[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

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                                            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 ï¿½309 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 ï¿½113A-
                  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
             ï¿½113A-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               ï¿½404 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 ï¿½309 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 (ï¿½319 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
            ï¿½319 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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                         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
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                         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:
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                 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, ï¿½309, 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, ï¿½309, 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.





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            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.


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                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.






















































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                                                               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


























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