HYDROLOGIC UNIT INDICATORS
                         Class of Information-F-                                       Type of Indlcators                                      Update

                    Constant Values                              HU identification, size, land & water areas, stream and waterbody             None
                                                                 names, historical census data

                    Surface Water Quality                        Water classifications of streams & waterbodies, use support class-            Periodic
                                                                 es, number & extent of degradation incidents

                    Groundwater Quality & Use                    Groundwater classification, capacity use designations, oontarnina-            Periodic
                                                                 ton incidents

                    Shellfish Waters                             Shellfish water areas, closures                                               Annual

                    Land Use & Resources                         Land cover and land use, extent of sensitive resources such as                Periodic
                                                                 anadromous fish areas, nursery areas, endangered species, etc.,
                                                                 land and water areas in public ownership and private preservation
                    Population & Housing                         Census-derived population and housing information                             Periodic
                    Municipalities                               Number & names of municipalities in seven size classes                        Periodic
                    Development                                  Highway and railroad mileage, building permits                                Annual
                    Economic Activity                            Number, employment, and revenues of businesses in various                     Annual
                                                                 classes

                    Agricultural Practices                       Extent & importance of various crops and livestock, BMPs                      Annual

                    Permitsissued                                CAMA, NPDES, non-discharge, septic tank, air emission, 404/10,                Annual
                                                                 landfill, sedimentation control plans

                  HU, including the environmental characteristics                           Based on consideration of these general principles
                  of the HU, the degree and type of human distur-                           and the specific conditions of coastal North Caro-
                  bance present, and the effects the particular                             lina, several potential classes of Cumulative
                  disturbances may have on the environment. The                             Impact High Risk Areas can be identified.
                  Risk Assessment step of the Cumulative Impacts
                  Management Model consists of characterizing                                           High Risk Area Categories
                  these conditions. The Risk Classification step
                  consists of grouping high risk areas into catego-                              (1) HUs with impaired water quality
                  ries based on those conditions so that the most
                  appropriate management strategy can be deter-                                  (2) HUs with high potential for water quality
                  mined.                                                                               impairment

                            Certain general principles about cumula-                             (3)   HUs with present or potential air quality
                  tive impacts risk give a useful starting point for                                   impairment
                  risk classification. An area may be at high risk of
                  adverse cumulative impacts due to either the                                   (4)   HUs with historic high growth in popula-
                  nature of its natural environment or the nature                                      tion /development
                  and extent of human-induced disturbances. An
                  area may already be experiencing environmental                                 (5)   HUs with anticipated high population-
                  degradation or it may have a high potential for                                      /development growth
                  future degradation if certain human activities
                  occur. High rates of population growth and                                     (6)   HUs with concentrations             of sensitive,
                  development in an area are likely to result in                                       high-value resources
                  significant cumulative impacts even if current
                  measures of degradation do not identify them.                                  (7)   HUs with concentrations of produc-
                                                                                                       tive laesthetic resources

                  Cumulative Impacts Management- Page 18

                                     These potential categories of Cumulative                                 The economic development of the coastal
                          Impact I-Iigh Risk Areas are discussed in more                                      area...
                          detail in Section 4 of this report. This list is
                          preliminary and based on professional judgement                                     The first goal setting step consists of
                          before the actual risk assessment is performed.                          applying these basic principles to each category of
                          Some of these categories may not actually exist in                       high risk area to develop more specific goals
                          the NC coastal area, and other as yet unidentified                       based on the nature of the risks present. For
                          categories may. But this a priori list is indicative                     example, the following goals for the potential high
                          of the type of classification that will be per-                          risk area categories listed above follow directly
                          formed.                                                                  from the general goals of CAMA.
                          Goal Seffing                                                                 HUs With Present or Potential Water
                                                                                                                    Quality Impairment

                                     Establishing specific management                                         To improve water quality so as to
                                     goa4 consistent with the goals of                                        preserve the ecological conditions,
                                     C"A and the NC CMP, for each                                             natural productivity, and biological
                                     high risk class based on the nature of                                   and economic value of the estuarine
                                     the risks and conditions present.                                        system.
                                     The primary goals of cumulative impacts                                  To maintain traditional water uses.
                          management in the North Carolina coastal area                                       To insure that land development and
                          must coincide with the overall goals of the NC                                      water use occurs in a manner consis-
                          Coastal Management Program. The following                                           tent with the ecological capability of
                          excerpts from CAMA!s statement of goals (G.S.                                       the aquatic system to sustain its po-
                          113A-102(b)) are the guiding principles upon                                        tential uses.
                          which more specific management goals are to be                                 HUs With Present or Potential Air
                          based.     To provide a management system capa-                                           Quality Impairment
                                     ble of preserving and managing the                                       To improve air quality so an to safe-
                                     natural ecological conditions of the                                     guard and perpetuate the biological,
                                                                                                              economic and aesthetic values of the
                                     estuarine systank the barrier dune sys-                                  area.
                                     tem, andbeaches, so as to safeguard and
                                     perpetuate their natural productivity and                                To protect and preserve high air
                                     their biological, economic and aesthetic                                 quality.
                                     values;..
                                                                                                              To guide economic development so
                                     To insure that the development or preser-                                as to minimize significant atmosphe.
                                     vation of the land and water resources of                                ric emissions.
                                     the coastal area proceeds in a manner                             HUs With Historic or Anticipated High
                                     consistent with the capability of the land                    PopulationlDevelopment Growth
                                     and water for development use, or pres-
                                     ervation based on ecological consider-                                   To emphasize guiding        development
                                     ations..                                                                 so as to insure that it occurs in a
                                                                                                              manner consistent with land and wa-
                                     To insure the orderly and balanced use                                   ter capability for development, use
                                     and preservation of our coastal re-                                      or preservation.
                                     sources...
                                                                                                              TO guide development toward those
                                     Protactiot; preservation, and conserve-                                  areas well suited for intensive use
                                                                                                              and away from areas of significant
                                     don of natural resources..                                               natural value.

                                     Management of transitional or intensely                                  To insure the orderly     and balanced
                                     developed areas and areas especially                                     use of resources.
                                     suited to intensive use or developmen4                                   To protect and preserve natural re-
                                     so well as areas of significant natural                                  sources in the face of continued
                                     value..                                                                  growth and development.

                                                                                                              Cumulative Impacts Management- Page 19

                          To recognize and plan for needed in-                               tion Control Program and require
                                                                                             application of additional NPS control
                          creases in local services and infra-
                          structure required to provide for a                                measures.
                          growing population.
                                                                                             Assist the local government in ac-
                    HUs With Concentrations of Sensitive,                                    quiring funds to expand the extent of
                                                                                             sewer lines in the EW and to upgrade
                               High-Value Resources                                          sewage treatment facilities.

                          To protect and preserve the biologi-                               Decrease allowable discharges from
                          cal and economic values of sensitive                               upstream dischargem
                          natural systems.
                                                                                             Discourage the use of septic tanks by
                          To guide development away from                                     limiting their use to highly suitable
                          areas of significant natural value.                                soils and requiring a setback from all
                                                                                             open water.
                  HUs With Concentrations of Productive
                              or Aesthetic Resources                                         Increase protection and restoration
                                                                                             of wetlands particularly effective in
                          To encourage the management of                                     improving water quality.
                          lands for their most biologically and                              These are just examples of the types of
                          economically productive uses.
                                                                                   specific  objectives that may be applicable to a
                          To protect scenic vistas and the aeo-                    given high risk area. The appropriate objectives
                          thetic quality of the area.                              for a specific HU would depend upon the sources
                          To guide land development toward                         of water quality degradation and the particular
                          areas well suited for development                        mix of land uses, discharges, and development
                          and away from areas better suited                        patterns present in the HU. This list of examples
                          for agriculture, forestry, or other                      illustrates the fact that several different imple-
                          natural resouree-related use.                            mentation mechanisms may be useful or neces-
                          The final step of the goal-setting process               sary in order to achieve the objectives. Analysis
                                                                                   of alternative implementation mechanisms is the
                is translating these general goals into specific                   next step in the Cumulative Impacts Manage-
                management-oriented objectives.             Since these            ment Model.
                specific objectives normally include or imply an
                implementation mechanism, development of
                specific objectives is also the first stage of imple-              Identification of Appropdate
                mentation of cumulative impacts management.                        Implementation Mechanisms
                Each general goal is likely to involve several
                objectives that will be specific to the conditions in                        Choosing from among the manage.
                the high risk area. For example, in a high risk                              ment tools available in the NC Coast.
                a .rea with impaired water quality, the first gener-                         al Management Program the most
                al goal is to improve water quality. Specific                                applicable alternative or combina-
                objectives under this goal might include the                                 tion ofalternatives for each high risk
                following.                                                                   class.
                          Protect estuarine waters from silt                                 The risk classification and goal-setting
                          and nutrient runoff by requiring a                       steps characterize the nature of the situation in
                          vegetated buffer in all CAMA permits                     each high risk area and set forth specific goals for
                          in the Estuarine Shoreline AEC.                          cumulative impacts management. These point
                          Require vegetated buffers along all                      toward the identification of appropriate imple-
                          tributary streams in local land use                      mentation mechanisms, since goals are stated in
                          plans and zoning'and subdivision                         terms of achievable management strategies. The
                          ordinances.                                              most appropriate set of implementation mecha-
                                                                                   nisms will vary for different classes of high risk
                          Target the EnJ for agricultural BMF                      areas and, to some extent, among individual HUs
                          installation under the Agricultural                      within a risk class.
                          Cost Share program.

                          Designate the EITJ as a Critical Area
                          under the Coastal Nonpoint P*Uu-

                Cumulative Impacts Management- Page 20

                               The CAMA Regulatory Program                                  The necessary coordination for water
                                                                                   quality management ran be achieved through
                              The CAMA regulatory program clearly                  including DENfs Basinwide Planning Program
                       has the statutory authority to deny permits for             and the Coastal Nonpoint Pollution Control Pro-
                       projects that would contribute to adverse cumula-           gram in the cumulative impacts management
                       tive impacts. The purpose of AEC designation is             strategy. State consistency can also be used in
                       to apply state-level control over development in            implementation of cumulative impacts manage-
                       areas identified as critical resource management            ment in any situation in which implementation
                       areas of greater than local concern (NOAA 1978).            through the regulatory or management programs
                       In so far as adverse cumulative impacts can be              of other state agencies is necessary to achieve
                       considered to be of greater than local concern, the         specific objectives.
                       CAMA regulatory program is directly applicable
                       to their management. There are at least three                             Federal Consistency
                       approaches toward using the CAMA regulatory
                       program as an implementation mechanism for                           Implementation of cumulative impacts
                       cumulative impacts management: (1) development              management through programs of federal agen-
                       of specific standards for cumulative impacts                cies is possible through the federal consistency
                       assessment in CAMA permit considerations; (2)               requirements of the CZMA. DCM plays an active
                       development of AEC use standards specifically               role in influencing federal actions and pern-dt and
                       applicable to high risk areas; and (3) designation          funding decisions through its federal consistency
                       of additional AECs in high risk areas. These                program. In high risk HUs in which the federal
                       mechanisms would apply to high risk HUs in                  government owns substantial amounts of property
                       which the risk is associated with actions occur-            or in which federal activities or permit decisions
                       ring in areas within present or statutorily-                are critical in implementing cumulative impacts
                       authorized AECs.                                            management, federal consistency can be an
                                                                                   effective implementation mechanism.
                                      Land Use Planning                                  Special Area Management Planning
                               Managing the cumulative impacts of
                       development is largely a matter of managing the                      Special Area Management Planning
                       development itself. Outside of AECs, land use               (SAMP) is a specialized process which may be
                       planning and control will be a primary component            used to address complex multi-jurisdictional
                       of cumulative impacts management. The CAMA                  environmental problems through cooperative
                       land use planning program provides several                  regional management. In a sense, DCM's entire
                       potential implementation mechanisms whereby                 cumulative impacts management effort, and even
                       local government determination of development               the entire Coastal Management Program, are
                       types, patterns, and intensities can be used to             forms of SAMP. Normally, however, the term is
                       minimize cumulative impacts. These mechanisms               applied to localized, more narrowly-focused
                       will be identified and applied through improve-             planning and management programs to address
                       ments to the land use planning process, particu-            highly complex situations that are beyond the
                       larly as it applies to high risk areas.                     scope of other managemen      't mechanisms. As
                                                                                   such, it may be an implementation mechanism for
                                   Interagency Coordination                        cumulative impacts management in high risk
                                                                                   areas with problems so complex and involving so
                               Many of the specific objectives for cumu-           many multi -jurisdictional issues that a coordinat-
                       lative impacts management will require imple-               ed approach through other implementation
                       mentation through programs of other state agen-             mechanisms is impossible. Whether there are
                       cies. The above illustrative list of possible objec-        any such high risk areas in the NC coastal area
                       tives for an HU with impaired water quality                 is yet to be detern--dned.
                       would involve the cooperation of at least four
                       distinct agencies for implementation.          Inter-
                       agency cooperation and coordination is an essen-
                       tial component of cumulative impacts manage-
                       ment in all high risk areas, but particularly in
                       those involving water and air quality concerns.                      Cumulative Impacts Management- Page 21

                 Implementation                                              policies. If Special Area Management Planning is
                                                                             used as an implementation mechanism, the
                        Development of specific policies,                    special area under jurisdiction of the plan would
                        ndes@ etc., applicable to each class of              have its own unique set of rules and policies.
                        high risk area that will serve as i7m
                        plementation mechanisms for cumu-                            The concept of applying different policies
                        lative impacts management.                           to areas that differ in their characteristics or
                                                                             management needs is not foreign to the NC CMP,
                        Implementation means taking action, and              even though its use has been limited. Different
                 government action requires enforceable policies             rules apply to AECs than to non-AECs, and
                 and rules. Application of the implementation                somewhat different rules apply to the estuarine
                 mechanisms identified in the previous step to               shoreline AEC around Outstanding Resource
                 management of specific cumulative impacts                   Waters than to the same AEC bordering other
                 situations will require some changes in existing            estuarine waters. The underlying principle is the
                 rules and policies of the NC CMP. It would be               same: that some areas need to be managed
                 premature to attempt to discuss the specific rule           differently from others because of their intrinsic
                 changes that might be needed, since this will               qualities, the hazards associated with their
                 require detailed analysis of the current rules in           uncontrolled use, the nature and intensity of
                 light of the management needs that become                   development occurring in them, or because they
                 apparent as a result of risk analysis and goal              have been recognized as of greater than local
                 setting. It is possible, however, to identify some          concern. The possibility of applying different
                 general areas of change that will be necessary to           rules to different areas has been recently dis-
                 apply the Cumulative Impacts Management                     cussed by CRC conunittees in relation to marina
                 Model successfully.                                         siting and land use planning requirements. Use
                        The Model is based on an approach of                 of the approach in cumulative impacts manage-
                                                                             ment is a similar context.
                 identifying specific geographic areas at high risk
                 of adverse cumulative impacts and applying                          Application of specific rules to high risk
                 specific management strategies to those high risk           areas will necessitate some means of formal
                 areas. This approach necessarily entails applying           designation of these areas by the CRC. Identifi-
                 different strategies, and thus different rules, to          cation of high risk areas through the risk assess-
                 high risk areas than are applied to other areas.            ment process will not, in itself, provide the neces-
                 Historically, the NC CMP has applied one set of             sary authority to apply different rules to these
                 rules uniformly throughout the coastal area.                areas. Some form of ratification by a policy-
                 Although different rules apply to AECs than to              making body is necessary. This designation could
                 non-AEC areas, use standards within a given                 be performed on an area-by-area basis, analogous
                 AEC category are the same where ever the AEC                to the designation of natural and cultural re-
                 occurs. As the above examples indicate, applica-            source area AECs, or it could be performed on a
                 tion of the Cumulative Impacts Management                   regional basis analogous to the way in which
                 Model would involve different use standards for             other AEC categories were established.
                 AECs in high risk areas than for those in other
                 areas.                                                              It must be stressed, however, that high
                                                                             risk areas are not envisioned to be a type of AEC.
                        Similar differences will likely be neces-            No permits would be required for activities in
                 sary for other implementation mechanisms, as                high risk areas other than those already required
                 well. Land use planning, for example, should                by existing regulatory programs; the standards
                 logically be more comprehensive in areas under-             for those permits would simply be different.
                 going intensive development than in rural areas             Activities not currently requiring a permit would
                 where little growth and development are occur-              not require a permit in a high risk area; they may
                 ring. An activity requiring another state or                simply be subject to more stringent local land use
                 federal permit (and thus subject to state or                considerations. Designation of an HU as a high
                 federal consistency requirements) that may be               risk area is meant to identify it as an area in
                 perfectly acceptable in some areas may not be               need of additional management attention by
                 desirable in a high risk area. Implementation of            whatever implementation mechanism is most
                 these different management strategies will neces-           appropriate for its particular situation, not as an
                 sitate the application of different rules and               area needing a new regulatory program.

                 Cumulative Impacts Management- Page 22

                              Since high risk areas will not, in them-
                      selves, be AECs, cumulative impacts management
                      Will require renewed attention to coastal area
                      wide policies applicable to areas outside of AECs.
                      Some cumulative impacts problems may be
                      amenable to management entirely through AEC
                      use standards, but many are likely to require
                      other implementation mechanisms. Management
                      through land use planning and state and federal
                      consistency requires policies that are applicable
                      outside of AECs. These may be parts of the land
                      use planning guidelines governing the ways local
                      governments perform the planning process,
                      policies applicable to permits granted or actions
                      taken by other state or federal agencies, or poli-
                      cies specifically applicable to an area for which a
                      special area management plan has been prepared.
                      Policies will need to be incorporated into 15A
                      NCAC 7B or 7M, must be specific enough to be
                      enforceable, and must receive OCRM approval as
                      part of the NC CMP. Without policies to allow
                      implementation of cumulative impacts manage-
                      ment outside of AECs, the management effort will
                      be severely limited.

                              Implementation through local land use
                      planning and control may also require recognition
                      of the fact that some land use decisions are of
                      greater than local concern. Since cumulative
                      impacts management is regional in scope, such
                      decisions cannot be made on the basis of purely
                      parochial considerations. Certain policies for high
                      risk areas may need to be required in local land
                      use plans, whether the local government recogniz-
                      es the need for them or not. Local implementa-
                      tion of those policies through zoning, subdivision
                      ordinances, and other land use controls will be
                      needed to supplement state-level implementation
                      through permit decisions. To fully achieve local
                      implementation, CAMA may need to be amended
                      to require consistency of local ordinances and
                      decisions with land use plans.

                                                                                          Cumulative Impacts Management- Page 23

                                                                                                                    The Risk Classification step of the Cumu-
                               O@m
                            P                                                                           lative    Impacts Management Model consists of
                                                                                                        identifying different categories of high risk areas
                                                 K A                                                    and classifying each high risk unit into one of the
                                                                                     ..........
                                                                                                        categories. Since assignment to a risk category is
                                                                                      .........
                                                        ... .......
                                                .... ........
                                                                                .. .........
                                                                              . .........
                                                                              . .. .......
                                                                                      ........          based on conditions, causative factors, and mea
                                                                                                        surable impacts present in the landscape unit,
                                                                                                        the category classification forms the basis for
                                                                                                        choice of appropriate management strategies. In
                                                                                                        the discussion of risk classification in Section 3,
                                                                                                        seven potential categories of high risk area were
                                                                                                        identified. Although this list of categories is
                                                                                                        preliminary and may change after the risk assess-
                                                                                                        ment is completed, a more detailed discussion of
                                                                                                        these categories is useful in explaining and
                                                                                                        illustrating the Management Model. This section
                                                                                                        examines each of the seven a priori high risk
                                                                                                        categories in terms of conditions that may exist in
                                                                                                        an area included in the category, the types of
                                                                                                        risks that may be present, potential indicators of
                                                                                                        those risks, and potential management strategies.

                                                                                                        Areas wth Impaired Water Quality

                                                                                                                    Areas with evident environmental degra-
                                                                                                        dation are already experiencing recognizable
                                                                                                        adverse cumulative impacts. Water quality is the
                                                                                                        best available indicator of the cumulative impacts
                                                                                                        of all activities in a watershed. A Hydrologic
                                                                                                        Unit with degraded water quality, then, is clearly
                                L)                                                                      a high risk area. It is likely that enough HUs
                                                                                                        with existing water quality degradation will exist
                                                                                                        in the coastal area that such a risk category will
                                                                                                        be needed.

                                                                                                                    If there were water quality monitoring
                                                                                                        stations on each stream in each HU, it would be
                                                                                                        easy to identify HUs with impaired water quality.
                                                                                                        Indicators could be developed by establishing
                                                                                                        thresholds for various water quality measure-
                                                                                                        ments beyond which the water would be consid-
                                                                                                        ered to be imparied. Vvrithout specific measure-
                                                                                                        ments for each stream, however, other parame-
                                                                                                        ters need to be used as indicators of water quality
                                                                                                        degradation. Several potential indicators exist.

                                                                                                                    Surface waters in the state are classified
                                                                                                        by the EMC according to their best uses based on
                                                                                                        existing and attainable uses and water quality
                                                                                                        (15A NCAC 2B .0100-.0200). Each classification
                                                                                                        requires that certain water quality standards be
                                                                                                        met in order to support the assigned uses. If
                                                                                                        water quality falls below those standards, the
                             (0

                                                                                                        stream is classified as partially-supporting or

                    Cumulative Impacts Management- Page 24

                      non-supporting of its designated uses or as                          If the HU contains estuarine waters
                      support-threatened. DEM maintains records on                subject to impairment from stormwater runoff,
                      the degree of use support of most streams in the            use standards for the Estuarine Shoreline AEC
                      state. These use support designations can be                could be used to provide protection. Require-
                      used as indicators of water quality in'an HU. If            ments for an undisturbed vegetated buffer along
                      the percent of non-supporting or partially-                 the estuarine shoreline and/or engineered storm-
                      supporting waters in an HU exceeds a certain                water control structures could be included as
                      level, then the HU can be classified as having              CAMA permit conditions for all development in
                      impaired water quality.                                     the AEC within the high risk HU. The amount of
                                                                                  impervious surface could be limited to less than
                              Other indicators, while less direct, may            the 30 percent general limitation, or the total
                      also be useful in identifying -areas with degraded          percentage of built-upon area could be limited as
                      water quality. Classification of shellfish growing          in the ORW Estuarine Shoreline rules. The
                      waters by the Division of Environmental Heal      th        width of the Estuarine Shoreline AEC could be
                      is based on point sources of contamination, fecal,          increased in water-quality high risk areas to
                      pathogenic or toxic contamination, and fecal                increase the effectiveness of these protective
                      coliform counts (10 NCAC 10B .1400). If any of              measures.
                      these conditions reaches a level in the water at
                      which consumption of shellfish taken from the                        Vegetated buffers to filter runoff water
                      .water may be deleterious to human health, the              may also be needed along tributary streams and
                      water is classified as restricted or prohibited             non-estuarine waters. This could be implemented
                      (closed) for shellfish harvest. The percentage of           by means of additional AEC designations. CAMA
                      shellfishing waters in an HU that are closed to             authorizes designation of AECs along the shore-
                      shellfishing can be used as an indicator of im-             line of public trust waters and in floodways and
                      paired water quality. Similarly, the number of              floodplains (G.S. 113A-113(b)(6)). Such AECs
                      events in an HU indicating possible contamina-              could be established in water quality high risk
                      tion, such as algal blooms and fish kills, can be           areas for the sole purpose of protecting water
                      used as indicators of short-term water quality              quality through vegetated buffers or density
                      impairment.                                                 limitations.

                              The causes of water quality impairment                       Vegetated buffers along waterways could
                      reflected by these indicators include high levels of        also be required in local zoning, subdivision, and
                      toxins, pathogenic organisms or nutrients, or low           sedimentation and erosion control ordinances.
                      levels of dissolved oxygen in the water. These              The CAMA land use planning guidelines could be
                      c@onditions -may result from identifiable point             amended to require that buffer areas be included
                      sources of pollution, from storm water rtmoff from          in the conservation land use class with appropri-
                      agricultural or developed lands, or from other              ate limitations on their use. Except for actions in
                      unidentified sources of contamination. Pollutants           which state or federal permits are involved,
                      may enter an HU in flowing water from upstream              however, enforcement of use limitations in buffers
                      sources or may originate in the HU itself. Analy-           would be by the local government. Unless CAMA
                      sis of permitted point source discharges, non-              were amended to require consistency between
                      discharge permits foron-site wastewater disposal,           land use plans and local ordinances, implementa-
                      and types and intensities of land use in the HU             tion of buffer protection would not be ensured.
                      can be used to develop indicators of the sources of
                      water quality impairment.                                            Nonpoint source pollution could also be
                                                                                  addressed through the use of Best Management
                              Appropriate management strategies for               Practices (BMPs) in agriculture, forestry, and
                      HUs with impaired water quality will depend                 land development. Such BMPs currently exist
                      upon the nature, extent, and sources of the                 and are.currently implemented voluntarily or
                      impairment. Possible management objectives for              through - economic incendves or disincentives.
                      an HU with impaired water quality were illus-               Targeting Water quality high risk areas for addi-
                      trated in Section 3 (see page 20). Achievement of           tional agricultural cost-share funding could be
                      those objectives would necessitate management               used to encourage the use of agricultural BMPs in
                      strategies including several implementation                 areas where agriculture is the predominant
                      mechanisms.                                                 source of runoff-borne pollutants. Similar target-
                                                                                  ing for strict enforcement of forestry BMPs or

                                                                                           Cumulative Impacts Management- Page 25

                additional sedimentation control measures under                      Point source discharges into surface
                the state Sedimentation Pollution Control Act               waters require an NPDES permit. Numbers of
                (G.S. 113A-50 et seq.) could provide additional             existing permits and their discharges can be used
                means of implementation. Since these programs               as indicators of the significance of point source
                are administered by other state agencies, inter-            pollutants in the HU. If they are' determined to
                agency coordination, either voluntary or through            be a significant problem, this information can be
                state consistency requirements, would be neces-             used to limit discharges from existing and future
                sary to accomplish this targeting.                          permitted sources. If water entering an HU from
                                                                            upstream is already degraded due to upstream
                        The Coastal Nonpoint Pollution Control              discharges, implementation would require limita-
                Program (CNPCP) requires enforceability of                  tion of those discharges as well as those occurring
                general NPS management measures such as                     within the HU. This type of holistic water quali-
                BMPs and the application of additional manage-              ty planning can be accomplished through DEM's
                ment measures in identified critical areas (NOAA            Basinwide Planning Program, and illustrates
                and EPA, 1993). Since one of the primary criteria           another situation in which interagency coordina-
                for identification of critical areas is the presence        tion is necessary for cumulative impacts man-
                of impaired or threatened waters, all or parts of           agement.
                water quality high risk areas could be designated
                as CNPCP critical areas. Management measures                         Protection and restoration of wetlands
                specific to the nature of the N?S problem could             that perform significant water quality functions
                then be applied. Such additional management                 could also be an appropriate management strate-
                measures might include stricter enforcement of or           gy for water quality high risk areas. DCM's
                more stringent standards for some of the imple-             wetland ftmctional assessment procedure could be
                mentation mechanisms discussed above or they                used to identify the specific wetlands with the
                might include more specific requirements for local          highest water quality functions, and these could
                actions such as low density zoning or cluster               be afforded higher levels of protection through
                development ordinances.                                     land use plan policies and by agreements with the
                                                                            Army Corps of Engineers and/or DEM. Since
                        In rural parts of the coastal area, septic          federal consistency requirements apply to 404
                tanks and package treatment plants are, the                 permits, any enforceable state or local policy in
                pnmary means of sewage disposal. Improperly                 the NC CMP that specifies high levels of pro-
                installed or malfunctioning onsite sewage disposal          tection for these wetlands could be used to imple-
                systems can discharge to the ground surface or a            ment this strategy. DCM`s Wetland Restoration
                shallow water table, resulting in eventual entry            Plan will identify possible restoration sites with
                of pollutants into surface waters. The proportion           high potential for performing significant water
                of houses in an HU with septic tanks rather than            quality functions. These sites could be targeted
                central sewage treatment systems can indicate               for restoration through a local, state, or federal
                the potential significance of this pollution source.        wetland restoration program.
                If onsite sewage disposal is a significant source of
                water quality degradation in a high risk HU,                         The overall management strategy for a
                several management strategies might be applied.             specific water quality high risk area might consist
                Stringent soil requirements, setbacks from sur-             of various combinations of these, or other, action
                face waters, and management and maintenance                 components, carefully coordinated to achieve the
                requirements could be applied to septic tank                desired objective of improving water quality and
                installations.  Large onsite disposal systems               preventing further degradation. In areas with
                require a state nondischarge permit, but individu-          severe water quality problems, such a strategy
                a,I small septic tanks are subject to regulation at         might approach being a type of special area
                the local level following state guidelines. Imple-          management plan addressing diverse problems
                mentation of stricter requirements would necessi-           through the coordinated efforts of several agen-
                tate interagency coordination and cooperation of            cies at different levels of goverrunent. In areas
                local governments. In situations where installa-            with less severe water quality degradation a less
                tion or expansion of a centralized sewage treat-            comprehensive approach targeting only the
                ment system is feasible, the appropriate manage-            largest pollutant sources may be adequate. It is
                ment strategy might consist of assisting the local          likely that a minimum set of management ap-
                government in obtaining funds for such purposes.            proaches and policies can be developed for appli-.
                                                                            cation to all high risk areas in this category, with

                Cumulative Impacts Management- Page 26

                       more specific management plans needed only for                         For areas experienc   ing rapid population
                       special cases.                                                growth, growth management tools could be used
                                                                                     by local governments to influence continued
                       Areas with High Potential for Water                           growth so as to minimize its potential effects on
                                                                                     water quality. More sophisticated land classifica-
                       Quality Impairment                                            tions in the land use plan could be used to identi-
                                                                                     fy areas in which growth management would
                                Another category of high risk area might             need to be applied to protect water quality.
                       include areas with presently acceptable water                 Planning expansion of central sewer systems and
                       quality but in which high rates of population                 limiting intensive development to areas serviced
                       growth or new or substantially expanding land                 by sewer lines may be an appropriate first step in
                       uses pose an imminent threat of water quality                 growth management. Again, revisions to the land
                       impairment. Environmental degradation is not                  use planning guidelines, and possibly an
                       yet evident in such areas, but the risk is high.              amendment to CAMA to require local consistency
                                                                                     with the land use plan, are likely to be necessary
                                Indicators of this type of risk would                to ensure implementation o     .f local management
                       include current water quality indicators in combi-            strategies.
                       nation with indicators of growth and/or land use                       For areas in which future water quality
                       changes. If an HU contains Outstanding Re-
                       source Waters or High Quality Waters, the man-                is threatened by land use changes not related to
                       agement objective is to prevent any degradation.              growth and development, such as expansion of
                       If the area contains stressed waters, such as                 concentrated livestock farnfing, state-level. action
                       Nutrient Sensitive Waters or support-threatened               may be needed. Designation of the area as a
                       waters, any additional stress may result in signif-           CNPCP critical area would require use of addi-
                       icant water quality impairment. In either case,               tional management measures to control nonpoint
                       such an area would be identified as at high risk              pollution. This may be a particularly appropriate
                       if other factors indicate a high potential for in-            strategy in areas with high potential risk for
                       creased pollutant loadings. A combination of                  water quality impairment, since the CNPCP
                       conditions is necessary for the risk of future                criteria for critical areas coincide with the condi-
                       water quality impairment to be high.                          tions that would result in inclusion in this high
                                                                                     risk category (NOAA and EPA, 1993). The addi-
                                Several indicators could be used to identi-          tional measures that might be applied would
                       fy areas in which growth or land use changes are              depend upon the specific land use change that
                       occurring at such rates that future water quality             poses the risk.
                       impairment is a high risk. Rapid rates of popula-
                       tion growth, a large number of recently granted               Areas with Present or Potential Air
                       NPDES or CAMA permits, large numbers of                       Quality IMPairMent
                       building permits or sedimentation pollution
                       control plans, increases or dramatic changes in
                       the extent of intensive agricultural practices, etc.,                  While air quality problems are not wide-
                       would indicate the likelihood of increased pollut-            spread in the coastal area, there may be limited
                       ant loadings. Increased loading, together with                areas at high risk of air quality impairment,
                       the presence of waters highly sensitive to even               particularly around urban or industrial areas. If
                       relatively small additional pollutant inputs,                 urbanization increases in the coastal area or if
                       indicate a high potential risk for water quality              industries with significant atmospheric discharges
                       impairment.                                                   locate there, air quality protection will become a
                                                                                     more pressing concern. By analyzing potential
                                Potential management strategies for this             air quality problems in advance, it will be possi-
                       category of high risk area would be similar to                ble to pay particular attention to increasing
                       those for an area with already impaired water                 urbanization and industrialization in potential
                       quality, except that more stress would be put on              high risk areas.
                       preventive rather than ameliorative actions.
                       Planning-related strategies would be more appro-                       Impaired air quality may result from the
                       priate than regulatory strategies.                            cumulative effects of many relatively minor
                                                                                     diffuse sources, such as large numbers of automo-
                                                                                     biles  or from one or a few large concentrated

                                                                                              Cumulative Impacts Management- Page 27

                emission sources, such as certain industries.               resources and services and in stresses on the
                Number and density of diffuse sources exist in              environment. Existing water supplies, waste
                proportion to population size and density, which            disposal systems, roads, schools, and other infra-
                can be used as indicators. Concentrated emis-               structure can be outstripped more rapidly than
                sions sources require an air quality permit from            local governments can respond. Development
                DEM (15A NCAC 2H .0600), and their locations                that necessarily accompanies high population
                are know. Complex sources, such as large park-              growth results in land conversion, increases in
                ing facilities and subdivisions, also require per-          impervious surfaces, and increases in waste
                mits (15A NCAC 2D .0800). Emission sources                  production that result in rapidly increasing
                that do not require a permit may be required to             stresses on water quality, wildlife and fish popu-
                register with DEM (15A NCAC 2D .0202), and                  lations, and other environmental resources.
                the locations of these registered sources are also
                known. The DEM Air Quality Branch maintains                          Indicators of areas of high population
                a database of all known emissions sources.                  growth are relatively straightforward. Simply the
                Through the use of these various data sources,              presence of population growth above a certain
                the locations of air pollutant emitters can be              rate can be used to identify high risk areas. The
                pinpointed.                                                 threshold rate might be deterrndned through the
                                                                            use of growth impact coefficients that relate
                        Whether emissions result in air quality             population growth to resulting effects and stress-
                problems depends upon their magnitude and                   es. DCM has a contract with Research Triangle
                density and on atmospheric dispersal. Actual                Institute to develop a first approximation of such
                ambient air quality monitoring is a more realistic          coefficients by the end of 1994. Other parame-
                assessment of the degree of air quality impair-             ters, such as rate and extent of land conversion
                ment than is simply the presence of sources.                and increases in population-related businesses
                DEM maintains ambient air quality monitoring                such as retail trade, may also be used as corrobo-
                stations in strategic locations across the state.           rating risk indicators.
                Standards for allowable concentrations of various
                pollutants are set in regulation (15A NCAC 2D                        In this risk category, the most significant
                .0400). The relationship of ambient concentra-              consideration for any indicator is rate of increase
                tions to the allowable maximum can be used as               rather than absolute numbers. An already dense-
                an indicator of how close an area is to exceeding           ly populated area might absorb an additional
                the standards.                                              thousand people with little noticeable effects,
                                                                            while a sparsely populated rural area might be
                        Management strategies within the scope              entirely changed by the same influx. Rapid
                of the NC CMP that may apply to areas with high             growth rates indicate rapidly changing conditions
                risk of air quality. impairment are probably                and potential instability in both human and
                limited to land use planning. Direct air quality            natural systems. Instability is a primary deter-
                regulation is performed by DEM through its                  minant of risk.
                permitting and emission control program, but the
                locations of sources are the result of land use                      Choice of appropriate management
                decisions. If HUs with high potential for develop-          strategies for high population growth areas will
                ment of air quality problems can be identified and          depend upon whether the area also falls into
                made known, local governments can take actions              another high risk category. For example, if the
                to steer pollutant emitting development away                stresses of population growth have. resulted in
                from those areas and into others.                           impaired water quality, the area will also be
                                                                            classified as a water quality high risk and appro-
                                                                            priate management strategies for that risk cate-
                Areas with Historic Rapid Growth                            gory will be applicable. If the area has high
                                                                            concentrations of sensitive resources, those re-
                        In parts of the coastal area, population            sources may already be under stress. Measures
                has increased dramatically over the past two                to ameliorate existing stress as well as to prevent
                decades. Between 1980 and 1990 the populations              additional stress may be warranted.
                of Brunswick, Carteret, Dare, and Onslow coun-
                ties increased by over 25 percent. Most of this                      There are significant differences between
                growth is concentrated within a few HUs. Rapid              ameliorative, or corrective, actions and preventive
                growth leads to rapid increases in demands for              actions. While stress can be prevented by guiding

                Cumulative Impacts Management- Page 28

                        growth and development, correction of existing                and land   use  controls above and beyond that
                        stresses requires changes to already existing                 currently required in the CAMA planning guide-
                        facilities or practices. Prevention of problems is            lines will need to be encouraged by DCM or
                        the traditional emphasis of planning and regula-              required by amendments to the rules. Consisten-
                        tory programs, while correction is more likely to             cy between the land use plan and local govern-
                        require costly engineering solutions. For exam-               ment actions will be essential.
                        ple, preventing dense residential development on
                        soils unsuitable for septic tanks unless a satisfac-                  If local governments fail to adequately
                        tory sewer system is in place imposes little direct           protect sensitive areas that are of more than local
                        costs. Providing a sewer system to an already                 significance, these areas may need to be designat-
                        existing residential development can involve                  ed as AECs so that state-level protection can be
                        substantial costs to both the local government                applied. Use standards in existing AECs may
                        and property owners. For this reason, corrective              need to be strengthened in high-growth areas to
                        actions are usually more difficult to accomplish              prevent further deterioration of water quality,
                        than preventive actions.                                      fisheries, etc.

                                 Nevertheless, management strategies                          The full authority of both state and
                        most appropriate for historic high growth areas               federal consistency requirements will need to be
                        may need to emphasize corrective as well as                   applied to ensure that the actions of other govern-
                        preventive actions. Improvement or expansion of               ment agencies are in accord with the growth-
                        water supply systems, sewage and solid waste                  directing policies of local governments and with
                        disposal systems, and other aspects of local infra-           any state-imposed protective efforts. If problems
                        structure may be necessary simply to correct                  are severe enough, and particularly if they in-
                        already existing problems. Collection and treat-              volve conflicts in the policies or actions of differ-
                        ment of stormwater runoff, installation of deten-             ent government agencies or levels, Special Area
                        tion ponds, and other stormwater runoff control               Management Planning may be necessary to
                        measures may be necessary to correct situations               adequately address the situation.
                        that could have been prevented by maintaining
                        riparian buffers.                                             Anticipated High-Growth
                                 Appropriate roles for the NC CMP in                  Areas
                        such engineering-based corrective actions might
                        include identifying problem areas in need of                          Most areas with high population growth
                        action, analyzing alternatives, and facilitating              rates over the past ten to twenty years are likely
                        funding for them. DCM has no authority to                     to continue to grow rapidly, at least until all
                        require such actions or to fund them. It could                available land is developed. There 'are other
                        perform a useful role, however, in expediting coor            areas, however, that are just beginning to experi-
                        dination between local governments and the                    ence rapid population growth or that will begin to
                        agencies with appropriate authorities.                        grow in the near future. These areas present the
                                                                                      best opportunities for implementation of meaning-
                                 Preventive actions will also be needed in            ful cumulative impacts management, since they
                        high growth areas to avert continued and intensi-             have not yet experienced major adverse impacts.
                        fied problems.     Comprehensive planning and                 It is in these areas that appropriate preventive
                        stringent land use controls will need to be applied           actions, if implernented in advance of anticipated
                        by the local government. Sensitive areas that                 growth, will be most beneficial.
                        would either be destroyed themselves by intensive
                        development or the development of which would                          Identifying potential future high growth
                        result in degradation of other resources will need            areas, however, is more difficult than identifying
                        to be identified and protected. Infrastructure and            areas that are already growing. Neither historic
                        community services will need to be improved and               population growth rates nor growth projections
                        expanded.                                                     based on historic trends can be used as reliable
                                                                                      indicators of future growth. Indicators of future
                                 All of the management strategies avail-              growth potential will have to be based on HU
                        able to the NC CMP will need to be applied to                 location in relation to histor .ic high growth areas
                        implement these corrective and preventive actions             and on indicators of increasing economic activity
                        in high growth areas. Comprehensive planning                  that may signal impending growth.

                                                                                              Cumulative Impacts Management- Page 29

                       Since areas that have been growing are                protective measures above and beyond any that
               likely to continue to grow, HUs adjacent to histor-           are already in place. All sensitive resources
               ic high growth areas are potential sites of future            should be identified, and at least those of greater
               growth. The paths that development in high                    than local significance targeted for specific protec-
               growth areas has been following may point to-                 tive measures.
               ward the areas in which future growth may be
               expected. For example, the recent rapid pace of                       Comprehensive land use planning should
               development of the Currituck County outer banks               be applied by the local governments to identify
               could have been predicted as the logical course of            areas into which growth would best be guided
               development spreading north from the Dare                     and to formulate protective mechanisms for
               County banks to the south. Thus, the presence of              sensitive areas. Planning will have to be coupled
               rapid growth in one HU may be used as an                      with growth management strategies and imple-
               indicator of potential growth in adjacent HUs,                mented through appropriate land use control
               particularly those in the path of expanding                   ordinances. Comprehensive plans should include
               development and those with environments similar               provisions for providing additional infrastructure
               to the area of historic growth.                               and services needed for the expected growth.

                       Planned growth4nducing activities or                          For areas identified as sensitive resources
               developments are also indicators of future popula-            of greater than local significance, AEC designa-
               tion growth. Examples include the Global Trans-               tion or stricter use standards for areas already in
               park (which is not in the coastal area, but close             AECs should be considered. This step should be
               enough to induce growth in Craven and adjacent                taken either in coordination with local govern-
               counties), military base expansions (expansion of             ment actions or to fill any gaps remaining after
               MCAS Cherry Point in Craven County is under-                  the local government has taken whatever actions
               way), new highways, new bridges, development of               it is willing to implement. Purchase of any
               industrial parks, major new residential develop-              outstanding resource areas that cannot be pro-
               ments, etc. Tracking plans and permit applica-                tected by other means should be considered by
               tions for such activities can provide a means of              both the state and local governments.
               predicting where future growth is likely to occur.
               HUs in the area of such growth-inducing activi-                       Specific protective and growth manage-
               ties can be identified as high risk areas and                 ment strategies chosen will depend upon the
               appropriate management strategies applied before              nature of the resources in the area and the types
               the growth takes place.                                       of threats likely to result from growth. If growth
                                                                             is likely to threaten water quality, for example,
                       Upturns in the general pace of economic               some of the strategies discussed under water
               activity can also be used as indicators of potential          quality high risk areas may be appropriate. If
               future growth. New business openings, increases               there are no outstanding resources or significant
               in the number of state or local permits being                 threats to environmental quality from the antici-
               applied for, increases in demand for building                 pated growth, simply good planning and growth
               materials, increases in real estate transactions,             management by the local governments may be
               and increases in retail sales could all be used as            sufficient to ensure that growth occurs in ways
               indicators that an area is poised for rapid popula-           that will enhance the quality of life in the area.
               tion growth. All of these parameters can be
               tracked with DCM`s Population/Development/                    High Value Resource Areas
               Resources Information System.

                       Management strategies for future growth                       Some parts of the coastal area may be
               areas will involve an intensification of both state           identified as high risk areas simply because of a
               and local activities to prepare for the increasing            concentration of sensitive, high value resources
               pressures of development. A logical first step                within them, whether or not those resources are
               would be to carefully inventory the resources that            currently threatened or impaired. These might
               will be impacted by future growth to determine                be HUs in which so much of the land or water
               their present status, their regional significance,            area is made up of high value resources or re-
               and their sensitivity to disturbance. The objec-              sources of such sensitivity to disturbance that
               tive of this inventory would be to identify the               very little growth and development could occur
               specific resources and areas that may warrant                 without significant resource impairment. Or they

               Cumulative Impacts Management- Page 30

                        might include HUs with only limited areas of                      also be identified as an area of high historic
                        sensitive resources but in which the resources are                population growth. The presence of indicators of
                        of such significance and sensitivity that develop-                two categories of high risk would emphasize and
                        ment around them should be carefully planned                      help to explain the significance of the risk.
                        and monitored. In either case, the high-value
                        resources are at risk of degradation from any                              The presence of even relatively small
                        substantial growth and development.                               areas of high value resources within an HU could
                                                                                          indicate high risk if those resources are of suffi-
                                 The PDRIS database contains the area                     ciently high value. An example of this category
                        and percentage of each HU composed of several                     would be an HU containing threatened or endan-
                        high-value and sensitive resources. The specific                  gered species habitat. Such habitat is protected
                        resources included are listed in Table II.                        by federal law even if it occupies a relatively
                                                                                          small area. Another example might be HUs
                                                                                          bordering Outstanding Resource Waters. Any
                                                                                          substantial development in such areas may result
                                               Table 11.                                  in water quality impairment unless it is carefully
                               High Value Resource Areas in PDRIS                         planned and executed.

                                      Anadromous Fish Habitat                                      The appropriate management strategies
                                       Coastal Reserve Waters                             for high-value resource areas will depend upon
                                       Coastal Reserve Lands                              the extent and value of the resources and the
                                  Natural Heritage Inventory Areas                        degree of already existing development. The
                                        Primary Nursery Areas                             primary management concern should be protec-
                                      Secondary Nursery Areas                             tion of the specific high-value areas. If they
                                   Submerged Aquatic Vegetation                           occupy a large proportion of an HU, then growth
                              Threatened/Endangered Species Habitat                       may need to be restricted in the whole HU. If, as
                                     Highly Signif icant Wetlands                         is more commonly the case, high-value resources
                                           Shellfish Waters                               occupy only a small portion of an HU, only that
                                         High Quality Waters                              portion and immediately surrounding areas may
                                    Outstanding Resource Waters                           need to be protected.
                                      Water Supply Watersheds                                      Some high-value resource areas are
                                                                                          already included in AECs. Coastal wetlands,
                                                                                          while they are only one type of high-value wet-
                                                                                          land, are included in a separate AEC category.
                        All of these resources are recognized as of suffi.-               Primary Nursery Areas (PNAs) and Outstanding
                        ciently high value to warrant special protection in               Resource Waters (ORWs) are included in the
                        state or federal statutes and/or regulations. They                Estuarine Waters AEC but are afforded higher
                        are high value resources by law, not by arbitrary                 levels of protection than other estuarine waters.
                        designation. There are several different situa-                   These existing mechanisms may be sufficient to
                        tions in which an HU containing these resources                   protect these high-value resources. The 1989
                        may merit designation as a high risk area.                        amendments to CAMA, however, authorized
                                                                                          inclusion of contiguous lands in the Coastal
                                 If the extent of these resources within an               Wetlands AEC and separate AEC categories
                        HU is so great that any substantial development                   including adjacent lands for PNAs and ORWs.
                        would pose a threat to them, the risk of their                    This authority could be used to improve protec-
                        impairment is high. Indicators of this situation                  tion of these areas as part of a cumulative im-
                        would consist of high total percentages of the area               pacts management strategy.
                        of an HU being occupied by these resources.                                 In many cases, local land use planning
                                 If existing development in an area is of                 and corresponding land use regulation could
                        sufficient magnitude or intensity that high-value                 provide adequate protection for high-value re-
                        resources are already threatened, then the simple                 source areas.       Most current land use plans,
                        presence of these resources in an HU may be                       however, don't afford significant protection to any
                        used as a high risk indicator. An area with that                  resources other than those in AECs. Land use
                        intensity of existing development, however, would                 control through zoning, protective overlay

                                                                                                   Cumulative Impacts Management- Page 31

                districts, etc., are lacking in most of the coastal                  While several management mechanisms
                area. Local land use planning and control will               exist for the protection of productive farm and
                need to be improved and stringently implemented              forest lands, they have not been used for this
                if it is to play a major role in protecting high-            purpose in the NC coastal area. Property value
                value resources.                                             assessment based on the economic return from
                                                                             agricultural or forest crops is one of the primary
                         In cases in which specific land areas are           means used in other areas to protect farm and
                of particularly high resource value, public acquisi-         forest land. Local tax structures that base prop-
                tion may be the best means of providing protec-              erty values on an area's potential for development
                tion. While a cumulative impacts management                  instead of its current use often result in the loss,
                strategy cannot mandate public acquisition, it can           rather than the protection, of productive lands.
                be used to identify those areas that should be               So long as this approach to property evaluation is
                considered for acquisition under other programs.             used and the economic demand for development
                                                                             continues, productive lands will continue to be
                Productive and Aesthetic Resource                            converted to other uses.
                Areas                                                                Whether productive lands are maintained
                                                                             in productivity or converted to other uses is, and
                         Agriculture, forestry, and fishing are              should remain, a local decision unless the signifi-
                economic mainstays in much of the coastal area.              cance of the crops being produced is of national or
                The scenic beauty of the coastal regions is one of           regional concern. If the benefits of land conver-
                the primary reasons for their popularity for                 sion are perceived to be greater than the costs of
                tourism, another important component of the                  losing productivity and the results of that loss on
                coastal economy. Protection of the productive and            the local economy and culture, government cannot
                aesthetic resources of the coastal area is essential         be justified in trying to prevent it. Unless the
                to maintaining its economic well-being.                      state or federal governments overtly choose to
                                                                             protect productive lands, it would not be appro-
                         The information on land use, soils, and             priate for the NC CMP to become involved. In
                economic activity in the PDRIS will provide                  this sense, then, the identification of highly
                adequate indicators of the presence and impor-               productive lands at high risk of loss will be
                tance of productive resources in each HU. Identi-            performed primarily to identify them to local
                fication of aesthetic resources, however, is less            governments which can choose the course of
                straight-forward. Presence of public recreation              action they feel is appropriate.
                lands and shoreline areas may provide some
                indication of aesthetic resources. The relative                      The protection of resources that are
                importance of the tourist economy in an HU may               perceived to belong to the public, however, is a
                serve as an indicator of the economic importance             different matter. The overall protection of envi-
                of protecting its aesthetic resources.                       ronmental quality falls into this category, as do
                                                                             the more specific protection of recreational fisher-
                         CAMA clearly includes the protection of             ies and aesthetic resources. Protection of fisher-
                highly productive and scenic areas within the                ies is already strongly emphasized in the NC
                authorized mandates of the NC CMP. Protection                CMP, and the factors related to fisheries, such as
                of recreational opportunities and scenic vistas is           water quality and nursery areas, will be ad-
                specifically included in the Legislative Findings            dressed in identifying and managing other catego-
                and Goals (NCGS 113A-102). The list of autho-                ries of high risk areas. The only specific resourc-
                rized AECs includes "renewable resource areas                es included in this risk category that are reason-
                where uncontrolled or incompatible development               ably subject to management by the NC
                which results in the loss or reduction of continued          CMP, then, are aesthetic resources.
                long-range productivity could jeopardize future                      Protection of scenic areas could be accom-
                water, food or fiber requirements," (NCGS 113A-
                113 (b)(3)) and lists "prime forestry land" as a             plished by several mechanisms. Local land use
                specific AEC category (NCGS 113A-113(b)(3)(c)).              planning could give priority to protection of scenic
                With the exception of fisheries productivity,                beauty by identifying particularly significant
                however, little emphasis has been given to the               areas and either preventing their development or
                protection of productive or aesthetic resources in           limiting development so as to maintain scenic
                the implementation of the NC CMP.                            values. More emphasis on protecting scenic

                Cumulative Impacts Management- Page 32

                      beauty could be included in AEC use standards.
                      Although the general management objective for
                      Estuarine System AECs includes safeguarding
                      and protecting aesthetic values (15A NCAC
                      711.0203), nothing specific as to how this is to be
                      done is included in the Use Standards. Without
                      any standards, it would be difficult to deny a
                      permit on the grounds that the resulting project
                      would be too ugly!

                               Whether any specific aesthetic standards
                      are practical or advisable is open to question.
                      The old cliche about beauty being in the eye of
                      the beholder has enough truth to it to make
                      absolute aesthetic standards difficult to formu-
                      late. Whether an ocean beach is more beautiful
                      with or without adjacent high rise hotels, for
                      example, probably depends more on whether the
                      person making the judgement is staying in one of
                      the hotels than on any universal standard. It is
                      likely that high risk of loss of aesthetic quality
                      will also be a risk category that will be identified
                      to provide information rather than one to be
                      directly addressed by the NC CMP.

                                                                                            Cumulative Impacts Management- Page 33

                                                                                      North Carolina!s approach to coastal area
                                                                             cumulative impacts management is based on
                                    ....     .......
                                                               ............
                                                                             identifying high risk areas and applying a combi-
                                                                             nation of management strategies appropriate to

                       j:: j
                       :::                                     i:":::        the specific situations within them. The proposi-
                          . .. ........
                                                                             tion that certain parts of the coastal area need to
                                                                             be treated differently from others is clearly
                                                           ............
                                              .... .....                     implicit in this area-based cumulative impacts
                                                                             management strategy. Some areas, due to their
                                                                             particular characteristics or the intensity of
                                                                             development in them, are subject to adverse
                                                                             cumulative impacts, and others, at least present-
                                                                             ly, are not. The focus of management attention
                                                                             must be placed on those areas in which adverse
                                                                             cumulative impacts are, or have a high potential
                                                                             for becoming, serious problems. That means that
                                                                             those areas need to be treated differently from
                                                                             areas where adverse impacts are minor.

                                                                                      While this idea is not foreign to the NC
                                                                             CMP, since AECs are treated differently from
                                                                             other areas, it has not been widely applied. All
                                                                             local governments are subject to the same Plan-
                                                                             ning Guidelines, and all permitted activities in a
                                                                             given AEC category must adhere to the same use
                                                                             standards. This uniform application of regula-
                                                                             tions, while it seems equitable and avoids the
                                                                             complications of identifying which areas come
                                                                             under which regulations, has serious short-com-
                                                                             ings in managing cumulative impacts. If high
                                                                             risk areas are to be treated differently to address
                                                                             their special situations, then different regulations
                                                                             must apply to them.

                                                                                      In order to legally apply a different set of
                                                                             regulations to high risk areas, some mechanism
                                                                             of officially designating those areas will be neces-
                                                                             sary. Then the specific regulations applicable to
                                                                             them must be adopted. Both of these steps will
                                                                             require action by the CRC. The first two steps of
                                                                             the cumulative impacts management model, i.e.,
                                                                             Relative Risk Assessment and Classification of
                                                                             Risks, are designed to perform the difficult task
                                                                             of identifying the areas that need special atten-
                                                                             tion. The rest of the model is designed to identify
                                                                             and apply the specific special attention needed.
                                                                             While these are two distinct steps, they are part
                                                                             of one management strategy. Either one without
                                                                             the other would be largely meaningless. Similar-
                                                                             ly, the CRC cannot be expected to approve the
                                                                             designation of an area as a high risk area without
                                                                             being clearly aware of the implications of that
                                                                             designation. The entire process, then, must be
                                                                             completed before it is introduced to the CRC.

                Cumulative Impacts Management- Page 34

                             The specific mechanisms for high risk                  assessment for individual projects is not avail-
                      area designation and the specific regulations that            able. The potential for application of such an
                      may be proposed to apply to them must be devel-               approach exists within the CAMA regulatory
                      oped as part of the cumulative impacts manage-                program, and alternative methodologies will be
                      ment strategy. This is the policy dimension of                examined in the development of I)CMs cumula-
                      the strategy as opposed to the technical dimen-               tive impacts management strategy. It is not
                      sions discussed above, The rest of this Section               likely, however, that objective cumulative impacts
                      discusses some of the policy implications of using            assessment methods will be incorporated into
                      the alternative management mechanisms avail-                  CAMA permit application review in the near
                      able to the NC CMP as effective tools for cumula-             future.
                      tive impacts management. The discussion of
                      various possibilities is not meant to suggest that                    Cumulative impacts are landscape scale,
                      they will be proposed, but only to identify and               rather than site-specific, phenomena. The Cumu-
                      explore as many alternatives as possible.                     lative Impacts Management Model described in
                                                                                    this report follows a landscape-scale approach
                      7he CAMA RegUlatory PrograM                                   toward identifying high risk areas. In order to
                                                                                    apply the site and project specific CAMA regula-
                                                                                    tory program to cumulative impacts management
                              The CAMA regulatory program, consist-                 in the context of this model, it must be applied
                      ing of AEC designation and direct state regula-               differently in high risk areas than in the rest of
                      tion of development, is the strongest management              the coastal area. This would entail changing the
                      tool available to the NC CMP. As such, it is a                regulatory structure in high risk HUs by desig-
                      primary potential implementation mechanism for                nating new AECs, increasing the geographic
                      cumulative impacts management.                                extent of present AECs, changing AEC use stan-
                                                                                    dards, or some combination of these approaches.
                             Cumulative Impact Considerations
                                 In CAUA Pennit Decisions                                               Now AECs

                              Since contribution to adverse cumulative                      While high risk areas, in their entirety,
                      effects is a statutorily authorized basis for permit          are not envisioned to be a type of AEC, cumula-
                      denial, it would appear that individual review of             tive impacts management in high risk areas could
                      each permit application for its contribution to               entail designation of parts of them as new AECs.
                      adverse cumulative impacts would be the obvious               The CRC has the option of designating new AECs
                      way to apply the CAMA regulatory program to                   so long as the AECs fit within one of the general
                      cumulative impacts management. This approach,                 categories authorized by CAMA. Several of the
                      however, requires an objective and legally defen-             AEC categories established by CAMA could be
                      sible means of assessing the cumulative impacts               particularly amenable to use in managing cumu-
                      of a single proposed project in the context of                lative and secondary impacts.
                      everything else that already has, or will in the
                      foreseeable future, impact the same resources.                        In 1989, the General Assembly amended
                      The scientific and practical difficulties of this             CAMA by adding two new categories of AECs:
                      kind of cumulative impacts assessment have been               Outstanding Resource Waters (ORWs) and Prima-
                      discussed above (p. 3), and are so overwhelming               ry Nursery Areas (PNAs). The statutory defini-
                      as to make this approach infeasible at the present            tion of these AEC categories authorizes the CRC
                      time.                                                         to include within the area designated as AECs
                                                                                    such contiguous land as the CRC reasonably
                              NEPA, with its requirement for cumula-                deems necessary" for the protection of the re-
                      tive impacts assessment, has been in effect since             source values involved.           (NCGS �113A-
                      1970. Over the ensuing 24 years, many cumula-                 11M)(8)(9)). This "contiguous area" authoriza-
                      tive impact assessments have been attempted for               tion reflects the realization that activities outside
                      individual projects, and environmental managers               the precise boundaries of the resources them-
                      and scientist have expended great effort in trying            selves may have substantial cumulative and
                      to develop adequate assessment methodologies.                 secondary impacts on them.
                      In spite of the time and effort invested in these
                      attempts, an objective, scientifically sound, and                     While ORWs and PNAs are already
                      understandable method of cumulative impact                    included in the Estuarine System AEC category,

                                                                                            Cumulative Impacts Management- Page 35

                 their designation as distinct AECs including the            icant coastal resource areas.       Current rules
                 land around them would have significant advan-              include complex natural areas, areas that contain
                 tages for cumulative impacts management. Both               remnant species, unique geologic formations, and
                 of these resources are included in the list of high         significant architectural and historical resources
                 value resource areas (Table 11). At least some of           within this category (15A NCAC 7H.0504), but
                 the HUs containing ORWs and PNAs are likely to              the examples given in CAMA are more inclusive
                 be identified as high risk areas; perhaps All of            than this. The definition would seem to allow
                 them should be. If these resource areas were                AEC designation for any "environmental or
                 distinct AECs in themselves, and if their presence          natural resources of more than local significance."
                 were a primary determinant of high risk, there
                 would be no need for different AEC use standards                    The natural and cultural resource AEC
                 in high risk areas. The presence of the resources           category could be of great value in providing
                 themselves would determine the use standards.               protection for sensitive resources in high risk
                                                                             areas. The fact that this AEC category has
                          The inclusion of contiguous lands within           received little application in the past is not a
                 these AEC categories would have particular                  comment on its usefulness so much as an artifact
                 advantages in managing secondary impacts                    of its narrow interpretation in current rules and
                 resulting from activities on surrounding lands.             an arcane and difficult nomination and designa-
                 The use standards for the AEC itself, rather than           tion procedure. If the CRC should decide to make
                 those for the Estuarine Shoreline AEC, would                greater use of this AEC category and change the
                 apply to contiguous lands. This would make the              nomination and designation procedures, it could
                 application of use standards specifically tailored          become a significant component of a cumulative
                 to protect these sensitive resources from second-           impacts management strategy.
                 ary impacts more straight-forward.
                                                                                     In addition to the Estuarine Shoreline,
                          The CAMA definition of the Coastal                 which has been an AEC since the initial approval
                 Wetlands AEC also includes the "contiguous                  of the NC CMP, CAMA authorizes AEC designa-
                 areas" clause that applies to ORWs and PNAs                 tion for shorelines of all public trust waters
                 (NCGS 113A-113(b)(1)). While use standards for              (NCGS 113A-113(b)(6)(b)) and for floodways and
                 coastal wetlands are highly protective, coastal             floodplains (NCGS 113A-113(b)(6)(c)). Designa-
                 wetlands are still subject to secondary impacts             tion of such areas as AECs could provide protec-
                 from development of adjacent lands. The ability             tion for riparian buffers and wetlands in areas
                 to treat lands and non-tidal wetlands adjacent to           upstream of estuarine waters. This could be a
                 coastal wetlands differently from those in other            valuable management tool in high risk HUs with
                 estuarine shoreline areas would provide a valu-             water quality degradation and in protecting
                 able tool for cumulative and secondary impacts              estuarine resources from stresses caused by
                 management.                                                 upstream development.

                          CAMA also authorizes AEC designation                       The rationale for    AEC designation of
                 for "renewable resource areas where uncontrolled            estuarine shorelines is that "Development within                   Ohl,
                 or incompatible development which results in the            estuarine shorelines influences the quality of
                 loss or reduction of continued long-range produc-           estuarine life" (15A NCAC 7H.0209(c)). This
                 tivity could jeopardize future water, food or fiber         relationship between shoreline development and
                 requirements of more than local concern" (NCGS              aquatic life clearly applies not only to estuarine
                 �113A-113(b)(3)). This statutory provision would            shorelines but also to the shorelines of all water
                 allow AEC designation for watersheds, aquifers,             bodies. It is also clear that the quality and
                 capacity use areas, prime forestry land, and                quantity of water flowing into estuaries from
                 similar areas likely to be included in some high            upstream sources has a significant influence on
                 risk areas.                                                 estuarine life. In order to adequately address
                                                                             management of cumulative impacts on overall
                          The natural and cultural resource AEC              water quality and aquatic life, protection of
                 category is defined in CAMA as including "fragile           upstream riparian areas is an indispensible
                 or historic areas, and other areas containing               management tool. The fact that this tool is
                 environmental or natural resources of more than             available as part of the CAMA regulatory pro-
                 local significance" (NCGS 113A-113(b)(4)). This             gram speaks strongly in favor of its implemen-
                 definition is broad enough to include many signif-

                 Cumulative Impacts Management- Page 36

                      tation through AEC designation of public trust              PNAs could also be widened without necessarily
                      shorelines and/or floodplains.                              establishing a separate AEC category, but to be a
                                                                                  meaningful change, this would have to be accom-
                              While designation of additional AECs                panied by different use standards for shorelines
                      would provide valuable tools for cumulative                 adjacent to PNAs. The Estuarine Shoreline AEC
                      impacts management, the advisability and feasi-             around ORWs has already been expanded, and
                      bility of emphasizing this approach is open to              different use standards apply.
                      question. AEC designation should not be taken
                      lightly nor considered a solution to all problems.                   It may also be appropriate to widen
                      The designation process in itself is long and               shoreline AECs in high risk areas where land-
                      administratively difficult and must be accompa-             based, rather than water-based, resources are
                      nied by the development of appropriate use                  threatened. For example, many functionally
                      standards. It would apply an additional regulato-           significant fresh water wetlands lie adjacent to
                      ry burden on the public and additional demands              shorelines, especially in the Albemarle Sound
                      on a limited DCM staff. Because of these consid-            area. While these wetlands are subject to the
                      erations, the CRC has been hesitant to expand               �404 wetland regulatory program, they are not
                      the scope of state regulation through designating           afforded the same level of protection as are
                      new AECs.                                                   coastal wetlands, even though they are likely to
                                                                                  be equally important to the estuarine system.
                              Using new AEC designation as a tool for             Similar examples of land-based resources located
                      cumulative impacts management should be                     near shorelines may be identified in the risk
                      considered an option of last resort, not the first          assessment. Widening the shoreline AEC to
                      approach to be applied. It should be considered             encompass the extent of these resources could be
                      only in cases in which a resource area of recog-            a useful tool in protecting both the resource areas
                      nized great significance is demonstrably threat-            themselves and adjacent estuarine waters from
                      ened by development activities and in which no              adverse cumulative and secondary impacts.
                      other management tool is adequate to provide the
                      necessary protection. Whether such situations                          Changes in Use Standards
                      will be identified in the cumulative impacts risk
                      assessment process remains to be seen.                               The least drastic approach to modifying
                                                                                  the CAMA regulatory program for implementa-
                                AEC Boundary Modifications                        tion of cumulative impacts management would be
                                                                                  modification of AEC use standards in high risk
                               Expanding the area encompassed in                  areas. Some development activities that would be
                      already existing AECs would provide a more                  permissable under current use standards in most
                      moderate approach to using the CAMA regulatory              of the coastal area may not be appropriate in
                      program to address cumulative and secondary                 certain high risk areas. For example, in areas
                      impacts. Precendent for this approach to provid-            designated high risk because of water quality
                      ing higher levels of protection for sensitive areas         impairment, marina siting standards could be
                      already exists in the expansion of the Estuarine            made more stringent, impervious surface limita-
                      Shoreline AEC to 575 feet around ORWs. This                 tions could be tightened, or development could be
                      same approach might be applicable to high risk              limited to areas served by municipal sewer sys-
                      HUs containing impaired or threatened waters in             tems.
                      which water quality impairment is linked to
                      shoreline activities. Indeed, this might prove to                    These examples are merely hypothetical,
                      be the most feasible way in which modifications             but indicate the kinds of changes in use stan-
                      to the AEC structure can be incorporated into               dards that might be considered to implement
                      cumulative impacts management.                              cumulative impacts management. Specific rule
                                                                                  amendment proposals will be developed in the
                               Including contiguous lands in the coastal          fourth step of the cumulative impacts manage-
                      wetlands AEC, as discussed above, might more                ment model when appropriate implementation
                      accurately be considered a boundary modification            mechanisms are identified to address specific
                      than a new AEC designation. This modification               situations in high risk areas.
                      would certainly make management of cumulative
                      and secondary impacts on coastal wetlands more                       Since rule amendments changing AEC
                      practical. The Estuarine Shoreline AEC around               use standards to address new situations has been

                                                                                           Cumulative Impacts Management- Page 37

                 an on-going process throughout the history of the            while larger than that of site specific development
                 NC CMP, it is a process that the CRC, DCM staff,             projects, is still too limited to adequately address
                 and the public are comfortable with. Modification            regional phenomena. The regional risk assess-
                 of AEC use standards applicable to AECs in high              ment and coastal-area-wide cumulative impacts
                 risk areas is, therefore, a feasible cumulative              management program being developed by DCM
                 impacts management mechanism. While it does                  will, however, provide the regional context into
                 represent a somewhat different approach, in that             which local planning can fit. The information
                 the modified use standards would be applicable to            bases developed for region-wide risk assessment
                 only those portions of a given AEC category                  and management can provide the link between
                 falling within certain high risk areas, it is not a          state and local perspectives necessary to achiev-
                 radical departure from the way in which the                  ing an integrated approach to cumulative impacts
                 CAMA regulatory program has always worked. If                management.
                 there are situations in which development in
                 A.ECs is a substantive contributing factor to                         The Population/Development'Resources
                 adverse cumulative impacts and in which modi-                Information System (PDRIS) developed by DCM
                 fied use standards could be clearly shown to be of           contains a wealth of information useful not only
                 benefit in preventing those impacts, it is likely            for regional management, but for local land use
                 that the CRC would approve reasonable rule                   planning as well. A complete list of information
                 modifications.                                               included in the PDRIS is given in the Appendix.
                                                                              In addition, DCM's wetlands mapping and func-
                 Land Use Planning                                            tional assessment efforts have produced detailed
                                                                              information on this significant component of the
                         The fact that the CAMA requirement for               coastal area landscape.       DCM is developing
                 local land use planning applies to all of the                mechanisms for providing this information to
                 coastal area, not just to A.ECs, makes it a poten-           local governments as part of the land use plan
                 tially more useful tool for dealing with landscape           update process.
                 level cumulative impacts than is the CAMA                             Providing this information to local gov-
                 regulatory program. The local planning compo-                ernments will have several advantageous results:
                 nent of the NC CMP, therefore, is expected to                (1) accuracy and consistency of the information
                 play a major role in cumulative impacts manage-              used for planning will be improved; (2) local
                 ment.                                                        governments will be relieved of many of the data
                         In order to make land use planning a                 gathering requirements of land use plan updates;
                 powerful implementation tool for cumulative                  (3) the use of information based on hydrologic
                 impacts management, however, several changes                 units will enable better local understanding of the
                 in current policies and procedures will be neces-            effects of growth and development on the natural
                 sary. Revisions to the Land Use Planning Guide-              environment than is possible with      ' information
                 lines and modifications of planning procedures               collected by political jurisdiction; and (4) data
                 will likely be necessary to incorporate cumulative           transfer and the use of common information will
                                                                              improve communication and coordination between
                 impacts management into local planning pro-                  state and local governments. All of these results
                 grams. Possible improvements to the planning                 will increase the value of local planning as a tool
                 process include the use of more comprehensive                for cumulative impacts management.'
                 information in planning, basing local plans on the
                 same hydrologic units used in regional cumulative                    The only barriers to providing PDRIS and
                 impacts risk assessment, improved plan coordina-             wetlands data to local governments are the
                 tion and consistency, and more stringent local               logistical problems of media, formats' timing, etc.
                 and state implementation of land use plans.                  Information must be provided in fo;;r; in which
                       Improved Informaffon for Planning                      local governments are able to access and use it.
                                                                              The wide size range of local governments in the
                         It is unrealistic, except, in a very limited         coastal area results in a range of computer and
                                                                              GIS capabilities and ability to use and manipu-
                 sense, to expect local plans to include cumulative           late information. Mechanisms for transferring
                 impacts assessments unless a regional assess-                and using information that account for these
                 ment is available from which to tier to the local            differences must be developed. A Project of
                 level (Hunsaker, 1993). The scope of local plans,            Special Merit grant awarded to DCM under the

                 cumulative Impacts Management- Page 38

                      CZMA �309 Program for federal fiscal year 1994-              planning for these HUs must be different than for
                      95 will provide funding to develop these mecha-              other areas. Requiring that planning for high
                      nisms. File or map formats, minimum computer                 risk areas specifically address the particular
                      hardware and software configurations, transfer               situations leading to the high risk designation is
                      media, and delivery procedures will be deter-                the only meaningful way in which local planning
                      mined to facilitate widespread dissemination of              can serve as an implementation mechanism
                      the state information database.                              within the cumulative impacts management
                                                                                   model. If local governments are required to plan
                               If this more sophisticated information is           differently for high risk HUs as distinct units
                      to be valuable in improving cumulative impacts               within a larger planning jurisdiction, it is only a
                      management, it must be used meaningfully by                  small additional step to base the entire plan on a
                      local governments. Since much of the information             series of hydrologic units.
                      will be new and in a format different from that
                      historically used for local planning, local govern-                  Basing local planning on watershed units
                      ments will need guidance and assistance in                   would   also promote better understanding of
                      applying it to their situations. DCM has started             relationships between land use and water quality
                      working with some local governments in the use               and provide a basis for implementation of DEM
                      of state-provided information to develop methods             basin-wide plans through local planning and land
                      for local applications. This effort will be expand-          use management. It might also stimulate local
                      ed over the next two years to include working                governments to consider the implications of land
                      relationships with several coastal area govern-              use in a part of a watershed on the rest of the
                      ments to develop applications appropriate to a               watershed and on those downstream.
                      range of local situations.                                           There are obvious difficulties, however, in
                               The diversity of local governments in the           attempting to base local planning on hydrologic
                      coastal area also results in a range in sophistica-          units. The most apparent difficulty is the dispari-
                      tion and interest in improving land use planning.            ty between boundaries of HUs and planning
                      Some communities are likely to embrace im-                   jurisdictions. Political jurisdictions do not con-
                      proved information and techniques and immedi-                form to watershed boundaries, resulting in many
                      ately put them to use; others are likely to be               HUs that overlap two or more planning jurisdic-
                      hesitant. The availability of better information             tions. Small municipalities may occupy only a
                      will not result in an immediate and universal                portion of a watershed and have no voice in what
                      improvement in local land use plans. Over a                  happens in the rest of it. Of necessity, plans for
                      period of time, however, it will increase the                many HUs would be fragmented among different
                      sophistication of local planning and will increase           local planning bodies so that the advantages of
                      the effectiveness of local planning in managing              coordinated planning for those HUs could be lost.
                      cumulative impacts.                                                  If approached realistically, however, this
                               Hydrologic Unit Bawd Planning                       difficulty could be turned into a long term advan-
                                                                                   tage. Planning by watershed units would require
                               The most obvious framework for tiering              local governments to examine relationships
                      from the regional risk assessment to local plan-             between land use and water quality. It should
                      ning would be using the same hydrologic units for            become apparent that what happens in part of a
                      local planning as are being used in the regional             watershed influences other parts, and what
                      assessment. The data collected and analyses                  happens upstream certainly influences water
                      performed for the regional assessment could be               quality downstream. Given enough time, this
                      provided in the same form to local governments,              may result in a more coordinated approach to
                      which would use this information as the basis for            planning among different political jurisdictions
                      sub-plans for each HU within their jurisdiction.             that occupy portions of the same watershed.
                      This approach would provide a common frame-                  Improved coordination among plans would, in
                      work for regional and local cumulative impacts               itself, increase the effectiveness of local planning
                      management and for addressing the particular                 in cumulative impacts management.
                      problems of high risk areas in local plans.
                                                                                           Another potential difficulty with water-
                               If local plans are to be effective in ad-           shed-based planning is the fact that population
                      dressing the problems of high risk areas, their              and economic data are collected and reported by

                                                                                           Cumulative Impacts Management- Page 39

                political jurisdictions, not watersheds.         This         protection and population center-based planning
                difficulty has been largely overcome, however, in             for community service needs would be most
                the development of the PDRIS. DCM and RTI                     appropriate.
                have developed methods for allocating and dis-
                tributing data reported on other geographic bases                      The feasibility of adopting and imple-
                to hydrologic units. This information will be                 menting a change to watershed-based planning in
                maintained in the PDRIS and will be readily                   CAMA land use plans depends upon the degree to
                available to local governments.                               which the involved parties - DCM, local govern-
                                                                              ments, and the CRC - choose to emphasize the
                         Again, what at first appears to be a                 difficulties and shortcomings or the long term
                disadvantage of HU-based planning could become                advantages. There would be some transitional
                a distinct advantage in the long term. Agricul-               difficulties, and watershed-based planning is not
                tural agencies, such as SCS and ASCS, are                     a panacea. But the long term advantages of this
                moving toward collecting and reporting agricul-               approach in the context of a resource protection
                tural data on the basis of the same HUs used in               oriented planning program are great Indeed,
                the PDRIS. Both EPA and NOAA are actively                     hydrologic unit based planning may be the only
                promoting watersheds as logical data collection               way to implement cumulative impacts manage-
                and environmental planning units. DEM's basin-                ment in the CAMA planning program.
                wide approach to water quality planning and
                permitting uses river basins and sub-basins as                    Improved Coordination and Consistency
                analytical and planning units. If local govern-
                ments began to plan by these HUs, they would                           Cumulative impacts management cannot
                begin to collect and analyze local information on             be successful if local actions are not coordinated
                the same basis. While there may be some diffi-                and consistent with regional goals (Contant and
                culties in the short run, moving toward common,               Wiggins,1991). After the regional assessment is
                environmentally-based units for data collection,              performed and a cumulative impacts management
                analysis, and planning by local, state, and federal           program developed for the entire NC coastal area,
                agencies would be a distinct long-term advantage              it will be necessary for local plans to be consistent
                in cumulative impacts assessment and manage-                  with and provide local implementation for region-
                ment.                                                         al cumulative impacts management goals. The
                                                                              basis for achieving this is found in CAMA, which,
                         Since planning by hydrologic units would             in reference to land use plans, states that "The
                necessitate closer coordination among political               plan shall be consistent with the goals of the
                jurisdictions sharing common watersheds, the                  coastal area management system ... and with the
                current disjointed timing of land use plan updates            State guidelines adopted by the Conunission"
                would present a short-run difficulty. There is                (G.S. 113A-110(a)). The State Guidelines also
                already an effort underway, however, to improve               state: "All policies adopted by the local govern-
                coordination of plan@update timing among adja-                ment as a part of the land use plan shall be
                cent and overlapping jurisdictions, such as coun-             consistent with the overall coastal policy adopted
                ties and the municipalities within them. Chang-               by the Coastal Resources Commission" (15A
                ing the organization of this rescheduling effort              NCAC 7B.0203(d)).
                from a county to a river basin basis would over-
                come this difficulty. Some lag time will elapse                       Achieving consistency between regional
                before all updates can be coordinated by river                cumulative impacts management strategies and
                basins. But once again, this short term difficulty            local plans will require some changes in the basis
                could result in long term improvements in dealing             for CRC review and certification of land use
                with cumulative impacts.                                      plans. In addition to ensuring that the required
                                                                              procedures have been followed and the required
                         While watershed-based planning is                    topics addressed, the CRC must ensure that the
                clearly relevant to environmental and resource                policies in local plans are consistent with the
                management, it may not be particularly relevant               basic goals of the NC CMP. In the context of
                to other planning needs. Provision of community               cumulative impacts management, local policies
                services, for example, bears little relationship to           must be consistent with policies developed in the
                watershed boundaries. In order to meet the                    regional strategy.     The legal basis for this
                planning needs of local communities, a oombina-               requirement is provided in the above quotations
                tion of watershed-based planning for resource                 from CAMA and the State Guidelines.

                Cumulative Impacts Management- Page 40

                              It is also necessary that local plans be                      Adopting a hydrologic unit basis for
                      consistent and coordinated with others in the                planning, as discussed above, would be a less
                      same subregion. The Guidelines require that                  drastic change than shifting to regional planning
                      "Meetings shall be held with the planning and                and could overcome many of the problems of lack
                      governing boards of all adjoining planning juris-            of consistency and coordination. If all of the
                      dictions to discuss planning concerns of mutual              plans within a river basin were updated simulta-
                      interesV' (15A NCAC 7B.0203(c)). This approach               neously, and if local governments were required
                      has proven to be ineffective, since there is no              to coordinate plans for shared hydrologic units,
                      explicit requirement that policies be consistent             the opportunity for improved coordination would
                      from one unit to another. This leads to uncoordi-            at least be present. Perhaps over time it would
                      nated and often conflicting policies in the plans of         become a reality.
                      adjacent jurisdictions, a situation that is more
                      likely to result in adverse cumulative impacts                        Land Use Plan Implomentatfon
                      than to alleviate them.                                               Plans by themselves, however well coordi-
                              This problem is exacerbated by the                   nated and comprehensive, will not be effective in
                      current timing of land use plan updates. Plans               managing cumulative impacts unless they are
                      must be updated every five years beginning with              implemented. Implementation at the local level
                      the time of the first plan prepared by the local             could be improved by requiring that all local
                      government. Since municipalities can decide at               ordinances and actions be consistent with the
                      any time to prepare a land use plan for the first            plan. CAMA now explicitly requires such consis-
                      time, plan updates for municipalities often do not           tency only in AECs (G.S. 113A-111).
                      occur on the same schedule as updates for the
                      county in which they are located or for other                         If CAMA were amended to require consis-
                      nearby municipalities. This disjointed timing                tency between land use plans and local ordinanc-
                      works against coordinated planning and results in            es, and if land use plans were required to be
                      failure to consider common concerns and develop              consistent with cumulative impacts management
                      consistent policies.                                         policies adopted by the CRC, a structure would be
                                                                                   in place whereby cumulative impacts manage-
                              A separate report is being prepared to               ment through local land use planning could
                      suggest specific changes to the land use planning            become a reality. Short of that, the CAMA
                      process to make it more effective in cumulative              planning program will be, at best, an uneven
                      impacts management, so only a few general                    implementation mechanism.
                      possibilities will be discussed here. The over-
                      riding concern must be putting plans in the                  Inter-Agency Coordination
                      context of their region through coordinated timing
                      and consistency of policies. All plans for a sub-
                      region should be developed at the same time, and                      Whatever changes might be made to the
                      policies should be consistent among plans and                CAMA     regulatory and land use planning pro-
                      with general policies for the subregion and the              grams to improve their effectiveness in managing
                      entire Coastal Management Program.                           cumulative impacts, these management tools
                                                                                   alone will be inadequate to the task. Although
                              Perhaps the number of separate plans                 the management tools available to the NC CMP
                      should be decreased, so that a county and all the            are broad in scope, they are limited by the statu-
                      municipalities in it produce one plan through                tory authorities of other agencies and the struc-
                      concerted effort rather than many plans through              ture of North Carolina state government. While
                      separate efforts. Possibly going a further step              protection of water quality, for example, is a goal
                      and shifting the planning process from a purely              of the NC CMP, the regulatory authority for
                      local to a regional basis would be most effective.           water quality protection lies with DEM. Many
                      Regional plans could then pay particular atten-              other state, federal, and local agencies also play
                      tion to and contain more comprehensive planning              significant roles in determining land use patterns
                      for local landscape units with high cumulative               and managing resources in the North Carolina
                      impacts risk and be less comprehensive for low               coastal area. The decisions and actions of all
                      risk landscape units.                                        involved agencies must be consistent with cumu-
                                                                                   lative impacts management. goals if those goals
                                                                                   are to be achieved.

                                                                                            Cumulative Impacts Management- Page 41

                         Other agencies, each focused on its own             gies (DEM, 1991). This innovative program is
                authorities and responsibilities, will not automat-          considered a national model for management of
                ically act consistently. DCM, as the lead agency             cumulative impacts on water quality.
                in cumulative impacts management, will have to
                take the initiative in coordinating agency activi-                   Close coordination between DCM's cumu-
                ties to address the situations in high risk areas.           lative impacts management strategy and DEM's
                Specific means of interagency coordination must              Basinwide Planning Program is a primary goal of
                be included in the cumulative impacts strategy.              the strategy (DCM, 1992b). Since both efforts are
                                                                             based on watershed units, and since water quality
                         The coordinating role of the NC CMP was             is a good indicator of cumulative impacts, the
                set forth in the original coastal management plan            basis for coordination is obvious. The structure of
                (NOAA, 1978), which pictures the CMP as an                   how coordination will be implemented is being
                "umbrella" program coordinating the activities of            developed through frequent consultations between
                all agencies involved in activities related to               the two agencies. Several possibilities exist.
                coastal management. Implementation of this
                coordinating role, however, has not been achieved                    While basinwide plans are for entire river
                to the extent originally envisioned. Resource and            basins, they are broken down into sub-basins for
                environmental management remains fragmented                  analysis and implementation. Currently DEM
                among various agencies, and the role of DCM is               uses it own sub-basin delineations, roughly
                seen as limited to implementation of the specific            equivalent to the eleven-digit SCS/TJSGS hydro-
                authorities of CAMA. Successful management of                logic units. Further reducing the level of detailed
                cumulative impacts, however, will require that a             analysis and implementation to the fourteen-digit
                More holistic approach be achieved and that the              HU level used by DCM would make the analytical
                NC CMP become a true umbrella program, not                   units of both agencies directly equivalent. The
                dictating the actions of other agencies, but coordi-         PDRIS could then be used by DEM to provide
                nating them into a cohesive program of coastal               more detailed information on population, land use
                management.                                                  and water quality in each HU, increasing the
                                                                             level of precision of the basinwide plan.
                         There  are too many agencies and pro-
                grams pertinent to coastal management to at-                         DCKs analyses will provide identification
                tempt to discuss them all here. The relevance of             of water quality high risk areas, which can be the
                some of them may not become apparent until the               focus areas within the basinwide plan. When the
                assessment is completed and cumulative impacts               high risk is a result primarily of upstream activi-
                management strategies are being devised. There               ties, DCM can potentially influence treatment of
                are, however, some programs carried out by or                those activities in the plan, extending the influ-
                involving other agencies that obviously relate to            ence of the NC CMP over upstream activities that
                cumulative impacts management. These include                 influence coastal water quality. When activities
                DEMs Basinwide Planning Program, the Water                   within a coastal HU significantly contribute to
                Supply Planning Program of the Division of                   water quality impairment, the NC CMP can
                Water Resources, and the Coastal Nonpoint                    provide basinwide plan implementation through
                Pollution Control Program.                                   land use planning and the CAMA regulatory
                                                                             program.
                               BasinWide Planning                                    Hydrologic unit-based planning with plan
                         North Carolina's basinwide approach to              updates coordinated by river basin would provide
                water quality management, designed and imple-                an ideal implementation opportunity for land use
                mented by DEM, is the closest approximation to               related aspects of basinwide plans. Changing to
                cumulative impacts management presently in                   this basis for CAMA land use planning would
                operation in the state. All water quality manage-            provide a clear basis for coordination with basin-
                ment activities, including permitting, monitoring,           wide planning, in addition to the intrinsic advan-
                modeling, nonpoint source assessments, and                   tages of HU-based planning discussed above.
                planning, are coordinated and integrated by river            True interagency coordination requires adjust-
                basin. Water quality and aquatic resources are               ments on the part of all programs involved. The
                assessed simultaneously throughout an entire                 CMP cannot expect to influence the actions of
                river basin - leading to the development of basin-           DEM in regard to upstream activities unless it is
                wide water'4uality management plans and strate-

                Cumulative Impacts Management- Page 42

                       prepared, in turn, to accomodate the implomenta-                 decrease redundancy of effort by local govern-
                       tion aspects of DEM's basinwide plans.                           ments.

                                     Water Supply Planning                                       Information from water supply plans
                                                                                        could also be used to identify HUs with potential
                                The State Water Supply Plan Statute                     water supply problems, increasing the scope and
                       (NCGS 143-3550-m)) requires local governments                    usefulness of the PDRIS. At some point in the
                       that provide public water supply service to ana-                 future, when local water supplies become limiting
                       lyze current water supply and demand, project                    to growth and regional solutions are necessary,
                       future water needs, and plan for the continued                   water supply planning may form a basis for a
                       provision of adequate water supplies. Water                      regional approach to growth planning and man-
                       Supply Plans must also specify how much waste-                   agement.
                       water is generated by the system and where it is
                       discharged. Plans are submitted to the Division                              Coastal Nonpoint Pollution
                       of Water Resources (DWR) and must be updated                                       Control Program
                       at least every live years. Based on these local
                       plans, DWR develops a state water supply plan to                          The Coastal Nonpoint Pollution Control
                       identify potential conflicts and areas for coordina-             Program (CNPCP), established by Section 6217 of
                       tion.                                                            the Coastal Zone Act Reauthorization Amend-
                                                                                        ments of 1990, requires coastal states to develop
                                Adequate water supply is a potential                    coordinated programs for control of nonpoint
                       growth-limiting factor in some coastal communi-                  source pollution of coastal waters. The program,
                       ties, particularly those dependent upon limited                  currently under development, will be implement-
                       groundwater aquifers. Water Supply Plans are                     ed through changes to the state Nonpoint Source
                       meant to identify those areas, bring them to the                 Management Program in DEM and to the NC
                       attention of the local government, and ensure                    CMP. The central purpose of the CNPCP is to
                       that appropriate adjustments are planned in ad-                  strengthen links between federal and state coast-
                       vance and that state technical assistance is                     al management and waterquality programs in
                       provided where needed. When water use conflicts                  order to enhance state and local efforts to manage
                       or water shortages occur, DWR performs ground                    land use activities that degrade coastal waters
                       water studies and recommends alternatives,                       and habitats (NOAA and EPA, 1993). It, thus,
                       including Capacity Use Designation and other                     provides excellent opportunities for improving
                       measures.                                                        inter-agency coordination in addressing the
                                                                                        cumulative impacts of land uses.
                                These water supply programs are an
                       attempt to manage and plan for cumulative                                 The CNPCP must contain enforceable
                       demands on a finite resource, and, as such, are a                policies and mechanisms to implement nonpoint
                       form of cumulative impacts management. Local                     source management measures for a range of land
                       Water Supply Plans are also closely related to                   use practices throughout the coastal area, and, in
                       land use planning, since amounts and patterns of                 some instances, to a larger area. In areas with
                       growth and development determine future water                    existing threatened or impaired waters or in
                       demand. Water supply planning is another                         which new or substantially expanding land uses
                       obvious area for coordination with the NC CMP's                  may contribute to future impairment, additional
                       cumulative impacts management program.                           more stringent management measures must be
                                                                                        applied. These CNPCP management measures
                                DCM and DWR have begun discussing                       may provide a range of implementation mecha-
                       ways in which the efforts can be coordinated.                    nisms for cumulative impacts management,
                       One obvious possibility is to combine water                      particularly in high risk areas with existing or
                       supply plan updates with CAMA land use plan                      potential water quality degradation.
                       updates. Water supply planning is an important
                       component of comprehensive planning, and both                             The primary purpose of the CNPCP is to
                       are updated on the same five-year cycle. In                      implement management measures for nonpoint
                       addition to increasing the scope and significance                source pollution by more fully integrating federal,
                       of CAMA land use plans in managing cumulative                    state, and local authorities. It is being developed
                       impacts, including water supply planning would                   by DCM in close coordination with the Nonpoint
                                                                                        Source Management Program (�319 Program in

                                                                                                 Cumulative Impacts Management- Page 43

                DEM, and also involves coordination with several                    SAMP is a difficult, time-consuming, and
                other agencies with management or regulatory               expensive process that requires the full commit-
                authorities related to potential nonpoint source           ment of all parties and often necessitates the
                generating activities or nonpoint source controls.         development of new implementation mechanisms.
                The other agencies involved, in addition to the            It has been used with varying degrees of success
                �319 Program, include the stormwater, wetlands,            in several states to address highly complex prob-
                groundwater, and basinwide planning programs               lems that could not be handled in any other
                in DEM and the divisions of Soil and Water                 fashion. In most cases, SAMP is considered an
                Conservation, Land Resources, Environmental                approach of last resort when all other manage-
                Health, Solid Waste Management, and Forest                 ment approaches have proven insufficient. The
                Resources. Seldom does any one effort attempt to           formal SAMP process should not be used if a
                coordinate the activities of so many agencies.             simpler solution is available.

                        While the exact form of North Carolina's                   Due to its difficulties and the limitation
                CNPCP is yet to be determined, it is federally-            of its use to unique situations in which alterna-
                mandated and must follow guidelines developed              tive approaches are inadequate, SAMP is not a
                by NOAA and EPA. Thus, its development and                 suitable implementation mechanism for wide-
                implementation in a form closely approximating             scale cumulative impacts management. Any
                federal requirements is virtually certain. The             policies or management structures developed
                role of the CNPCP as an implementation mecha-              through a SAMP would be limited to the specific
                nism for cumulative impacts management, howev-             geographic area to which it applies. If SAMP is
                er, will depend upon the degree to which the two           used as a means of cumulative impacts manage-
                efforts are integrated into an overall strategy.           ment, its applicability will be limited to areas
                                                                           with particularly acute problems where other
                        To ensure this integration, DCM           is       alternatives are inadequate.
                developing North Carolina's CNPCP in close
                coordination with development of the cumulative
                impacts management strategy. Analyses of land
                use and water quality impairment performed in
                cumulative impacts assessment will be used to
                identify areas in need of additional NPS manage-
                ment measures in the CNPCP. Since these same
                areas are also likely to be identified as high risk
                areas, the CNPCP will play a primary role in
                addressing the cumulative impacts of land uses
                within them.

                Special Area Management Planning

                        SAMP is a tool for cooperative multi-
                agency management of areas of special impor-
                tance with intense use and management conflicts.
                Its use is normally limited to situations in which
                highly valuable resources are overtly threatened
                and no appropriate management framework
                exists. The SAMP process brings together all
                involved agencies, governmental levels, and user
                groups in an attempt to resolve conflicts and
                develop a mutually agreeable management struc-
                ture. Special administrative arrangements or
                new management forms are often created to
                increase regulatory coordination or to guide
                development (Brower and Carol, 1987).

                Cumulative Impacts Management- Page 44

                                                                                              As population and development continue
                                                                                     to increase in the North Carolina coastal area,
                                                                                     managing the cumulative and secondary impacts
                                                                                     0 development has become a necessity. The
                                                                                     primary
                            "CONCL                                                            mandate of the NC CMP is to guide
                                        ........... .....
                                                                       ...              wth and development so as to minimize envi-
                               .... ....                                             gro
                                                                                     ronmental degradation. It is not possible to carry
                                                                                     out this mandate successfully without assessing
                                                                                     and managing the cumulative and indirect, as
                                                                                     well as the individual and direct, impacts of
                                                                                     development.     This requires a more holistic
                                                                                     management perspective and approach than have
                                                                                     been used in the past.

                                                                                              It is extremely difficult to assess the
                                                                                     cumulative impacts of incremental development
                                                                                     on complex ecological systems. Linking individu-
                                                                                     al causes with cumulative effects in an objective
                                                                                     and legally defensible manner is impractical with
                                                                                     current knowledge and methods. While it would
                                                                                     be desirable to include cumulative impacts assess-
                                                                                     ments in CAMA permit reviews, detailed, cause
                                                                                     and effects assessment is too complex, imprecise,
                                                                                     and difficult to comprehend to form an acceptable
                                                                                     basis for regulatory decision-making.

                                                                                              Instead of cause and effect analysis, DCM
                                                                                     is applying an area-based risk assessment ap-
                                                                                     proach emphasizing management, rather than
                                                                                     assessment, of cumulative impacts. This ap-
                                                                                     proach identifies the activities that result in
                                                                                     impacts and the status of resources that are
                                                                                     affected. If either the level of impacting activities
                                                                                     is intense or resources are already impaired, an
                                                                                     area is at high risk of adverse cumulative im-
                                                                                     pacts. Risk assessment can be applied without
                                                                                     analysis or complete understanding of the com-
                                                                                     plex details of cause and effect relationships and
                                                                                     ecological thresholds.      Risk assessment can
                                                                                     identify which risks are greater or which areas
                                                                                     are at higher risk so that time and attention can
                                                                                     be focused on risk management rather than on
                                                                                     ecological assessment.

                                                                                              This change in emphasis allows the use
                                                                                     of standard planning and management techniques
                                                                                     in cumulative impacts management. Risk man-
                                                                                     agement decisions can be made through the
                                                                                     consideration of priority problems in light of
                                                                                     available management options, resources, admin-
                                                                                     istrative and legal structures, etc. This approach
                                                                                     is, therefore, more amenable to public policy-
                                                                                     making. It's objective is not to provide a precise
                                                                                     assessment of cumulative impacts within an area
                                                                                     nor to assess the cumulative impacts of specific

                                                                                              Cumulative Impacts Management. Page 45

                projects, but to identify areas at highest risk to            of relative risk assessment, classification of risks,
                which the conventional tools of environmental                 goal-setting, identification of the most appropriate
                management can be applied.                                    implementation mechanisms, and implementa-
                         Since the cumulative impacts of individu-            tion.
                al actions adversely affect public resources,                             Relative Risk Assessment
                cumlative impacts management is a legitimate
                function of government. Traditional government                         The first step consists of comparing
                environmental prograrnS, however, are designed                conditions in relatively small landscape units to
                to deal with individual actions and resources one             identify areas at high risk of adverse cumulative
                at a time. The structure of single-purpose agen-              impacts. The landscape units being used are 348
                cies often contrains their ability to take the                small watersheds, or hydrologic units, of 5,000 to
                holistic approach necessary for successful cumula-            50,000 acres delineated by SCS. A large amount
                tive impacts management.                                      of information is being collected for each of these
                                                                              units to indicate the intensity of land use and
                         The NC CMP, however, is unusual in                   development pressure and the concentration and
                that its mandate includes a very broad and com-               condition of natural resources. A series of indices
                plete statement of environmental management                   are being developed to summarize the indicator
                goals. It is not limited to a specific class of re-           data and provide a basis for comparison among
                sources or a single type of activity, but is to               hydrologic units to identify those at.highest risk
                address the entire range of human activities as               of adverse cumulative impacts.
                they influence the economic, aesthetic, and ecol-
                ogical well-being of the coastal area. The legis-                           Classification of Risks
                lative findings and goal statements of CAMA
                provide a sound basis for a comprehensive cumu-                        High risk areas will be classified into
                lative impacts management program.                            categories based on conditions and causative
                                                                              factors present in them. An area may be at high
                         Similarly, the management mechanisms                 risk of adverse cumulative impacts due either to
                available to the NC CMP provide a broad spec-                 the nature or condition of its natural environment
                trum of cumulative impacts management tools.                  or to the type and magnitude of human-induced
                The CAMA regulatory program, which specifically               disturbances. Which management measures are
                includes adverse cumulative impacts as grounds                most appropriate for a given area will depend
                for permit denial, focuses full state authority on            upon its risk category.
                the most environmentally critical portions of the
                coastal area. The land use planning require-                                     Goal Setting
                ments of CAMA, together with the authority to
                establish state planning guidelines, provides a                        Specific management goals, consistent
                coordinated state-local system of land use. plan-             with the goals of CAMA, will be established for
                ning capable of including a strong cumulative                 each high risk category. Appropriate manage-
                impacts management component. The inter-                      ment objectives for a given area will depend upon
                agency coordinating function of the NC CMP,                   the nature of the risk and conditions present in
                backed up with legal requirements for state and               the unit.
                federal consistency, provides the basis for imple-
                mentation of the holistic, inter-agency approach                               Identification of
                needed for cumulative impacts management.                               Implementation Mechanisms
                The Notth Carolina Model                                               For each high risk area category, the
                                                                              most applicable alternative or combination of
                                                                              alternatives will be chosen from among the
                         Although the statutory authority and                 management tools available in the NC CMP.
                tools for cumulative impacts management have                  Different situations and goals dictate the use of
                e)dsted in the NC CMP since its inception, they               different management strategies. Various combi-
                have not been applied specifically for this pur-              nations of regulatory action, land use planning,
                pose. Putting them together for the specific                  and inter-agency coordination will be devised to
                purpose of managing cumulative impacts requires               address the situations of different high risk categories.
                a new analytical and structural model consisting

                Cumulative Impacts Management- Page 46

                                        impimnentadon                                 high risk areas, could also be a valuable manage-
                                                                                      ment tool for maintaining riparian areas in water
                                Specific policies and rules applicable to             quality threatened areas.
                       each category of high risk area will be developed
                       to apply the appropriate implementation mecha-                          Several possibilities exist for applying
                       nisms. Different management strategies, and                    AEC boundary modifications to cumulative im-
                       thus different rules, will need to be applied to               pacts management. Including contiguous land
                       high risk areas than to other areas. This will                 areas around outstanding resource waters, prima-
                       require CRC action to designate high risk areas                ry nursery areas, and coastal wetlands within the
                       and adopt appropriate rules for their manage-                  designated AEC area would allow management of
                       ment. Implementation will also require close                   the resources and the lands most directly affect-
                       coordination with other agencies in the applica-               ing them under one set of rules designed to
                       tion of their regulatory and management authori-               protect the resources from cumulative and second-
                       ties in high risk areas.                                       ary impacts as well as direct impacts. Widening
                                                                                      the estuarine shoreline AEC in water quality high
                       Management Strategies                                          risk areas could be valuable in protecting estuar-
                                                                                      ine water quality from the impacts of shoreline
                                                                                      acitivities.
                                The management tools available in the
                       NC CMP provide a basis for managing cumulative                          Modifying AEC use standards in existing
                       impacts if they are applied effectively. The risk              AECs within high risk areas is probably the most
                       and area-based management strategy implies                     feasible way of applying the CAMA regulatory
                       that certain parts of the coastal area, the high               program to cumulative impacts management.
                       risk areas, need to be treated differently from                Applying somewhat different rules in high risk
                       others. This will entail some changes in the way               areas would reflect the unique situations of these
                       that CAMA management mechanisms are ap-                        areas and the fact that activities that are appro-
                       plied.                                                         priate elsewhere may not be appropriate in these
                                                                                      areas.
                                The CAMA Regulatory Program
                                                                                                      Land Use Planning
                                The difficulties in performing objective
                       and legally defensible cumulative impact assess-                        The local land use planning component of
                       ments for individually proposed projects are so                the NC CMP can be a critical aspect of cumula-
                       great that this approach is presently an infeasible            tive impacts management. Its use in this contex:t,
                       way to use the CAMA regulatory program for                     however, will require some changes in planning
                       cumulative impacts management. A more feasi-                   guidelines and procedures.
                       ble approach would be to modify the CAMA
                       regulatory structure as it applies to designated                        The regional risk assessment being used
                       high risk areas. This could be done through                    to identify high risk areas provides a regional
                       designating new AECs in high risk areas, increas-              context into which local cumulative impacts
                       ing the geographic extent of AECs in high risk                 management can fit. Transfer to local govern-
                       areas, or applying different use 'Standards to                 ments of information gathered and analyzed in
                       existing AECs in high risk areas.                              the regional assessment can provide the link be-
                                                                                      tween regional and local perspectives necessary to
                                While several CAMA-authorized AEC                     make this happen. Providing this information
                       categories could be useful in cumulative impacts               and assisting local governments in applying it to
                       management, designation of new AECs is not an                  their local situations will improve the accuracy
                       appropriate approach for wide-scale use.             In        and consistency of information used for planning
                       limited cases, however, it should be considered.               and help to focus attention on high risk areas and
                       The natural and cultural resource AEC category,                sensitive resources.
                       in particular, could be of value in providing
                       protection for sensitive resources of more than                         The most straight-forward way to apply
                       local significance in high risk areas. The high                regional information to local planning would be to
                       risk designation would indicate the presence of                use hydrologic units as planning units. Data and
                       significant threats to those resources. The desig-             analyses from the regional assessment could be
                       nation of public trust shoreline AECs, at least in             provided to local governments, which would use

                                                                                               Cumulative Impacts Management- Page 47

                this- information as the basis for sub-plans for             local and state levels, cumulative impacts man-
                each HU within their jurisdictions. While there              agement through local land use planning could be
                are difficulties in changing to watershed-based              highly effective.
                planning, the long-term advantages in the context
                of a resource protection oriented planning pro-                          Inter-Agency coordination
                gram are compelling., Basing local plans on
                hydrologic units would improve the environmen-                        Many local, state, and federal agencies
                tal soundness of local plans and would fit local             play significant roles in determining land use
                planning into a nested system of watershed units             patterns and managing resources in the coastal
                that could integrate planning, cumulative impacts            area. Cumulative impacts management requires
                management, and information management at                    that the actions of these agencies be coordinated
                the local, state, and federal levels.                        toward achieving common goals. The NC CMP
                                                                             must play the key role in coordinating agency
                        In order for local land use planning to              activities to address the situations in high risk
                specifically address the situations in high risk             areas, and specific means of inter-agency coordi-
                areas, planning for those areas must be different            nation must be included in a cumulative impacts
                than for other areas. Somewhat different plan-               management strategy.
                ning guidelines need to be developed for applica-
                tion to high risk areas. The particular conditions                    The Division of Environmental Manage-
                leading to the high risk must be addressed and               ment's   Basinwide Water Quality Planning Pro-
                dealt with in plans for high risk HUs. The type              gram, the Water Supply Planning Program imple-
                of special planning attention appropriate will               mented by the Division of Water Resources, and
                depend upon the nature of conditions in the HU               the Coastal Nonpoint Pollution Control Program
                and the nature of the risk.                                  being developed by the Division of Coastal Man-
                                                                             agement provide excellent opportunities for inter-
                        Cumulative impacts management will not               agency coordination in cumulative impacts man-
                be successful unless local plans are consistent              agement. All of these programs, as well as other
                with and provide local implementation for region-            opportunities for coordination, must be integrated
                al cumulative impacts management goals. This                 into a cumulative impacts management strategy.
                requirement needs to be added to review criteria
                for land use plan certification, and the regional                     In particularly severe situations in which
                goals need to be incorporated into the NC CMP.               the problems of high risk areas cannot be ad-
                The goals should include specific objectives for             dressed by other means, coordination and man-
                local action in each category of high risk area.             agement could be achieved through development
                                                                             of Special Area Management Plans. Since SAMP
                        Improving coordination among plans in                is a difficult process that requires the full com-
                the same subregion is perhaps the most pressing              mitment of all parties and often necessitates the
                change needed to address cumulative impacts                  development of new implementation mechanisms,
                through local planning. This could best be                   its practicality for wide-scale cumulative impacts
                achieved by timing land use plan updates on a                management is limited.
                river basin basis. Updating all plans within a
                river basin at the same time and requiring local             Conclusions
                governments to coordinate plans for shared
                hydrologic units would provide a sound basis for                      The potential for successful cumulative
                integrated watershed planning. This approach                 impacts management exists within the North
                would also present the opportunity for imple-                Carolina Coastal Management Program. The
                menting the DEM basinwide plan for the river                 basic statutory authorities and program struc-
                basin.                                                       tures are in place, and the regional assessment
                        Plans must be implemented to be effec-               being performed by DCM will identify areas at
                tive.  CAMA needs to be amended to require                   highest risk. An overall cumulative impacts
                consistency between land use plans and local                 management strategy must be developed, adopted
                ordinances. If land use plans and local ordinanc-            by the CRC, and implemented, however, to make
                es are consistent with cumulative impacts man-               the effort successful.    The cumulative impacts
                agement 'als and policies adopted by the CRC,                management strategy must include a means of
                          90                                                 legally designating high risk areas, together with
                and if the plans are implemented at both the

                Cumulative Impacts Management- Page 48

                      specific means of addressing the risks in those             program alone, It stresses the need for a renewed
                      areas.                                                      inter-agency and state-local cooperative effort "to
                                                                                  establish a comprehensive plan for the protection,
                              The CAMA land use planning program                  preservation, orderly development, and manage-
                      and inter-agency coordination are the most                  ment of the coastal area olNorth Carolina" (G.S.
                      promising implementation mechanisms for cumu-               113A-102(a)). As such, it encourages the ftdl
                      lative impacts management. The CAMA regula-                 implementation of CAMA through realization of
                      tory program has limited value as a cumulative              the vision for coastal management expressed by
                      impacts management tool because of the limited              the General Assembly in 1974 and in North Caro-
                      geographic area to which it applies and the                 lina's original coastal plan (NOAA, 1978).
                      difficulty of assessing the cumulative impacts of
                      individual projects. The use of Special Area
                      Management Planning in cumulative impacts
                      management is limited to highly unique situa-
                      tion8 because of its difficulty and expense.

                              Incorporating CAMA land use planning
                      into a cumulative impacts management strategy
                      will necessitate several changes in planning
                      procedures and guidelines. Planning should be
                      done by hydrological units, with particular atten-
                      tion to HUs designated as high risk areas.
                       pecific guidelines for treatment of high risk
                      areas in local plans need to be incorporated into
                      S

                      the planning guidelines, and local policies for
                      those areas must be consistent with regional
                      goals. Land use plan updates should be per-
                      formed simultaneously for all jurisdictions in a
                      river basin to allow for better coordination and for
                      implementation of the basinwide plan.

                              DCM must take the initiative in achiev-
                      ing coordination with other agencies in address-
                      ing situations in high risk areas. When appropri-
                      ate, DCM can play a role in programs of other
                      agencies by providing information, helping identi-
                      fy problem areas, and participating in plans and
                      decisions. This is being performed with Basin-
                      wide Planning, Water Supply Planning, and the
                      Coastal Nonpoint Pollution Control Program.
                      When active DCM involvement is impractical or
                      inappropriate, state consistency should be fully
                      implemented to ensure consistent action in regard
                      to cumulative impacts management. To the
                      extent possible, formal consistency agreements
                      should be developed with those agencies most
                      involved in activities influencing the coastal area.

                               Application of this cumulative impacts
                      management strategy to the North Carolina
                      Coastal Area will provide a comprehensive means
                      of managing and minimizing adverse effects of
                      growth and development. The strategy recognizes
                      that cumulative impacts are the result of total
                      patterns of growth and development and, thus,
                      cannot be managed through the CAMA regulatory

                                                                                           Cumulativo Impacts Managemont- Page 49

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                                                                                                                                1

                                                            REFERENCES CITED

                     Barnthouse, L.W. and G.W. Suter (eds.) 1986. User's Manual for Ecological Risk Assessment. ORNL-6251.
                             Oak Ridge National Laboratory, Oak Ridge, TN.

                     Beanlands, , G.E., W.J. Erckmann, G.H. Orians, J. O'Riordan, D. Policansky, M.H. Sadar, and B. Sadler
                             (eds.). 1986. Cumulative Environmental Effects: A Binational Perspective. The Canadian
                             Environmental Research Council and The United States National Research Council, Ottawa,
                             Ontario and Washington, D.C.

                     Bedford, B. L. 1990. Increasing the scale of analysis: The challenge of cumulative impact assessment for
                             Great Lakes wetlands. In Proceedings ofan International Symposium: Wetlands ofthe Great Lakes:
                             Protection and Restoration Policies: Status of the Science, edited by J. Kusler and R. Smardon, pp.
                             186-194. Association of State Wetland Managers and Great Lakes Research Consortium, NY.

                     Bedford, B.L. and E.M. Preston. 1988. Developing the scientific basis for assessing cumulative effects of
                             wetland loss and degradation on landscape systems of wetlands: scientific status, prospects, and
                             regulatory perspectives. Environmental Management 12(5):751-771.

                     Bell, C.R. et al. 1983. Currituck County Outer Banks Carrying Capacity Study. Department of City &
                             Regional Planning, Univ. of North Carolina, Chapel Hill.

                     Brower,D.J. and D. S. Carol. 1987. Managing Land- Use Conflicts: Case Studies in Special Area Manage
                             ment. Duke University Press. Durham, NC.

                     Clark, W.C. 1986. The cumulative impacts of human activities on the atmosphere. In G.E. Beanlands, et
                             al., (eds.) Cumulative Environmental Effects: A Binational Perspective. Canadian Environmental
                             Assessment Research Council/U.S. National Research Council. Ottawa, Ont. and Washington, D.C.

                     Contant, C.F- and L.L. Wiggins. 1991. Defining and analyzing cumulative environmental impacts.
                             Environmental Impact Assessment Review 11:297-309.

                     DCM. 1992a. Final Assessment of the North Carolina Coastal Management Program. Report to the Office
                             of Ocean and Coastal Resource Management, NOAA, U.S. Dept. of Commerce performed under the
                             Coastal Zone Enhancement Grants Program, �309, CZMA. NC Division of Coastal Management,
                             Raleigh. January 10, 1992.

                     DCM.    1992b. Final Strategy for Achieving Enhancements to the North Carolina Coastal Management
                             Program. Proposal to the Office of Ocean and Coastal Resource Management, NOAA, U.S. Dept. of
                             Commerce for implementation of the Coastal Zone Enhancement Grants Program, �309, CZMA. NC
                             Division of Coastal Management, Raleigh. March 25, 1992.

                     DEM. 1991. North Carolina's Whole Basin Approach to Water Quality Management: Program Description.
                             Report No. 91-08. NC Dept. of Environment, Health and Natural Resources, Div. of Environmental
                             Management, Water Quality Section, Raleigh, NC.

                     Dickert, T., J. Sorenson, R. Hyman, and J. Burke. 1976. Collaborative Land Use Planning for the Coastal
                             Zone: Halfmoon Bay Case Study. Vol. II. IURD Monograph 28. Institute of Urban and Regional
                             Development, Univ. of California, Berkeley.

                     Dickert, T.G. and A.E. Tuttle. 1985. Cumulative impact assessment in environmental planning. a coastal
                             wetland watershed example. Environmental Impact Assessment Review. 5:37-64.

                                                                                      Cumulative Impacts Management- Page 51

                Dodd, R.C., G. McMahon, and S. Stichter. 1992. Watershed Planning in the Albemarle-Pamlico Estuarine
                        System. Report 1 -Annual Average Nutrient Budgets. Center for Environmental Analysis, Research
                        Triangle Institute. APES publication no. 92-10. Albemarle-Pamlico Estuarine Study, NC Dept. of
                        Environment, Health and Natural Resources, Raleigh.

                Dodd, R.C., P.A. Cunningham, R.J. Curry, and S.J. Stichter. 1992. Watershed Planning in the Albemarle-
                        Pamlico Estuarine System. Report 6 - Subbasin Profiles and Critical Areas. Center for Environmen-
                        tal Analysis, Research Triangle Institute. APES publication no. 93-01. Albemarle-Pamlico Estuarine
                        Study, NC Dept. of Environment, Health and Natural Resources, Raleigh.

                Gosselink, J.G., G.P. Shaffer, L.C. Lee, D.M. Burdick, D.L. Childers, N.C. Leibowitz, S.C. Hamilton, R.
                        Boumans, D. Cushman, S. Fields, M. Koch, and J.M. Visser. 1990. Landscape conservation in a
                        forested wetland watershed: Can we manage cumulative impacts? BioScience 40, No. 8:588-600.

                Gosselink, J.G. and L.C. Lee. 1989. Cumulative impact assessment in bottomland hardwood forests.
                        Wetlands 9:83-174.

                Hardin, G. 1968. The Tragedy of the Commons. Science 162:1243-1248.

                Hunsaker, C.T., R.L. Graham, G.W. Suter, R.V. ONeill, L.W. Barnthouse, and R.H. Gardner. 1990.
                        Assessing ecological risk on a regional scale. Environmental Management 14(3):433-445.

                Hunsaker, C.T. 1993. Ecosystem assessment methods for cumulative effects at the regional scale.
                        Environmental Analysis: The NEPA Experience, pp. 480-491. Oak Ridge National Laboratory. Oak
                        Ridge, TN.

                Institute for Environmental Negotiation. 1991. Management of Cumulative Impacts in Virginia: Identifying
                        the Issues and Assessing the Opportunities.. Report prepared for the Virginia Council on the
                        Environment's Coastal Resource Management Program. Univ. of Virginia, Charlottesville.
                        December, 1991.

                Johnston, C.A., N.E. Detenbeck, J.P. Bonde and G.J. Niemi, 1988. Geographic information systems fo
                        cumulative impact assessment. Photogrammetric Engineering and Remote Sensing, Vol. 54, No. 11,
                        pp. 1609-1615.

                Lee, L.C. and J.G. 0osselink. 1988. Cumulative impacts on wetlands: linking scientific assessments and
                        regulatory alternatives. Environmental Management 12(5):591-602.

                Leibowitz, S.G., B. Abbruzzese, P.R. Adamus, L.E. Hughes, and J.T. Irish. 1992. A Synoptic Approach to
                        Cumulative Impact Assessment: A Proposed Methodology. EPA/600/R-92/167, US EPAEnvironmen-
                        tal Research Laboratory, Corvallis, OR.

                Leibowitz, S-G, E.M. Preston, L.Y. Arnaut, N.E. Detenbeck, C.A. Hagley, M. E. Kentula, RX Olson, W. D.
                        Sanville, and R.R. Sumner. 1992. Wetlands Research Plan FY92-96. EPA/600/R-921060. EPA
                        Environmental Research Laboratory, Corvallis, OR.

                NOAA. 1978. State of North Carolina Coastal Management Program and Final Environmental Impact
                        Statement. Office of Coastal Zone Management, National Oceanic and Atmospheric Administration,
                        U.S. Dept. of Commerce. Washington, D.C.

                NOAA and EPA. 1993. Coastal Nonpoint Pollution Control Program. Program Development and Approval
                        Guidance. National Oceanic and Atmospheric Administration and U.S. Environmental Protection
                        Agency, Office of Water. Washington, D.C. January, 1993.

                Science Advisory Board. 1990. ReducingRisk: Setting Priorities and Strategies for Environmental Protection.
                        SAB-EC-90-021. U.S. Environmental Protection Agency, Science Advisory Board, Washington, D.C.

                Cumulative Impacts Management- Page 52

                    SCS. 1992. Plan of Work for a Hydrologic Unit River Basin Study - State of North Carolina. USDA, Soil
                           Conservation Service, Raleigh, NC. January 14, 1992.

                    Williamson, S.C., 1992. Cumulative Impacts Assessment and Management Planning: Lessons Learned to
                           Date. USFWS National Ecology Research Center, Fort Collins, CO.

                                                                                 Cumulative Impacts Management- Page 53

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             Cumulative Impacts Management- Page 54
                                                                                                                                1

                                                                   APPENDICES

                                                   CUMULATIVE IMPACT INDICATORS
                                                         CONTAINED IN PC-BASED
                            POPULATION/DEVELOPMENT/RESOURCES INFORMATION SYSTEM

                      Agriculture: Uvestock and Poultry                          Development
                      Beef Feedlots (< 300 Head, > 300 Head)                     Building Permits -All residential
                      Dairy Farms (< 70 Head, > 70 Head)                         Building Permits -Amusement/ Recreation
                      Hog Farms (< 200 Head, > 200 Head)                         Building Permits -Multi-family Residential
                      Horse Stables    200 Head, > 200 Head)                     Building Permits -One-family Residential
                      Poultry Farms    15,000 Birds, > 15,000 Birds)             Building Permits -Hotels and Motels
                                                                                 Building Permits -Retail
                      Agriculture: Farming                                       Building Permits -industrial
                      Land in Farms (acres, % of HU)                             Highway Mileage:
                      Land with Best Mgmt Practices (acres, % of HU)                Total (miles)
                      Land w/o Best Mgmt Practices (acres, % of HU)                 Primary (miles, % of total)
                      Land in Conservation Tillage (acres, % of HU)                 Secondary (miles, % of total)
                      Land w/o Conservation Tillage (acres, % of HU)                Paved (miles, % of total)
                      Harvested Cropland (acres, % of HU)                           Unpaved (miles, % of total)
                      Hay Crops (acres, % of HU)                                 Rail lines (miles)
                      Irrigated Land (acres, % of HU)                            Increase of primary & secondary roads (miles, %)
                      Pasture Land (acres, % of HU)                              Increase of paved vs. unpaved Roads (miles, %)
                      Row Crops (acres, % of HU)

                      Primary                                                    Economic
                      Estuarine Waters (acres, % of HU)                          Ag-Related Business (number, employees, income)
                      Freshwater Lakes                                           Farms (number, employees, income)
                      HU Name                                                    Fisheries Business (number, employees, income)
                      Receiving HU                                               Forestry/Wood- Using Business (number, employees,
                      Receiving Water Body                                       income)
                      Primary Water Body                                         Lodging Establishments (number, employees,
                      Secondary Water Body                                       income)
                      Shoreline                                                  Manufacturing Establishments (number, employees,
                      Waterways w/ Vegetated Buffers (miles, % of HU)            income)
                      Population 1970                                            Marinas (number, employees, income)
                      Population 1980                                            Mining Establishments (number, employees, in-
                      Population 1990                                            come)
                      Population Growth '70-'80                                  Recreation Business (number, employees, income)
                      Population Growth '80-'90                                  Restaurants (number, employees, income)
                      Counties                                                   Retail Establishments (number, employees, income)
                      Total HU size
                      Land area (acres, % of HU)
                      Water area (acres, % of HU)                                Groundwater
                      Stream length (miles)                                      Groundwater Contamination Incidents
                      Stream order (miles, % of stream length)                   Groundwater Class (acres, % of HU)
                                                                                 Groundwater Contamination Area (acres, % of HU)
                                                                                 Groundwater Capacity Use Areas (acres, % of HU)

                                                                                         Cumulative Impacts Management- Page 55

                Land and Estuarine Resources                                  Shellfish
                Anadromous Fish Streams (miles, % of streams)                 Shellfish Waters (acres, % of HU)
                Coastal Reserve Waters (acres, % of HU)                       Shellfish Closures- Permanent (acres, % of HU)
                Coastal Reserve Lands (acres, % of HU)                        Shellfish Closures-Temporary (acres, % of HU)
                Federal Ownership:
                   National Parks (acres, % of HU)                            Water Quality-Open water
                   National Forests (acres, % of HU)                          Class B. Waters (acres, % of water area)
                   Military Reservations (acres, % of HU)                     Class C Waters (acres, % of water area)
                   USFWS Refuges (acres, % of HU)                             HQW Waters (acres, % of water area)
                   Federal Ownership--other (acres, % of HU)                  NSW Waters (acres, % of water area)
                State Ownership:                                              ORW Waters (acres, % of water area)
                   Game Lands (acres, % of HU)                                Swamp Waters (acres, % of water area)
                   State parks (acres, % of HU)                               SA Waters (acres, % of water area)
                   State Forests (acres, % of HU)                             SB Waters (acres, % of water area)
                   State Ownership--other (acres, % of HU)                    SC Waters (acres, % of water area)
                Natural Heritage Inventory Sites (count)                      WS-1 Waters (acres, % of water area)
                Primary Nursery Areas (acres, % of water area)                WS-11 Waters (acres, % of water area)
                Private Preservation (acres, % of HU)                         WS-111 Waters (acres, % of water area)
                Secondary Nursery Areas (acres, % of water area)
                Threatened/Endangered Species Habitat                         Water Quality-Streams
                Water Supply Watersheds (acres, % of HU)                      Class B Streams (miles, % of streams)
                                                                              Class C Streams (miles, % of streams)
                Land Use                                                      HQW Streams (miles, % of streams)
                Total Wetland Area (acres, % of HU)                           NSW Streams (miles, % of streams)
                High Value Wetland (acres, % of HU)                           ORW Streams (miles, % of streams)
                Medium Value Wetlands (acres, % of HU)                        Swamp Water Streams (miles, % of streams)
                Low Value Wetlands (acres, % of HU)                           SA Streams (miles, % of streams)
                Predominant Land Cover                                        SI3 Streams (miles, % of streams)
                                                                              SC Streams (miles, % of streams)
                Population and Housing                                        WS-1 Streams (miles, % of streams)
                Avg Seasonal Population                                       WS-11 Streams (miles, % of streams)
                Peak Seasonal Population                                      WS-111 Streams (miles, % of streams)
                Units w/o indoor plumbing
                Units with Septic Tanks                                       Water Quality-Use Support
                Units on Central Water Systems                                Algal Blooms (Count, Extent/Severity)
                Units on Central Sewer                                        Fish Kills (Count, Extent/Severity)
                Units with Wells                                              Streams Fully Supporting (miles, % of streams)
                                                                              Streams Support Threatened (miles, % of streams)
                Permits                                                       Streams Partially Supporting (miles, % of streams)
                Air Emission Permits - PSD                                    Streams Non-Supporting (miles, % of streams)
                Air Emission Permits - Toxic                                  Waters Fully Supporting (acres, % of water area)
                CAMA Minor Permits                                            Waters Support Threatened (acres, % of water
                CAMA General Permits                                          area)
                CAMA Major Permits                                            Water Partially Supporting (acres, % of water area)
                CAMA Exemptions                                               Waters Non Supporting (acres, % of water area)
                CWA Sect. 404/10 Permits
                Landfill Permits - Municipal
                Landfill Permits - Industrial
                Non-Discharge Permits
                NPDES Permits - Industrial
                NPDES Permits - Other
                NPDES Permits - POTW
                Stormwater Discharge Permits
                Sedimentation Control Plans
                Septic Tank Permits

                Cumulative Impacts Management- Page 56

                                                                      GIS DATABASES IN
                                POPULATION/DEVELOPMENT/RESOURCES INFORMATION SYSTEM

                         Ambient Water Quality Monitoring Sites                            Natural Heritage Element Occurrence Sites
                         Anadromous Fish Spawning Areas                                    Natural Areas
                         Artificial Marine Reefs                                           Outstanding Resource Waters
                         Bottom Sediment Sampling Sites                                    Peat Resources
                         Business Locations by SIC Code                                    Proposed Critical Habitat Areas
                         CAMA Major Permits                                                SCS Hydrologic Unit Boundaries
                         Census Blocks                                                     Shipwreck Locations
                         Census Block Groups                                               Soil Associations - General
                         Closed Shellfish Areas                                            Soil Series - Detailed
                         Coastal Marinas                                                   Solid Waste Facilities
                         Coastal Reserves                                                  Spiny Mussel Locations
                         County Boundaries with Shorelines                                 State Owned Complexes
                         Federally Owned Lands                                             State Parks
                         Fisheries Nursery Areas                                           Stream Gauging Stations
                         Geodetic Control - NAD83                                          Submerged Rooted Vascular Plants (SAV)
                         Geology - general bedrock,     faults, dikes, and sills           Superfund Sites
                         Ground Water RechargelDischarge Areas                             Surface Water Intakes
                         Hard Bottom/Live Bottom Trawl and Dive Locations                  Transportation - primary roads
                         Hazardous Waste Facilities                                        Transportation - detailed
                         Historic Sites and Districts                                      Transportation - general
                         Hurricane Storm Surge Inundation Areas                            USGS 1:24,000 Scale Neatlines
                         Hydrography - detailed                                            USGS 1:100,000 Scale Neatlines
                         Hydrography - general                                             Water Supply Watersheds
                         land Use/Land Cover from TM Imagery -          1918               Wetland Restoration Sites
                         Military Airspace                                                 Wetland Types
                         Municipal Boundaries                                              Wetland Functional Significance
                         National Wetlands Inventory                                       Wildlife Resources Commission Gamelands
                         NPDES Permit Sites

                                                                                                    CUMUlative Impacts Management- Page 57

                                                                                                                                    NOAA COASTAL SERVICES CTR LIBRARY         I
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