FINDINGS FOR THE
       GUAM COASTAL NONPOINT PROGRAM


FOREWORD

     This document contains the findings for the coastal
nonpoint pollution control program submitted by the Territory of
Guam pursuant to Section 6217(a) of the Coastal Zone Act
Reauthorization Amendments of 1990 (CZARA).  The findings are
based on a review of the Guam Coastal Nonpoint Source Pollution
Management Plan, July 1995.  The National Oceanic and
Atmospheric Administration (NOAA) and the U.S. Environmental
Protection Agency (EPA) reviewed this information and evaluated
the extent to which it conforms with the requirements of CZARA.

     NOAA and EPA commend Guam on the substantial
amount of time and effort put into developing your program and
we appreciate the commitment you have shown to complete an
ambitious task with limited resources.  We will continue to work
with coastal states and territories to ensure that these findings
represent an accurate assessment of current state and territory
abilities and efforts to address coastal nonpoint source pollution. 
We recognize that there may be further administrative changes to
the coastal nonpoint program that will impact these findings and
we assure you that, once such changes are finalized, we will review
these findings in light of the changes and make any necessary
adjustments. 


APPROVAL DECISION

     NOAA and EPA approve the coastal nonpoint pollution
control program submitted by the Territory of Guam pursuant to
Section 6217(a) of the Coastal Zone Act Reauthorization
Amendments of 1990, subject to certain conditions.  

     This document provides the specific findings used by
NOAA and EPA as the basis for the decision to approve Guam's
program.  It also provides the rationale for the findings and
includes conditions that will need to be met for Guam to receive
final approval of its program.  The timeframes associated with
conditions become effective on the date of the approval letter for
these findings.
INTRODUCTION

      This document is organized by the major nonpoint source
categories and subcategories identified in the section 6217(g)
guidance and the administrative elements identified in the program
guidance (including the boundary for the 6217 management area). 
Where appropriate, NOAA and EPA have grouped categories and
subcategories of management measures into a single finding.  The
structure of each finding follows a standard format.  Generally, the
finding is that the Territory's program includes or does not include
management measures in conformity with the (g) guidance and
includes or does not include enforceable policies and mechanisms
to ensure implementation.  In some cases, the finding reflects that
the Territory has identified a back-up enforceable policy, but has
not yet demonstrated the ability of the authority to ensure
implementation.  For further understanding of terms in this
document, the reader is referred to the following:

Guidance Specifying Management Measures for Sources of
Nonpoint Pollution in Coastal Waters (EPA, January 1993)
Coastal Nonpoint Pollution Control Program:  Program
Development and Approval Guidance (NOAA and EPA, January
1993)
Flexibility for State Coastal Nonpoint Programs (NOAA and EPA,
March 1995)

     The references in this document refer to the Guam Coastal
Nonpoint Source Pollution Management Plan, July 1995 ("program
submittal").  NOAA and EPA have written this document as
succinctly as possible.  We have relied upon, but do not repeat
here, the extensive information that the Territory has included in its
program submittal.  Further information and analysis is contained
in the administrative record for this approval decision and may be
reviewed by interested parties at the following locations:

EPA/Office of Wetlands, Oceans and Watersheds
Assessment and Watershed Protection Division
Nonpoint Source Control Branch
401 M Street, SW (4503-F)
Washington, DC  20460
Contact:  Robert Goo (202-260-7025)

NOAA/Office of Ocean and Coastal Resource Management
Coastal Programs Division
SSMC-4, N/ORM3
1305 East-West Highway
Silver Spring, MD  20910
Contact:  Matthew Arnn (301-713-3121 x183)

U.S. EPA, Region IX
Office of Pacific Island Programs (E-4)
75 Hawthorne Street
San Francisco, CA  94105
Contact:  Norman Lovelace (415-744-1484)

     I.   BOUNDARY

FINDING: Guam's 6217 management area, defined as all land
areas on the island of Guam, with excepted areas under the control
of the U.S. Navy and U.S. Air Force, is sufficient to control the
land and water uses that have or are reasonably expected to have a
significant impact on the coastal waters of Guam.  Guam is
encouraged to work closely with the Navy and Air Force in the
implementation of its coastal nonpoint source program. 

     II.  AGRICULTURE

FINDING:  Guam's program  includes management measures in
conformity with the 6217(g) guidance.  The Territory has identified
a back-up enforceable policy and mechanism for implementing the
management measures but has not yet demonstrated the ability of
the authority to ensure implementation throughout the 6217
management area.  Guam has presented sufficient justification for
exclusion of the grazing management measure.

CONDITION:   Within one year, Guam will develop a strategy (in
accordance with Section XII, page 12) to implement the
agricultural management measures throughout the 6217
management area. 

RATIONALE:  Guam has identified management practices in its
document.  Guam has some authority which may serve to
implement the agriculture management measures.  Guam has
authority to address the animal waste management measures
through the Feedlot Waste Management Regulations.  Guam's
submittal includes proposals for expansion or modification of
existing regulations or the development of new regulations which,
if achieved, could serve to implement the management measures. 
NOAA and EPA encourage the Territory to consider improvements
to its regulations to better address waste utilization.  Guam has
proposed to use the Water Pollution Control Act (10 GCA 47) as a
back up enforcement authority where a water quality violation has
occurred.  

     Guam has stated that grazing impacts are not a significant
contribution to pollutant loadings to Guam's coastal waters.  The
acreage of pastureland in Guam is not significant; the 1992 Census
of Agriculture listed 183 acres of pastureland, except cropland
pasture, on 46 farms.  
     III. FORESTRY

FINDING:  Guam has provided sufficient justification to support a
categorical exclusion of forestry from its coastal nonpoint program. 


RATIONALE:  Guam states that there is currently no commercial
silvicultural activity, and none is expected on the Island. 
Moreover, it is unlikely that Guam's ecosystem could support
silviculture.





     IV.  URBAN

     A.   NEW DEVELOPMENT and SITE DEVELOPMENT

FINDING:  Guam's program does not include management
measures in conformity with the 6217(g) guidance.  The Territory
has identified a back up enforceable policy and mechanism to
implement the management measures but has not yet demonstrated
the ability of this authority to ensure implementation throughout
the 6217 management area.

CONDITION:  Within three years, Guam will include in its
program management measures in conformity with the 6217(g)
guidance for the new development and site development
management measures.  Within one year, Guam will develop a
strategy (in accordance with Section XII, page 12) to implement
the new development and site development management measures
throughout the 6217 management area.  

RATIONALE:  Guam, with EPA's assistance, has been assessing
the applicability of the new development management measure in
Guam, taking into account Guam's unique topographic and climatic
characteristics.  It is estimated that a tropical 2-year 24-hour storm
results in runoff volumes too large to treat economically or
practically and that the reduction of 80 percent of the total
suspended solids loadings from the initial 0.5 inches of runoff
would provide a more appropriate standard of performance for
water quality best management practices.  Guam intends to use the
results of the current assessment effort to propose and document an
alternative management measure for new development.  In its
program submittal, Guam states that it will revise the Guam Storm
Drainage Manual to incorporate this standard and implement the
new development management measure.  The above condition
provides time to complete analysis and development of appropriate
management measures.

     The program submittal also states that the I Tano'ta Land
Use Plan, which is proposed to be adopted by Guam Legislature
and implemented by Guam EPA and other Territorial agencies,
contains development performance standards in partial conformity
with the 6217(g) recommended practices for new development and
site development.  NOAA and EPA continue to encourage Guam
to implement and adopt plans such as the I Tano'ta Plan in a
manner consistent with the 6217(g) management measures.  

     Guam's Water Pollution Control Act (10 GCA 47) has been
identified in the submittal as a backup enforceable policy and
mechanism for these management measures.  However, Guam has
not demonstrated the ability of the authority to ensure
implementation of the management measures throughout the 6217
management area.

     B.   WATERSHED PROTECTION and EXISTING
     DEVELOPMENT

FINDING:  Guam's program does not include management
measures in conformity with the 6217(g) guidance.  Guam has
identified a backup enforceable policy and mechanism to
implement these management measures but has not yet
demonstrated the ability of this authority to ensure implementation
throughout the 6217 management area.

CONDITION:  Within three years, Guam will include in its
program management measures in conformity with the 6217(g)
guidance for the watershed protection and existing development
management measures.  Within one year, Guam will develop a
strategy (in accordance with Section XII, page 12) to ensure
implementation of the watershed protection and existing
development management measures throughout the 6217
management area.

RATIONALE:  Although Guam currently does not implement a
comprehensive watershed program, the Guam Coastal
Management Program, the Bureau of Planning, and the Guam EPA
jointly conduct several prototype watershed planning efforts.  For
example, in its program submittal, Guam states that it hopes to
obtain voluntary compliance with these management measures
through the Ugum River Watershed Plan, which will serve as a
model for other watershed planning efforts.  In addition, the I
Tano'ta Land Use Plan, which is proposed to be adopted by the
Guam Legislature and implemented by the Guam EPA and other
Territorial agencies, is anticipated to provide mechanisms for the
implementation of the existing development management measure. 
In its program submittal, Guam also states that the Department of
Public Works is developing a reporting, evaluation, tracking,
planning, design, and improvement management system for
structural responses to urban runoff problems.  The Guam EPA and
the Bureau of Planning will assist the Department of Public Works
in monitoring the success of these efforts.  NOAA and EPA
encourage Guam to pursue these efforts as part of its strategy for
fully implementing these management measures.  

     In addition to the potential authority of the I Tano'ta Land
Use Plan, Guam's Water Pollution Control Act (10 GCA 47) has
been identified as a backup enforceable policy and mechanism to
implement the management measures.  

     C.   CONSTRUCTION SITE EROSION AND SEDIMENT
     and CHEMICAL CONTROL

FINDING:  Guam's program includes management measures in
conformity with the 6217(g) guidance, except for construction site
chemical control, and includes enforceable policies and
mechanisms to ensure implementation.
 
CONDITION:  Within three years, Guam will include in its
program management measures in conformity with the 6217(g)
guidance for construction site chemical control.

RATIONALE:  Guam's site erosion and sedimentation control
rules, administered by the Guam EPA, require that an erosion
control plan be approved by the Guam EPA before the Department
of Public Works issues a permit for clearing, grading, filling,
excavating, or other earth-moving operations.  The rules require
that earth-moving operations are conducted to prevent accelerated
land erosion, transportation of sediment off site, and that the
disturbed area is minimized and stabilized as soon as possible after
final grading.

     Guam has authority to address construction site chemical
control under the Hazardous Waste Management Regulations and
other authorities.  Guam states that it will develop additional
regulations to address practices to help achieve the construction
site chemical control management measure, including the storage,
cover, and isolation of construction materials; maintenance and
washing of construction equipment; and fuel and vehicle
maintenance.  NOAA and EPA encourage Guam to develop and
finalize such regulations to ensure implementation of the
appropriate practices to achieve the management measure.

     D.   NEW and OPERATING ONSITE DISPOSAL
     SYSTEMS (OSDS)

FINDING:  Guam's program includes management measures in
conformity with the 6217(g) guidance and includes enforceable
policies and mechanisms to ensure implementation.

RATIONALE:  Guam's Individual Wastewater System
Regulations (10 GCA Chapter 48) require a permit from the Guam
EPA for the installation, construction, and repair or additions of
onsite disposal systems.  The regulations establish protective
setbacks from surface waters and separation distances between
systems and groundwater, and require the Guam EPA to assess
plans for proposed systems to assure site suitability.  The Guam
EPA inspects systems throughout their construction and after
construction is completed.  For operating systems, owners are
required to empty and clean the tank or pit when necessary or when
ordered by the Administrator in the interest of public Health. 
Section XVIII.C. and D. of Title 10 specify that septic tanks should
be inspected at intervals of no more than 3 years to determine
whether cleaning should occur.  In addition to these requirements,
Guam EPA conducts inspections as part of their routine
enforcement activities, inspecting approximately 10 percent of
operating systems each year.  

     The program submittal states that there are few onsite
systems in the Territory (less than 2000), that the number of new
systems is declining, and that identified nutrient problems are
related to faulty primary sewage treatment (point sources) and
agricultural feedlot waste. Therefore, NOAA and EPA agree with
Guam's assessment that it is not necessary to address denytrifying
systems at this time.
 
     E.   POLLUTION PREVENTION

FINDING:  Guam's program includes management measures in
conformity with the 
6217(g) guidance.

RATIONALE:  In its program submittal, Guam describes a
number of existing programs and activities that implement the
components of this management measure.  These programs and
activities include a household hazardous waste education program,
anti-littering and recycling education programs, and an
"Adopt-A-Road" program.  Guam also plans to initiate several new
efforts such as a storm drain awareness program, an impervious
parking lot outreach program, 
and improvements in animal collection and carcass disposal.

     F.   ROADS, HIGHWAYS, AND BRIDGES
 
FINDING:  Guam's program does not include management
measures for roads, highways, and bridges in conformity with the
6217(g) guidance except for construction site erosion and sediment
control.  Guam's program does not include enforceable policies
and mechanisms to ensure implementation except for planning
siting, and design, and construction site erosion and sediment
control.

CONDITION:  Within three years, Guam will include in its
program management measures in conformity with the 6217(g)
guidance for roads, highways, and bridges, and enforceable
policies and mechanisms to ensure implementation of these
measures throughout the 6217 management area.

RATIONALE:  Guam has a permit program requiring approved
erosion and sediment control plans for all clearing and grading. 
Guam's erosion and sediment control regulations include the
authority to inspect construction sites and require compliance with
approved plans.  The authority also provides the ability to stop
work.  

     For the planning, siting, and design management measure,
Public Law 20-147 requires review of highways for consistency
with the master plan, and Subdivision Law 21 GCA 62 requires
that specifications for subdivision roads conform to Department of
Public Works standards.  However, the Territory still needs to
address the specific planning, siting, and development management
measures.

     Guam is planning several program revisions to achieve
conformity with the other 6217(g) management measures,
including:  (1) developing memorandums of understanding
between the Guam Department of Public Works and Guam EPA to
ensure consistent Territorial review of all road, highway, and
bridge projects; (2) revisions to the Guam Storm Drainage Manual
to include standards for bridges; (3) developing standards for
operation and maintenance; (4) development and adoption of
Department of Public Works regulations to protect unstable and
highly erodible areas or areas that require excessive cut and fill;
and (5) adoption of the proposed I Tano'ta Plan that will establish
standards for setbacks from sensitive areas.

     Guam has also proposed to implement the construction site
chemical control measure by developing regulations to address
chemicals on construction sites.  Guam does not address the runoff
systems management measure, and needs to include the measure in
its program.  NOAA and EPA encourage Guam to develop and
adopt the suggested regulations to ensure implementation of the
appropriate practices.

     V.   MARINAS AND RECREATIONAL BOATING

FINDING:  Guam's program does not include management
measures in conformity with the 6217(g) guidance.  Guam has
identified back up enforceable policies and mechanisms to
implement the management measures, but has not yet
demonstrated the ability of these authorities to ensure
implementation of the measures throughout the 6217 management
area.  Guam has not provided sufficient information to justify an
exclusion of the shoreline stabilization management measure.

CONDITION:  Within two years, Guam will include in its
program management measures in conformity with the 6217(g)
guidance for marinas and recreational boating, and enforceable
policies and mechanisms to ensure implementation throughout the
6217 management area.

RATIONALE:  Guam proposes to adopt a comprehensive set of
regulations authorizing the Guam Environmental Protection
Agency to review and approve management practices for new and
expanding marinas (see page 5-3, Guam Nonpoint Source
Pollution Management Plan).  These regulations are planned to
require practices in conformity with the management measures and
to include enforceable policies and mechanisms to ensure
implementation.  Currently, the Territory has a general water
quality law (Water Pollution Control Act) and building code
requirements authorizing the Guam EPA to review building
permits.  This authority can be used to address marinas.  Guam also
has laws establishing Water Use Master Plans which can be used to
protect shallow water habitat.  These authorities provide backup
enforceable policies and mechanisms pending adoption of specific
regulations governing marina developments, as proposed.

     Guam's discussion of shoreline stabilization notes that there
is no evidence of significant problems with erosion along its
shorelines.  Shoreline erosion is very minor due to the
predominance of coral reefs which act to attenuate wave energy
significantly before the energy is transferred to the shoreline. Guam
has not needed to erect protection structures or provide beach
nourishment or other techniques to stabilize its shorelines.  
However, the management measure for shoreline stabilization is
also intended to be applied by states and territories to new and
expanding marinas where site changes may result in shoreline
erosion.  This scenario was not discussed in the Guam program
submittal.   

     VI.  HYDROMODIFICATION

FINDING:  Guam's program includes management measures and
enforceable policies and mechanisms in conformity with the
6217(g) guidance for erosion and sediment control at dams. 
Guam's program does not include management measures in
conformity with the 6217(g) guidance for:  (1) channelization and
channel modification, (2) chemical and pollutant control at dams;
(3) protection of water quality and habitat from the effects of dams,
and (4) shorelines and streambanks.  Guam has identified backup
enforceable authorities, but has not yet demonstrated the ability of
the authorities to ensure implementation of the management
measures throughout the 6217 management area.  

CONDITION:  Within two years, Guam will include in its
program management measures in conformity with the 6217(g)
guidance for channelization and channel modification, pollutant
and chemical control at dams, protection of water quality and
habitat from the effects of dams, and shorelines and streambanks. 
Within one year, Guam will develop a strategy (in accordance with
section XII, page 12) to implement the hydromodification
management measures throughout the 6217 management area.  

RATIONALE:  Management measures for erosion and sediment
controls at dams are implemented through the Guam Soil Erosion
and Sedimentation Control Regulations.  These regulations state
that a Clearing and Grading permit will not be issued without an
approved Erosion and Sedimentation Control Plan.

     Under authority of the Water Pollution Control Act, the
Guam EPA plans to develop rules, regulations on and standards
specifically for the evaluation of channel modification and
channelization projects by December 31, 1996.  All future
channelization and channel modification projects will be required
to have the results of modeling appended to the mandatory
environmental assessment required by the Guam EPA and the
Department of Agriculture.  Based on the results of the completed
environmental assessments, the Guam EPA will prescribe
management practices considered suitable and necessary for
individual projects.  The Guam EPA and Guam Department of
Public Works will also develop a manual of approved best
management practices by December 31, 1996.  Guam has not yet
proposed a process for implementing the portion of the
management measures for channelization and channel modification
which concerns operation and maintenance of existing modified
channels.

     In its program submittal, Guam states that the Guam
Pesticide Act and the Hazardous Waste Management Regulation
implement the chemical control management measure.  These
authorities address pesticides and petroleum and spill prevention,
but do not address other pollutants associated with chemical
control associated with gasoline, paints, and sealers.  Guam states
that it will develop additional regulations to address practices to
help achieve the management measure.   NOAA and EPA
encourage Guam to develop and finalize such regulations to ensure
implementation of the appropriate practices to achieve the
management measure.

     Management measures to protect surface water quality and
instream and riparian habitat from the effects of dams will be
implemented by the Guam EPA, the Department of Agriculture,
and the Public Utility Agency of Guam, which will develop
standards and practices prior to 
December 31, 1996 for habitat protection from planned dams and
other water impoundments.  

     Guam has not yet proposed a process to protect surface
waters and habitat from the effects of the one dam presently on
Guam.  Given the documentation of significant water quality
degradation of downstream water quality, it is important that Guam
develop a process to apply the management measure to the impacts
associated with this dam.  

     Guam's Department of Agriculture is to be the lead agency
in implementing management measures for streambanks and
shorelines, in coordination with the Guam EPA, the Department of
Public Works, and the Coastal Management Program.  These
agencies plan to develop necessary legislation to detect, evaluate,
and mitigate streambank and shoreline erosion, and to implement
practices contained in the 6217(g) guidance, as appropriate.

     Until the rules and regulations described above are
developed and promulgated, Guam will need to develop a strategy
for using the Water Pollution Control Act as a backup authority to
ensure implementation of the hydromodification measures
throughout the 6217 management area.

     VII. WETLANDS, RIPARIAN AREAS AND VEGETATED
     TREATMENT SYSTEMS

FINDING:  Guam's program does not include management
measures in conformity with the 6217(g) guidance.  Guam has
identified backup enforceable authorities for the management
measure for protection of wetlands and riparian areas, but has not
yet demonstrated the ability of these authorities to ensure
implementation throughout the 6217 management area.

CONDITION:  Within three years, Guam will include in its
program management measures in conformity with 6217(g)
guidance for the protection and restoration of wetlands and riparian
areas, and vegetated treatment systems.  Within one year, Guam
will develop a strategy (in accordance with section XII, page 12) to
implement the management measure for protection of wetlands and
riparian areas throughout the 6217 management area.

RATIONALE:  Guam has several authorities which have the
potential to protect the nonpoint pollution abatement functions of
wetlands, however, these authorities do not specifically require
such protection.  For example, the Guam Water Resources
Conservation Act and the Water Pollution Control Act provide
authority to protect water quality and water resources generally. 
However, Guam does not appear to have a consistent program to
ensure that wetlands protection is considered in the application of
these authorities.  The proposed Wetlands Bill has the potential to
provide the Territory with a more cohesive program for wetlands
protection.  This bill, now included in the proposed I'Tano'ta land
use plan, will better define the  linkage between Guam's authorities
and the wetlands management measures.  

     The Guam EPA promotes the restoration of wetlands and
riparian areas by directing the restoration of damaged wetlands in
cases where water quality violations are potentially present. Guam
EPA also encourages owners to restore their wetlands, but does not
have a program for accomplishing this goal.

     Guam EPA is working to promote the use of vegetative
treatment systems through its proposed design guidance and
standards for review of permit applications.  Guam is encouraged
to utilize its proposed design guidance to demonstrate compliance
with the management measure.

          VIII.     ADMINISTRATIVE COORDINATION

FINDING:  Guam's program does not include adequate
mechanisms to improve coordination among Territorial agencies
with a role in the implementation of the coastal nonpoint program.

CONDITION:  Within one year, Guam will establish a process for
ensuring coordination among Territorial agencies with a role in the
implementation of the coastal nonpoint program.

RATIONALE:  While Guam has identified possible coordination
mechanisms in the approved Guam Coastal Management Program
and Executive Orders establishing specific bodies such as the
Development Review Committee, NOAA and EPA are concerned
that these mechanisms were not effective in the development stage
of the program.  

     In addition, Guam has not provided supporting information
which would ensure that coordination takes place between the
agency assuming plan development and administrative monitoring
responsibilities and those agencies which will implement the
program.  It is noted that, to date, several key implementing
agencies have had only limited participation in the development of
the coastal nonpoint program. 
 
     There are also concerns regarding the lack of core staff
available to complete the many tasks identified in the document. 
EPA and NOAA would like to work with Guam to identify
solutions to this basic resource limitation.

     The Territory is encouraged to include in its program a
mechanism for tracking management measure implementation, as
well as legislation introduced to implement the measures.  While
not required, completion of an MOU detailing agency
responsibilities for further development of the program could
provide a means to achieve effective implementation of the
Territory's program.  

     IX.  PUBLIC PARTICIPATION

FINDING:  Guam's program provides opportunities for public
participation in the 
development and implementation of the coastal nonpoint program.

RATIONALE:  The Plan Design and Development Section of
Guam's Program submittal 
describes activities that provide opportunities for and encourage
public participation in the coastal nonpoint program.  Examples
include numerous interactive radio talk show appearances where
listeners were able to call in and express opinions about the
program, outreach through information articles and interaction with
Guam's larger civil engineering firms, the Soil and Water
Conservation Districts, schools, waste hauling contractors, and the
military.

     Guam provided a 30-day public comment period prior to
program submission.  Responses are addressed within the plan. 
While Guam has met the general requirements for providing
participatory opportunities within its program, it is encouraged to
place a greater emphasis on involving the public in a meaningful
way.

     X.   CRITICAL COASTAL AREAS, ADDITIONAL
     MANAGEMENT MEASURES and TECHNICAL
     ASSISTANCE

FINDING:  Guam's program does not include processes for the
identification of critical coastal areas or for the development and
continuing revision of management measures applicable to critical
coastal areas and cases where the 6217(g) measures are fully
implemented but water quality threats or impairments persist.  The
program does not describe efforts to provide technical assistance to
agencies and the public for implementing additional management
measures.

CONDITION:  Within two years, Guam will develop a process
for the identification of critical coastal areas and a process for
developing and revising management measures to be applied in
critical coastal areas and in areas where necessary to attain and
maintain water quality standards.  Within two years, Guam will
also develop a program to provide technical assistance in the
implementation of additional management measures.

RATIONALE:  Guam has not described how its program will
address each of these elements.  While Guam notes that its coastal
waters are among the least polluted in the United States, it does
acknowledge the presence, in certain areas, of significant sediment
plumes during storm events (sediment being a major cause of
decreased coral spawning on Guam), bacteria counts sufficient to
merit the closure of beaches for recreational purposes, high algal
activity, and corals threatened by pesticide use.

     The program does not include efforts to provide technical
assistance to agencies and the public for implementing additional
management measures.  Technical assistance may be provided
through the ongoing efforts under the 319 program.

     XI.  MONITORING

FINDING:  Guam's program does not yet include a plan to assess
over time the success of the management measures in reducing
pollution loads and improving water quality.

CONDITION:  Within one year, Guam will develop a plan that
enables the Territory to assess over time the extent to which
implementation of management measures is reducing pollution
loads and improving water quality.

RATIONALE:  Guam mentions, but does not describe, its
ongoing monitoring of chemical constituents and bacteria.  Guam
also mentions its desire to develop an integrated monitoring
strategy, as well as its plans to include coral spawn observation,
coral head surveys, and fish harvest data in its proposed biological
monitoring strategy.  The Territory also states that it will monitor
implementation of the nonpoint source program, including all
management measures and practices, permits approved and denied,
the number of cases where enforcement action is taken, and overall
trends in chemical and biological condition.  However, none of the
current or planned monitoring efforts are described in adequate
detail to determine if they might be useful to evaluate the
effectiveness of the Territory's coastal nonpoint program.

     Guam is encouraged to continue development of its
proposed monitoring program.  The Territory should include in its
plan information regarding the number and location of monitoring
stations, the types and frequency of water quality data being
collected, and the analytic approaches that will be employed in
conjunction with existing monitoring efforts to assess the success
of management measures in achieving water quality objectives. 
The Territory should include some inexpensive tracking of
management measure implementation in conjunction with water
quality monitoring as such information is needed to assess the
success of management measures in achieving water quality
objectives.

     XII. STRATEGY AND EVALUATION FOR BACK-UP
     AUTHORITIES

     Within one year, Guam will develop a strategy to
implement the agricultural management measures, urban
management measures for new development, site development,
watershed protection and existing development,
hydromodification, and wetland and riparian area protection
management measures throughout the 6217 management area. 
This strategy will include a description and schedule for the
specific steps the Territory will take to ensure implementation of
the management measures; describe how existing or new
authorities can be used to ensure implementation where voluntary
efforts are unsuccessful; and identify measurable results which, if
achieved, will demonstrate the Territory's ability to achieve
implementation of the management measures using the described
approach.

     In order to evaluate the adequacy of this strategy, Guam
will also develop and apply credible survey tools to demonstrate
the ability of the Territory's approach to achieve implementation
for these management measures.  The use of credible assessment
techniques is necessary in order for NOAA and EPA to evaluate, at
the end of the three year period described in the March 16, 1995
guidance issued by NOAA and EPA entitled Flexibility for State
Coastal Nonpoint Programs, whether the Territory's approach has
been successful or whether new, more specific authorities will be
needed.