FINDINGS FOR THE
   MASSACHUSETTS COASTAL NONPOINT PROGRAM


FOREWORD

     This document contains the findings for the coastal
nonpoint pollution control program submitted by the
Commonwealth of Massachusetts pursuant to Section 6217(a) of
the Coastal Zone Act Reauthorization Amendments of 1990
(CZARA).  The findings are based on a review of the
Massachusetts Coastal Nonpoint Program, Final Program
Submittal, July 1995 and supplemental material provided by
Massachusetts subsequent to the program submittal.  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 Massachusetts 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 Commonwealth of
Massachusetts 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 the
Commonwealth's program.  It also provides the rationale for the
findings and includes conditions that will need to be met for
Massachusetts to receive final approval of its program.  We
recognize that Massachusetts has already proposed some changes
to its program that would, if finalized, ensure implementation of
the management measures in conformity with the section 6217(g)
guidance.  In these cases, the conditions are based on the
Commonwealth's proposed changes. 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 state 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 state 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 Massachusetts
Coastal Nonpoint Program, Final Program Submittal, 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 Commonwealth
has included in its program submittal.  Further information and
analysis, including material provided by Massachusetts subsequent
to the program submittal, 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 & Watershed Protection Division
Nonpoint Source Control Branch
401 M Street, S.W. (4503-F)
Washington, DC  20460
Contact:  Kristen Martin (202/260-7108)

NOAA/Office of Ocean and Coastal Resource Management
Coastal Programs Division
SSMC-4, N/ORM3
1305 East West Highway
Silver Spring, MD   20910
Contact: Joelle Gore (301/713-3117, x177)

U.S. EPA, Region I
Kennedy Federal Building
Boston, MA  02203
Contact:  Bruce Rosinoff (617/565-3546)

     I.   BOUNDARY

FINDING:  Massachusetts has expanded the management area
recommended by NOAA and EPA to include the Nashua and
Concord River watersheds which drain to the Merrimack River. 
The Commonwealth's boundary 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 Massachusetts.

     II.  AGRICULTURE

FINDING:  Massachusetts' program includes management
measures in conformity with the 6217(g) guidance.  Massachusetts
has identified back-up enforceable policies and mechanisms for
implementing the agricultural management measures and has
developed a strategy for implementation but has not yet
demonstrated the ability of these authorities to ensure
implementation throughout the 6217 management area.

CONDITION:  Within three years, Massachusetts will
demonstrate its ability to achieve implementation of the
agricultural management measures using the approach described in
its coastal nonpoint program strategy for agriculture (see Section
III.1.3 pages 98-100 of the program submittal).  Within one year,
the Commonwealth will identify measurable results to be achieved
during this three year timeframe.

RATIONALE:  Existing programs for agriculture in
Massachusetts are largely voluntary, but the Commonwealth has
identified a back-up enforceable authority through its Surface
Water Quality Standards, and has additional authorities under the
Pesticide Control Act and Wetlands Protection Act.  The
Commonwealth will rely on the general authority contained in the
Surface Water Quality Standards (314 CMR 4.00) in combination
with its voluntary programs to implement the agricultural
management measures.  Massachusetts has stated that it will work
to establish interim implementation goals to define measurable
progress, and that it will evaluate the need for additional control
mechanisms after three years.

     Massachusetts has described how it will use its voluntary
programs to achieve management measure implementation.  The
farm planning model described on page 93 of the program
submittal will be used in combination with U.S. Department of
Agriculture (USDA) conservation plans.  Technical guidance will
contain performance standards in conformity with the measures
and practices in the section 6217(g) guidance.  The Commonwealth
has also described how it will apply the Basin Planning Approach
and Surface Water Quality Standards to require implementation of
farm plans in cases where water quality violations persist.

     To strengthen its voluntary approach, Massachusetts is
encouraged to develop and implement the Commonwealth's farm
planning model and technical assistance program, and work with
USDA in its development and implementation of conservation
plans, in a manner that ensures that all applicable management
measures are fully implemented on farms in the 6217 management
area.

     While the program submittal discussed
each of the elements of the section 6217(g)
management measures for agriculture, some
elements were not fully detailed.  The
submittal did not specify that the components
of the Nutrient Management Program include a
written nutrient management plan and nutrient
application rates based upon realistic yield
expectations, but in subsequent discussions
with Massachusetts Coastal Zone Management
staff, the Commonwealth informed EPA and NOAA
that this is the case.  Massachusetts should
ensure that these aspects of the nutrient
management measure are fully addressed in
program implementation.  Where irrigation is
practiced in Massachusetts, the measurement
of both crop water needs and quantity of
water applied to crops should be addressed as
the key elements of the irrigation management
measure.
                       
     III. FORESTRY

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

RATIONALE:  Massachusetts has a Forest Cutting Practices Act
(FCPA) that contains the primary mechanisms for implementing
the forestry management measures.  Requirements and standards
governing operations related to forest cutting, as well as references
to standards in the Massachusetts Forestry Best Management
Practices (BMP) Manual, are expressly contained in the FCPA
(3.04 CMR 11.00 et seq.).  Other enforceable policies and
mechanisms the Commonwealth uses to implement forestry
management measures include the Wetlands Protection Act (MGL
c.131 s.40), the Slash Law (MGL c.48 ss16-16A), and the Pesticide
Control Act (MGL c. 132B).

     IV.  URBAN RUNOFF

     A.   NEW DEVELOPMENT
          
FINDING:  Massachusetts' program does not yet contain
management measures in conformity with the 6217(g) guidance. 
Massachusetts has identified back-up enforceable policies and
mechanisms for implementing the management measure but has
not yet demonstrated the ability of these authorities to ensure
implementation throughout the 6217 management area.

CONDITION:  Within two years, Massachusetts will finalize the
proposed Stormwater Management Performance Standards. 
Within three years, Massachusetts will demonstrate its ability to
achieve implementation of the new development management
measure using the approach described in its coastal nonpoint
program strategy for the Stormwater Initiative (see Section III.3.4
pages 173-176 of the program submittal).  Within one year, the
Commonwealth will identify measurable results to be achieved
during this three year timeframe.

RATIONALE:  The Massachusetts Department of Environmental
Protection (DEP), in coordination with the Massachusetts Coastal
Zone Management (MCZM) Office, has proposed Stormwater
Management Performance Standards which will meet the
requirements of this management measure.  The proposed
Performance Standards address a number of areas, including the
avoidance of direct stormwater discharges to surface waters and
wetlands; managing increases in peak flood rates and elevations;
control of post-development runoff volumes; control of total
suspended solids (TSS); and operation and maintenance for
stormwater facilities.  Specifically, the Performance Standards will
require that post-development peak discharge rates not exceed pre-
development peak discharge rates for 2- and 10-year storm events,
and that 80 percent TSS be removed on an average annual basis. 
The Commonwealth is also developing an accompanying guidance
document, Performance Standards and Guidelines for Stormwater
Management in Massachusetts to explain the Performance
Standards, establish design criteria, identify management practices
to achieve the Standards, and provide technical and regulatory
guidance.

       As described on pages 173-176 of the program submittal
and further detailed in draft Policy/Regulatory Guidance developed
by the Stormwater Advisory Committee, Policy Subcommittee
(provided to NOAA and EPA subsequent to the program
submittal), the stormwater performance standards are designed for
use under multiple statutory and regulatory authorities of the DEP. 
The Commonwealth proposes to use the regulatory review
processes of the Wetlands Protection Act (MGL c.131 s.40) and its
regulations (310 CMR 10.00) as one of the primary means to
ensure implementation of the performance standards.  Technical
guidance (developed by the Commonwealth as part of the
Stormwater Initiative and described above) will be provided to
each of the local Conservation Commissions, which will use the
performance standards in review of any wetlands permitting
activity.  Because of the broad jurisdiction exercised by
Conservation Commissions and the DEP under the Wetlands
Protection Act, Massachusetts proposes that the Commonwealth
has the ability to ensure implementation of this management
measure.

     B.   WATERSHED PROTECTION AND EXISTING
     DEVELOPMENT

FINDING:  Massachusetts' program includes management
measures in conformity with the 6217(g) guidance, except for
watershed protection, and includes enforceable policies and
mechanisms that can be used to ensure implementation.

CONDITION:  Within two years, Massachusetts will complete
development of the "Soil and Water Conservation in Urbanizing
Areas of Massachusetts" guidance document.

RATIONALE:  Massachusetts proposes to use a variety of
programs to implement the watershed protection management
measure.  As described for the construction site erosion
management measure below, the Commonwealth is developing
guidelines for soil and water conservation in urbanizing areas that
can accomplish protection of erosion-prone soils.  As described on
page 176 of the program submittal, this new technical guidance,
entitled "Soil and Water Conservation in Urbanizing Areas of
Massachusetts," will be integrated into both Commonwealth and
local level planning and resource protection programs.  The
environmental evaluation program under the Massachusetts
Environmental Policy Act (MEPA)(MGL c. 30, ss. 61-62H), which
calls for the review of the impacts of certain large-scale projects on
aquatic resources, and the Watershed Protection Act, which calls
for the implementation of comprehensive watershed protection
plans for drinking water supplies, will also be used to preserve
areas that provide important water quality benefits.  Massachusetts
needs to complete development of the guidance document to
provide the technical basis for implementing watershed protection.

     The Commonwealth's Watershed Initiative, which
establishes a model framework to involve stakeholders in the
development and implementation of watershed action plans,
includes a multi-year process that will ultimately be implemented
in each of the Commonwealth's twenty-seven river basins and
drainage areas.  This initiative involves a watershed resource
assessment and outreach effort; water quality and quantity and
habitat inventory; an assessment of collected data to identify basic
objectives and preliminary results; development of management
goals for water quality, including point and nonpoint sources;
identification of watershed protection and restoration goals, and; an
evaluation of results to determine progress and identify next steps. 
A schedule for implementing this new watershed approach is
provided in Appendix G of the program submittal.  This effort is to
be commended and provides a framework for implementing the
existing development management measure.

     We encourage the Commonwealth to further strengthen
implementation of the above programs and ensure that, together,
they provide a comprehensive approach to achieving the watershed
protection and existing development management  measures.  We
also applaud the Commonwealth for recently adopting river
protection legislation that will create riparian buffer zones to
protect water quality supplies and fisheries and wildlife habitat and
prevent polluted runoff.  This will further assist the
Commonwealth in achieving the measures.

     C.   SITE DEVELOPMENT, CONSTRUCTION SITE
     EROSION AND SEDIMENT CONTROL, and
     CONSTRUCTION SITE CHEMICAL CONTROL

FINDING:  Massachusetts' program does not yet contain
management measures in conformity with the 6217(g) guidance,
but includes enforceable policies and mechanisms to ensure
implementation.

CONDITION:  Within two years, Massachusetts will finalize and
adopt the proposed revisions to its State Building Code (780CMR)
as outlined in the program submittal (see Section II.C.).  

RATIONALE:  The Commonwealth has proposed to revise the
State Building Code to meet these management measures.  Under
the Building Code, all new development is subject to review by
local building inspectors.  As described on page 182 of the
program submittal, specific language in the Building Code will
require the use of best management practices to prevent
unnecessary soil disturbance, offsite sediment movement, and
water quality degradation from the improper storage, use, or
disposal of construction chemicals.

     In support of the proposed revisions to the Building Code,
MCZM plans to provide technical assistance targeted to local
officials to more effectively implement these management
measures.  The Commonwealth will also adopt new technical
guidance entitled "Soil and Water Conservation in Urbanizing
Areas of Massachusetts" as an official Commonwealth document
and reference it in the Building Code.

     D.   NEW AND OPERATING ONSITE DISPOSAL
     SYSTEMS (OSDS)

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

RATIONALE:  The siting, design, installation, and operation of
new and operating OSDS is regulated by DEP through its
Groundwater Discharge Program (MGL Ch. 221A, s.13).  DEP has
promulgated regulations under 310 CMR 15.00 Title 5 of the State
Environmental Code.  The Commonwealth recently revised the
Code (effective at the end of March 1995).  The revisions
significantly improve the Code, providing comprehensive
requirements that meet both the new and operating OSDS
management measures.

     E.   POLLUTION PREVENTION

FINDING:  Massachusetts' program contains management
measures in conformity with the 6217(g) guidance.

RATIONALE:  In its program submittal, the Commonwealth
describes a number of programs and efforts in place in the
Commonwealth that cover all aspects of this management measure. 
These programs and efforts include the Municipal Household
Hazardous Waste Program, the Save the Bay Program, the
Massachusetts Bay Program, the Groundwater Discharge Program,
the Massachusetts Adopt-A-Stream program, and various
education and outreach efforts.

     F.   ROADS, HIGHWAYS, AND BRIDGES

FINDING:  Massachusetts' program does not yet include
management measures for roads, highways, and bridges in
conformity with the 6217(g) guidance.  The Commonwealth has
identified back-up enforceable policies and mechanisms for
implementing the management measures and has developed a
strategy for implementation but has not yet demonstrated the
ability of these authorities to ensure implementation throughout the
6217 management area.

CONDITION:  Within two years, Massachusetts will complete
and implement the strategy for roads, highways, and bridges
described in items 1-6 on pages 201 and 202 of the program
submittal.

RATIONALE:  Massachusetts has proposed to complete the
development of an environmental specifications manual that can be
used in concert with the existing design manual of the
Massachusetts Highway Department (MHD).  In addition,
implementation of DEP's Stormwater Initiative will establish a
basis for project controls at the local level.  Completion of the DEP
urban stormwater guidance and the MHD specifications guidance
will provide the technical basis 
for ensuring that projects are implemented in accordance with the
6217(g) management measures.

     MEPA, the Wetlands Protection Program, the Stormwater
Initiative, the Hazardous Material Control Program, and the Clean
State Executive Order (#350) provide the means to implement
these management measures.  Massachusetts has proposed to
develop explicit policies to clarify the relative responsibilities of
State and local agencies where their jurisdiction and authority
intersect.  MHD manages both construction and operation and
maintenance contracts and has the ability to write specific
environmental controls into those contracts.  The MEPA review
process requires environmental review and certification for larger
land disturbances and road designs, but does not ensure that
management measures are implemented for smaller projects.  The
Commonwealth has proposed to examine MEPA thresholds and
consider a standard based on impervious cover in order to evaluate
the negative impacts of surface water runoff for roads, highways
and bridges.
     V.   MARINAS AND RECREATIONAL BOATING

FINDING:  Massachusetts' program does not yet include
management measures in conformity with the 6217(g) guidance
but includes enforceable policies and mechanisms that can be used
to ensure implementation.

CONDITION:  Within two years, Massachusetts will finalize the
development of technical guidance to provide agency staff with
information necessary to make consistent and effective permit and
enforcement decisions.

RATIONALE:  The Massachusetts Chapter 91 Waterways
Program (Massachusetts General Laws, Chapter 91) and
regulations (310 CMR 9.00), along with the Wetlands Protection
Act and other environmental and planning programs, can be used
to ensure the implementation of the marina management measures
as specified in the 6217(g) guidance.  The Chapter 91 Waterways
Program provides that jurisdictional activities must comply with
any and all applicable environmental laws of the Commonwealth. 
However, specific nonpoint source controls that may be required
by these authorities are not always clearly identified and the
Waterways Program currently does not have a set of standard
marina management measures that are used in permitting
decisions.

     The Commonwealth recognizes this limitation and is
proposing to develop guidance documents that will be used in the
review of permit applications for new and expanding marina
developments, including requirements for stormwater
management.  As stated in on page 242 of the program submittal,
the proposed guidance document will provide the technical basis
for determining compliance and, if needed, enforcement actions by
DEP.  The establishment of a uniform and predictable protocol
(through the guidance document for marinas and recreational
boating), linked with the existing permitting programs, will
provide Massachusetts with a program that can meet the 6217(g)
management measures.

     VI.  HYDROMODIFICATION

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

RATIONALE:  Massachusetts requires a permit
for new fill or structures and dredging in
channels.  To receive a Chapter 91 Waterways
Permit, regulations require that projects not
cause or contribute to erosion,
sedimentation, inadequate flushing,
stagnancy, interference with anadromous fish
runs, or the degradation of aquatic habitat. 
Projects involving channelization of more
than 2,000 feet of waterway, or dredging more
than 500 feet of waterway, also undergo a
formal comprehensive review process under
MEPA.  The Commonwealth's Waterways Program
has been expanded to identify and implement
projects that restore water quality and
aquatic habitat in existing modified
channels.

     Massachusetts regulates construction of
new dams and alteration or repair of existing
dams.  To obtain a permit, erosion and
sediment controls must be included as part of
the project's design plan.  The Dam Safety
Program notifies project sponsors of the
Commonwealth's Hazardous Material Control
Program regulations, which address the
storage, transport, and disposal of toxic
pollutants, as well as the development of
emergency preparation and response plans. 
The Office of Dam Safety also performs
inspections of dam projects and conducts full
engineering and hydrological inspections as
warranted.  In addition, the Office of Dam
Safety requires specific details regarding
the timing, extent, phases, materials, and
designs of construction and
repair/alterations.

     The management measure to protect
surface water quality and habitat will be
implemented through the Commonwealth's Basin
Planning Approach.  The Commonwealth's
surface water permitting and planning
responsibilities focus on management of
watersheds.  Nonpoint sources are being
assessed and impacts from the operation of
dams will be identified, with special focus
on low flow problems and on violations of
water quality standards.  All structures,
including dams, in tidelands and navigable
rivers are licensed through the Chapter 91
Program.

     The Commonwealth has a comprehensive
program to meet the management measure for
eroding shorelines and streambanks.  During
the assessment phase of the Basin Planning
Approach, the Commonwealth will conduct
inventories of nonpoint sources for
individual watersheds, including
identification of sites with serious erosion
problems.  Based on this information, either
proactive restoration work or enforcement
procedures can be targeted to rectify these
erosion problems.  Projects on shorelines and
streambanks are to be comprised of
nonstructural engineering when possible. 
Regulations for Coastal Shorelines contain
strict standards for siting, engineering
design, and construction of proposed new
work.  

     In addition, the Wetlands Protection
Program requires permits for activities in
shoreline areas, and proposed projects must
not alter the resource area or its functions. 
Local Conservation Commissions or the DEP may
impose additional conditions on permits if
necessary to ensure protection of critical
areas and functions along shorelines and
streambanks.  Regulations for Inland Banks,
and Regulations for Coastal Shorelines
contain strict standards for siting,
engineering, and construction of projects,
and require that proposed new work shall not
impair the physical stability of the bank, or
alter water quality or habitat.

     VII. WETLANDS, RIPARIAN AREAS AND VEGETATED
     TREATMENT SYSTEMS

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

RATIONALE:  Massachusetts requires a permit for any activity
involving dredge-and-fill, or other alterations, within a wetland
area or within a 100-foot buffer zone around a wetland area.  In
addition, the Wetlands Protection Act provides the ability to
address activities outside of wetland areas and their buffer zones. 
The Act contains language that expands jurisdiction to include any
activity outside of the buffer zone that alters an area subject to
protection under the Act.  Regulations include explicit criteria for
the protection of water quality and aquatic habitat functions of
wetland and aquatic systems which are addressed in the review of
permit applications.

     The Commonwealth's Stormwater Initiative will also help
implement the management measure for protection of wetlands, by
requiring the best practical method of treatment of new stormwater
discharges to wetlands.  Other practices to protect wetland
functions such as acquisition efforts, local bylaws, and increased
buffer zones, will be achieved through planning processes at the
town level.

     The Commonwealth's Wetland Restoration and Banking
Program coordinates efforts to implement restoration of wetlands
on a statewide basis.  Many federal and local organizations have
become involved as partners with the Commonwealth in
restoration projects.  Examples of ongoing wetlands restoration
projects are found in the Neponset River Watershed, Conte
National Wildlife Refuge, Cape Cod, and Sagamore Marsh.

     The use of vegetated treatment systems will also be
encouraged with the implementation of the new Statewide
Stormwater Initiative.  The Commonwealth is finalizing a manual
of performance standards and guidelines for stormwater
management in Massachusetts, which will provide comprehensive
and effective guidance on the siting, design, operation, and
maintenance of vegetated treatment systems.

          VIII.     ADMINISTRATIVE COORDINATION

FINDING:  Massachusetts' program establishes mechanisms to
improve coordination among Commonwealth agencies and
between Commonwealth and local officials.

RATIONALE:  Massachusetts proposes to implement the coastal
nonpoint program through a combination of several programs
administered by agencies primarily described under Sections II.2.2
and 2.3 of the program submittal.  The Commonwealth has
negotiated Memoranda of Understanding between the relevant state
agencies to ensure appropriate coordination among participating
agencies.  Copies of these are included under Appendix A of the
Commonwealth's program.  Several efforts are proposed to
strengthen coordination among state agencies and between state
and local officials.  These  include interagency agreements, an
Interagency Outreach Coordinating Committee, and several
interagency work groups comprised of members of the public and
private sector who will also be responsible for measuring the
effectiveness of program coordination and evaluation of the
performance of the coastal nonpoint program.  

     IX.  PUBLIC PARTICIPATION

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

RATIONALE:  The Commonwealth describes many activities
that provide opportunities for public participation in the
development and implementation of its coastal nonpoint program. 
Opportunities for public participation include the continued use of
special work groups for each Section 6217 source category,
distribution of a community survey to all towns located within the
Commonwealth's 6217 management area, publication of a series of
articles on the 6217 program, several workshops held in various
regions of the Commonwealth, and development of a long-term
outreach strategy that will be updated annually.  Comments
solicited and received on the effectiveness of the Commonwealth's
coastal nonpoint program will be used to evaluate and improve the
public's opportunities to participate.  

     X.   TECHNICAL ASSISTANCE

FINDING:  Massachusetts has included programs that will
provide technical assistance to local governments and the public
for implementing additional management measures.

RATIONALE:  Massachusetts has proposed a variety of technical
assistance efforts for local governments and the public.  These
efforts will emphasize several issues relative to nonpoint source
pollution activities.  Technical assistance will be conducted by a
variety of sources including state agencies such as MCZM,
Massachusetts DEP and Department of Food and Agriculture
(DFA); and federal agencies, such as NRCS, in concert with DFA. 
The assistance will include traditional state agency technical
assistance such as the preparation of guidance documents and other
manuals, training workshops and seminars, one-on-one assistance
by the state technical assistance staff, and financial assistance
programs such as the Massachusetts Coastal Zone Management
Program and EPA's Section 319 program.

     XI.  ADDITIONAL MANAGEMENT MEASURES

FINDING:  Massachusetts' program provides for implementation
and continuing revision of additional management measures
applicable to critical coastal areas and cases where section 6217(g)
measures are fully implemented but water quality threats or
impairments persist.

RATIONALE:  The DEP's Basin Planning Program will be used
to determine the effectiveness of (g) measure implementation. 
Using a five-year rotation schedule, the Commonwealth will
evaluate all 28 of its basins to determine the results of (g) measure
implementation and water quality monitoring efforts.  Based on
these evaluations, appropriate additional management measures, if
required, will be developed and implemented on a site-specific
basis.  This process generally follows the second approach
described in the program guidance whereby the 
Commonwealth relies on site-specific evaluations to determine
whether additional management measures are required.

     XII. CRITICAL COASTAL AREAS

FINDING:  Massachusetts' program includes a process for the
continuing identification of critical coastal areas adjacent to
impaired and threatened coastal waters.

RATIONALE:  The Commonwealth has developed threshold
criteria based on a site specific evaluation process to identify
critical coastal areas.  The evaluation process incorporates the use
of various sources of data to identify critical areas within each of
the seven major coastal areas of the Commonwealth.  The review
process involves a two-level screening and evaluation approach. 
The first level of review involves the initial screening of the seven
major coastal regions in order to determine their relation to the
threshold criteria.  In those areas where conditions or trends meet
the threshold criteria, they will receive further evaluation during
the second level.  Generally, the Commonwealth's review process
follows the second approach described in the program guidance
whereby a State relies on site-specific evaluations to determine the
extent of the critical coastal areas.

         XIII.    MONITORING

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

CONDITION:  Within two years, Massachusetts will develop a
plan that enables the Commonwealth to assess over time the extent
to which implementation of management measures is reducing
pollution loads and improving water quality.

RATIONALE:  In the program submittal, Massachusetts
identifies a number of monitoring activities that are currently being
conducted, including traditional water quality monitoring under
section 305(b) of the Clean Water Act and land use trends and
analysis that provide information on geographic distribution of
potential sources.  There is also a discussion of the use of fate and
transport modeling for specific geographic areas and loading
assessment models that can be used to evaluate relative loadings of
nonpoint source pollutants.  However, Massachusetts does not
describe how the these individual monitoring techniques will be
coordinated and applied to assess over time whether the
management measures are reducing pollutant loads and improving
water quality.

         XIV.     EVALUATION FOR BACK-UP AUTHORITIES

    For management measures where Massachusetts is
proposing to use back-up authorities to ensure implementation,
including the measures for agriculture, new development, and
roads, highways and bridges, the Commonwealth will develop and
apply credible survey tools to demonstrate the ability of the
Commonwealth'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 3 year period described in the March 16, 1995 guidance issued
by NOAA and EPA entitled Flexibility for State Coastal Nonpoint
Programs, whether the Commonwealth's approach has been
successful or whether new, more specific authorities will be
needed.