Proceedings Prepared
by the

NATIONAL ACADEMY OF
PUBLIC ADMINISTRATION
for the National
Dredging Team
D
            redged-
           Material
     Management
 and State Coastal
     Management
         Programs:
          Lessons from
        a Workshop in
 New Orleans, Louisiana
         January 1999

NATIONAL
ACADEMY
OF PUBLIC
ADMINISTRATION

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ABOUT THE ACADEMY

The National Academy of Public Administration is an independent, nonpartisan, nonprofit
organization that assists federal, state, and local governments in improving their performance.
In 1984, the Academy was granted a congressional charter. The unique source of the Academy's
expertise is its membership—more than 480 current and former Cabinet officers, members of
Congress,  governors, mayors, legislators, diplomats, jurists,  business executives,  public
managers, and scholars who have been elected as Fellows.

Since its establishment in 1967, the Academy has assisted numerous federal agencies, congres-
sional committees, state and local governments, and institutions overseas  through problem
solving, research and innovation, and implementing strategies for change. The Academy is also
supported by businesses, foundations, and nonprofit organizations.

The Academy also promotes discourse on emerging issues of governance. It focuses on perfor-
mance and management issues, both as overarching processes and as practical considerations
for agencies and programs engaged in the full range of domestic and international concerns.

About the Center

The Academy's Center for the Economy and the Environment, which produced this report,
works with public and private institutions to protect the environment and build sustainable
regional economies. The Center focuses on improving public management and policy tools,
public involvement in decisionmaking, and the transition to performance-based management
systems at the state and national level.

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Proceedings Prepared
by the
NATIONAL ACADEMY OF
PUBLIC ADMINISTRATION
for the National
Dredging Team
MAY 1999
           redged-
          Material
     Management
and State Coastal
     Management
        Programs:
          Lessons from
        a Workshop in
 New Orleans, Louisiana
         January 1999

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The views expressed in this document are those of the contributors alone.
They do not necessarily reflect the views of the Academy as an institution.

National Academy of Public Administration
1120 G. Street, N.W
Suite 850
Washington, DC 20005

First published 1999

Printed in the United States of America

The paper used in this publication meets the minimum requirements of American
National Standard for Information Sciences — Permanence of Paper for Printed
Library Materials, ANSI Z39.48.1984.

ISBN 1-57744-030-7
Dredged-Material  Management  and State  Coastal  Management Programs:
Proceedings of a Workshop in New Orleans, Louisiana, January 1999

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           Officers of the Academy

 Jonathan B. Howes, Chair of the Board
Feather O'Connor Houstoun, Vice Chair
              R. Scott Fosler, President
              Jane G. Pisano, Secretary
             David S.C. Chu, Treasurer

                        Project Staff

  Richard A. Minard, Jr., Project Director
 Stephen Coye, Senior Research Associate
     Benita Carr, Administrative Assistant

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                            TABLE OF  CON
FOREWORD	,	  vii
EXECUTIVE SUMMARY	  ix
SETTING THE SCENE: AN INTRODUCTION TO THE ISSUES	  xi
PART ONE: RECOMMENDATIONS FROM THE WORKSHOP	   1
  A. Use the Regulatory Process to Facilitate Beneficial Uses	   3
  B. Improve Intergovernmental Coordination and Project Planning	   4
  C. Increase Funding for Beneficial Uses	   5
  D. Increase Scientific Knowledge and Public Awareness About Beneficial Uses  ...   6
PART TWO: WORKSHOP PROCEEDINGS	   9
  A. Opening Remarks: What's at Stake	   9
  B. State Coastal Management Programs and the Federal Dredged Material
     Planning Process	  11
  C. Case Studies in Dredged Material Management Planning	  13
  D. Louisiana's Use of the Coastal Wetlands Planning, Protection, and
     Restoration Act	  15
  E. Understanding and Using the Federal Budget Process	  16
  E Case Studies of Beneficial-Use Projects	  20
APPENDICES
Appendix A: List of Acronyms	  25
Appendix B: Sources of Further Information	  27
Appendix C: Workshop Agenda	  29
Appendix D: Workshop Participants  	  35

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                                                FORE
The National  Dredging Team,  the  National  Oceanic  and  Atmospheric
Administration's (NOAA) Office of Ocean and Coastal Resource Management, and
the Coastal States Organization sponsored a workshop in New Orleans on the
often troubled intersection of federal navigation dredging projects and state coastal
management programs. We started with two modest goals: to clarify dredging and
coastal management requirements, and to stimulate better communication among
federal, state, and local agencies on  these issues.

The workshop exceeded  our expectations. The participants proposed an abun-
dance of recommendations for improving intergovernmental processes related to
dredged material management in the coastal zone. The attitude and spirit of coop-
eration evident during the  workshop suggests that real progress can be made
within existing constraints.

We thank all of the participating federal and state agencies for sending their rep-
resentatives  and assisting in the planning and preparations for  the  workshop.
NOAAs Office of Ocean and Coastal Resource Management and the Coastal States
Organization were instrumental in securing the participation of state coastal man-
agement programs  and deserve special thanks. We  also thank  the American
Association of Port Authorities and the representatives of ports from  around the
country  that participated in the  workshop. Staff members of the  National
Academy of Public  Administration's Center for the Economy and Environment
facilitated the workshop and prepared this report. We diank the Academy for its
assistance and good work.

While the workshop itself was a great success, the optimism of those three days
will soon dissipate if the  participants' agencies do not commit  themselves to the
daily work needed to reach our common objectives. Two types of follow-up are
particularly required. At a local and regional level, all concerned parties must con-
tinue their efforts to  improve interagency coordination and develop long-term

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       planning processes. Second, the federal agencies must work to ensure that the
       national programs are harmonized and that appropriate guidance and policies are
       developed for implementation at local and regional levels.

       In support of this second follow-up action, the National Dredging Team will for-
       mulate an action plan that extracts key recommendations from the workshop and
       specifies how the various agencies in the federal government can make improve-
       ments in this important area.
       Richard Worthington
       U.S. Army Corps of Engineers
       Co-Chair, National Dredging Team
Craig Vogt
U.S. Environmental Protection Agency
Co-Chair, National Dredging Team
Vllll

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                         EXECUTIVE SU
This report summarizes the discussions and recommendations developed at a work-
shop on dredged material management and state coastal management programs held
in New Orleans, Louisiana, on January 20, 21, and 22, 1999. The workshop was
jointly sponsored by the National Dredging Team, the Office of Ocean and Coastal
Resource Management of  the National Oceanic and Atmospheric Administration,
and the Coastal States Organization. The National Academy of Public Administration
facilitated the workshop and prepared this report.

The workshop was designed to elucidate the difficulties in using dredged material
for beneficial purposes, and to stimulate thinking about creative ways to resolve
those difficulties. To a great extent,  the federal, state, and nongovernmental par-
ticipants at the workshop agreed that it is desirable  to use dredged material to
restore wetlands or other natural resources. The challenge is to coordinate state
and federal processes to accomplish those beneficial uses within the existing finan-
cial and legal constraints. The workshop participants' suggestions and recommen-
dations can be collected into four categories:

   • There was a widely held sentiment that the regulatory relationship between
     the U.S.  Army Corps of  Engineers  and  the  state  coastal  management
     programs can be improved through incremental steps. Improved clarity about
     goals and greater transparency in the decisionmaking process can reduce the
     conflicts between the Corps and state and local organizations.

   • In many  cases, the beneficial use of dredged-material  costs more  than
     traditional "dredge and dump" practices. Proponents of beneficial uses need
     to get involved in the  Corps' planning activities earlier, make  better use of
     existing cost-sharing mechanisms,  and identify additional project sponsors
     and  additional funding mechanisms.  Beneficial uses benefit coastal
     communities and the nation as a whole, and need funding support from a
     broader section of the population than navigation interests alone.
                                                                             I ix

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Sponsoring Agencies
The planning process and the procedures for state and federal coordination
can be improved in many ways. Earlier project planning, regular meetings
between  state  and   federal  agency  representatives,  broader  public
participation, and longer-range planning will contribute  to better  project
implementation and funding.

Better  scientific understanding  and  greater public education  about the
beneficial uses of dredged material are necessary to make better decisions and
to garner support for further expansion of these programs.

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                             SETTING THE
              An Introduction to the Issues
Dredging is critical to maritime trade and many recreational pursuits. Harbors
and channels grow more shallow with the deposition of sediment from rivers and
tributaries. This sediment must be removed periodically to maintain the depth of
the harbor. Waterways are also dredged to deepen shipping channels and con-
struct new harbor facilities, and to clean up contaminated sediments.

For much of the nation's history, the dredged material was regarded as a waste, a
view that was reflected in the historic term "dredging spoils." In recent  years,
dredged material has come to be regarded as a resource that can be reused to
advance other economic and environmental goals. Examples of beneficial uses of
dredged material include using the material for beach replenishment, wetlands
creation and replenishment,  construction of waterside  recreational  facilities and
parks, construction of shoreline protection projects, as  raw material for landside
construction projects, and in the manufacture of topsoil.


THE ROLE OF THE FEDERAL GOVERNMENT

Keeping navigation channels clear has long been regarded as a federal interest. The
U.S.  Army Corps of Engineers performs the largest portion of dredging in U.S.
waterways, either using its own dredges or through private contractors. The  Corps
is responsible for maintaining 25,000 miles of federal  navigation channels. The
Corps also issues permits for dredging to private and public organizations, such as
port authorities, marinas, and private companies with industrial harbors. The
Corps dredges about 300 million cubic yards of material from U.S. waterways each
year, and private parties dredge about 100 million cubic yards more.

The Corps of Engineers' involvement in dredging activities is rooted in a century
of federal legislation. The Rivers and Harbors Act of 1890 provided the  Corps
with the authority to maintain navigable waterways. Section 404  of the  Clean
Water Act of 1972 gave the  Corps the power to regulate discharges of dredged

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       materials into waters of the United States. The third major legislative foundation
       for  the  Corps'  dredging program is the Marine Protection, Research, and
       Sanctuaries Act  of 1972  (MPRSA), which authorizes the Corps of Engineers to
       issue permits for the transportation of dredged material to be dumped at selected
       disposal sites  in the ocean. Under the CWA and MPRSA, the Corps selects  its
       Section 404 and ocean disposal sites, and issues permits and authorizations for
       dredged material disposal, in accordance with guidelines and criteria developed by
       the Environmental Protection Agency (EPA).

       Project development goes through several stages. Projects are initiated by a local
       demand for dredging. Thereafter, the Corps carries out reconnaissance and feasi-
       bility studies of  the proposed project. At each step, there is an interplay between
       the  Corps' district office  and Corps' headquarters. With only a few exceptions,
       Congress authorizes each individual dredging project on a case-by-case basis, and
       appropriates funds for those projects on an annual basis until their completion.
       Congress also  makes annual project-specific appropriations for the maintenance of
       existing  channels and harbors.

       The Corps' regulations prescribe that the dredging project should assure that the
       disposal of dredged material from the project occurs in the "least costly, environ-
       mentally acceptable manner, consistent with engineering requirements established
       for the project." The "least costly, environmentally acceptable" alternative is termed
       the "federal standard" and is the base plan from which project planning and bud-
       geting is performed.


       STATE  ROLES IN  DREDGING AND DREDGED MATERIAL
       MANAGEMENT

       Although the federal government has an important role in dredging, state and local
       governments also have important interests and responsibilities. Many of the benefits
       of dredging—waterborne trade and water recreation—flow to regional economies.
       In similar fashion, the environmental impacts of dredging and dredged material dis-
       posal are also largely borne by the communities living near the waterways.

       The Coastal Zone Management Act of 1972 (CZMA) authorized the creation of
       state coastal management programs to comprehensively manage uses of resources
       in the coastal  zone. The statute is implemented by state coastal management pro-
       grams in partnership with the federal government. The CZMA program is admin-
       istered by the Office of Ocean and Coastal Resource Management of the National
       Oceanic and Atmospheric Administration (NOAA), which has approved 32 state
       coastal management programs under the statute.

       Section 307 of the CZMA requires that federal actions in or outside of the coastal
       zone that affect  any coastal use or resource must be consistent with the enforce-
       able policies of state coastal management programs "to the maximum extent prac-
       ticable." Federal actions that must be consistent include federal agency activities,
xii

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federal approval activities (such as federal permits for private actions), and federal
financial assistance activities. Therefore, the CZMA  consistency requirement effec-
tively incorporates the enforceable policies of state coastal management programs into
the environmental regulations with which the federal dredging plan must comply.

State governments have a second regulatory role in connection  with federal
dredged material disposal practices. Section 401 of the Clean Water Act of 1977
requires the Corps to seek a  certification from the state water quality certifying
agency that a proposed discharge of dredged material into any waters of the
United States within state jurisdiction (including the territorial seas) would not
violate applicable water quality requirements. The requirement to  comply with
applicable state water quality standards  is also incorporated into the federal reg-
ulations governing the issuance of Section 404 permits and authorizations includ-
ing the Section 404(b)(l) guidelines. The ocean dumping regulations also require
compliance with applicable marine water quality criteria.

Dredging projects  depend on a complex intergovernmental process that tries to
balance economic costs and benefits while minimizing environmental harm. On a
number of occasions in the past, the Corps and the states have found themselves
in conflict over dredging projects. The Corps seeks  to perform as much of its nav-
igation responsibilities as it can with the funds appropriated by Congress for that
purpose, and tends to regard  additional environmental components  of the dredg-
ing process as external to the navigation project itself. On the other hand, states
and  some federal agencies view the beneficial use of dredged material as an inte-
gral  part of the navigation dredging project, and seek to maximize the direct and
collateral benefits that may flow from a given dredging project. In many cases,
those benefits carry an additional cost beyond the cost projected by the Corps for
the completion of the project.  The Corps sometimes responds that these additional
features should be separately  financed by the state, or should be cost-shared with
the Corps under its beneficial-use authorities. Conflicts over financing lie at the
root of many controversies about CZMA consistency requirements and the benefi-
cial uses of dredged materials.
                                                                                1X111

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                                              PART

                Recommendations from the
                                         Workshop
This report summarizes the presentations and recommendations developed at a
workshop on dredged material management and state coastal management pro-
grams held in New Orleans, Louisiana, on January 20, 21, and 22, 1999. The
workshop was jointly sponsored by the  National Dredging Team,  the Office of
Ocean and Coastal  Resource Management of  the  National  Oceanic and
Atmospheric Administration, and the Coastal States Organization. The National
Dredging Team includes the  U.S.  Army  Corps  of  Engineers, the  U.S.
Environmental Protection Agency, the  Maritime  Administration  of the  U.S.
Department of  Transportation,  the  U.S. Fish and Wildlife Service  of the
Department of Interior, two departments of the National Oceanic and Atmospheric
Administration, the Office of Ocean and  Coastal Resource Management, and the
National Marine Fisheries Service.

The workshop was intended to bring together state and federal agency representa-
tives to discuss the connections and frictions between federal dredged material man-
agement processes and coastal management program requirements. Approximately
120 people attended the workshop, and their affiliations reflected the varied gov-
ernmental and quasi-governmental organizations that are involved in this area. The
bulk of the participants  came from the U.S. Army  Corps of Engineers and state
coastal management programs, with smaller contingents from the Environmental
Protection  Agency,  the  Maritime Administration  of  the  Department  of
Transportation, NOAAs Office of Ocean and Coastal Resource Management, the Fish
and Wildlife Service, and port authorities from around the country.

On the first day, speakers laid out the issues and provided a base of factual infor-
mation on which the attendees might find common ground and better understand
their differences. (Part II of this report is a digest of the speakers' remarks.) On the
second day, workshop participants broke into five regional work groups to discuss
issues of importance to their particular regions and to develop recommendations
to improve the coordination of dredging projects. In the afternoon, the  partici-
pants took a tour of a dredging operation at the Port of New Orleans. On the third

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and final day, the five work groups presented their conclusions and suggestions. A
general plenary discussion closed the workshop on a very positive note.

The workshop discussions illustrated many of the current pressures on dredging
and the maritime environment. There will be a continuing need for dredging, and
there is a growing demand for a number of deeper shipping channels. At the same
time, the federal and state funds that are available for dredging and for environ-
mental enhancement  and restoration  are highly constrained and are likely to
remain so. Finally, there is a growing public awareness of the value and importance
of environmental protection in the coastal  zone, which leads to the demand  for
more beneficial uses for dredged material. These narrowing constraints affect all of
the agencies dealing with these issues.

Several strong themes sounded throughout the workshop. One theme was the peren-
nial challenge of fairly spreading the costs of the navigation and environmental com-
ponents of dredging operations among the federal  government, state and local
governments, and local sponsors. A second theme reflected the difficulties associated
with a transition from a narrow focus on navigation to a broader focus on maximizing
both the  commercial and environmental benefits of the coastal zone. A third major
theme concerned the need to stimulate cultural change within the affected federal and
state agencies to respond effectively to these new demands.

Notwidistanding the real challenges ahead, the workshop participants collectively
expressed the  sentiment that progress is being made, and that more progress is
possible. Presentations on the first day explained some notable success stories,
such as wetlands restoration projects in San Francisco Bay, marshland creation in
Galvestori Bay, sediment reduction in Toledo Harbor, and public and private part-
nerships in Louisiana. Throughout the workshop, diere were many signs of soft-
ening attitudes and an expressed willingness to try to avoid conflicts by involving
all interest groups in early collaborative planning.  Overall,  there was a striking
convergence of sentiments between the breakout groups, and  only a few of their
recommendations were strictly local or regional in character. For that reason, this
report has organized  the comments and recommendations  according to certain
common themes and categories, rather than on a region-by-region basis. The over-
head slides used during the  presentations by the regional breakout groups  are
posted on  the website of  die National Academy of  Public Administration
(www.napawash.org).

This part of the report summarizes the leading suggestions  and  recommenda-
tions  voiced by the workshop participants and the breakout groups.  As one
would expect, most of the suggestions were not unanimously supported, and
some of the suggestions are at odds with other suggestions.  These recommenda-
tions reflect the views of the workshop attendees and not the National Academy
of Public Administration.

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A.  USE THE REGULATORY PROCESS TO FACILITATE
     BENEFICIAL USES

Workshop participants discussed the meaning and validity of the Corps' "federal stan-
dard" throughout the plenary sessions and breakout groups. Some speakers, particu-
larly from the Corps, felt a continuing need to use the federal standard to protect the
Corps' navigation budget. Other speakers stated that they thought the Corps too often
uses the federal standard to restrict projects that were environmentally appropriate.
Despite a lack of consensus about whether the federal standard should be altered,
many participants made suggestions that were intended to improve  the outcomes
within the existing regulatory framework.

   • There was widespread sentiment that the federal standard should not be
     regarded as an inflexible prescription for dredged material management, but
     rather as part of a process for arriving at a preferred course of action. While
     based on legal requirements and technical and economic factors, the federal
     standard for each project is developed through an interactive process, and the
     final result  is  shaped by  the  considerations  that  emerge  during  the
     collaboration between state, federal, and nongovernmental groups.

   • There is a productive middle ground between state and federal agencies' interests
     on many projects. To reach this middle ground, the Corps should recognize that
     the term "environmentally acceptable" requires consistency with the mandatory
     elements of a state's coastal management program unless prohibited by federal
     law. Similarly, states should recognize that some elements of state programs may
     be ambiguous, vague, or broad in application.

   • State managers and other stakeholders sometimes do not understand how the
     Corps has concluded that  a proposed action is "environmentally acceptable."
     Workshop participants suggested that the Corps should open the "black box"
     of its decisionmaking process by documenting its decision that a course of
     action is environmentally  acceptable. If it can make its own thinking more
     transparent, the Corps can contribute to better understanding and a  more
     robust public dialogue. Numerous  participants urged the  Corps to define
     what it means for a base plan to be "environmentally acceptable."

   • The Corps' district offices are perceived to be inconsistent and often inflexible
     in their interpretation and application of the "federal standard." The Corps
     headquarters should issue guidance to clarify the flexibility inherent in the
     federal standard, thereby improving the application and consistency of the
     district offices' use of the federal standard.

   • NOAA should issue guidance about what is required for a dredging project to
     be consistent with an  enforceable state policy under the CZMA.

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  • Achieving federal consistency with state coastal management policies depends on
    those policies being clear. NOAA and/or the individual states should identify the
    enforceable state policies applicable to dredging operations and the disposal and
    use of dredged materials so that the Corps and project sponsors will have a better
    understanding of applicable state requirements.

  • The Corps should broaden its valuation analyses to  incorporate the various
    environmental benefits of dredged materials. It was also suggested that the Corps'
    calculations 'should offset the cost of beneficial use projects by the value  of not
    filling in existing confined disposal facilities. Although placing dredged material
    in an existing confined disposal facility may be very inexpensive for the project at
    hand, the premature closure of confined disposal facilities will ultimately require
    the use of more expensive options for future projects.

  • The Essential Fish Habitat initiative under the Magnuson-Stevens  Act may
    have a significant impact on dredging and dredged-material management.
    Participants  called  on NOAA to  provide  guidance  on  this emerging
    conservation and restoration issue.

  • The Great Lakes breakout group observed that the process for designating the
    federal standard has no process for ensuring consistency with  the coastal
    management policies of the Great Lakes Commission, which is a binational body
    rather than a state coastal management plan.

  • The West Coast and Pacific Islands breakout group noted that EPAs Section 102
    ocean discharge criteria were too restrictive in island  environments where the
    upland  disposal  areas are very limited and where land  disposal can be
    environmentally harmful.

B.  IMPROVE INTERGOVERNMENTAL COORDINATION AND
    PROJECT PLANNING

Some dredging problems that are expressed as "consistency" conflicts are really the
result of planning and budgeting  failures.  There  have been projects where the
existing funding authority would have permitted the beneficial use of the dredged
material, but there was insufficient planning and coordination to accomplish it.
Workshop participants noted a variety of problem areas and made a number of
suggestions about how to improve intergovernmental cooperation.

   • The Corps planning process  and the state  consistency review process are
    mismatched in various ways that invite conflicts:

    - In many cases, state environmental programs are built around a  permit
       approval process. Since federal dredging activities do not require a permit,
       it is often hard for the state agencies to  focus constructively on the Corps'
       dredging plans.

    — Another process mismatch flows from a state's reticence to commit itself to
       a dredging project without full details and information about the project.

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       States are more likely to influence a federal navigation project if the state is
       vocal and involved in the early stages of the project.

     - The  Corps' regulations offer too little time for states to comment on a
       consistency determination. The 45-day review  period  is  especially
       burdensome in  states  that have a  decentralized coastal management
       program based on local participation in the decisionmaking process.

     - The Corps plans its dredging operations several years in advance, but state
       agencies are often only dimly aware of  these future plans. The  Corps
       should give relevant state agencies as much notice about these early plans
       as possible, in  order to stimulate early state feedback on dredged material
       management issues. The Corps should also provide fact sheets and other
       general information on its budget and planning processes to state managers
       and other stakeholders.

   • State coastal management programs need to identify the future needs and
     opportunities for dredging and beneficial uses. The Corps  can more readily
     respond to a long-term plan than to requests that are expressed at the end of
     the planning process for a particular dredging project.

   • State coastal management programs are not  always in full  policy alignment
     with other state agencies.  This  problem sometimes emerges late  in the
     dredging planning process, and might be avoided by more communication
     among the state agencies.

   • There  are no shortcuts  to  intergovernmental  cooperation and  public
     participation.  Effective participation and  full communication  require a
     sustained outreach program by all affected agencies.

   • The dredging process works better when state and federal actors sit down
     regularly to discuss current and future  activities. A structured relationship
     and regular meetings can provide a foundation for the development  of
     informal  working  relationships  among decisionmakers.   Local planning
     groups should be created to develop harbor or estuarywide  dredged material
     management plans.

   • The National Dredging Team should provide further guidance on the role and
     operation of the regional dredging teams. This guidance should address the
     roles of ports and environmental groups in the teams,  and what role regional
     dredging teams should play in the development and approval of regional and
     local dredging plans.             .

C.  INCREASE FUNDING  FOR BENEFICIAL USES

In many, but not all, cases, it costs more to use dredged material in a beneficial
manner than it does to dispose of it in other ways. Federal and state funds for ben-
eficial uses are limited. Workshop participants discussed a variety of ways in which
more money could be  made available for beneficial uses.

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  • Increases in congressional appropriations for dredging and beneficial use will
    require private-sector support. Workshop attendees urged a larger and more
    vocal role for the Coastal States Organization, the American Association of
    Port Authorities,  beach communities,  commercial  and  sport fishing
    organizations, and environmental groups. A coalition approach is required to
    obtain sound funding for both the navigation and environmental aspects of
    dredging operations.

  • The Corps, states, ports, and local governments should make better use of
    existing legislative authorities  to fund beneficial-use projects. In  particular,
    Section 204 of WRDA of 1986 can help pay for beneficial-use projects,  but
    has been used less often than it might be.

  • It is important to seek new sponsors for cost-shared projects. This includes
    reaching out to existing public and quasipublic organizations,  and also
    reaching out to the private sector.

  • In some cases,  navigation  improvement sponsors (e.g.,  ports,  shippers)
    oppose beneficial-use projects out of fear that they will bear the costs of the
    environmental improvements. Proponents of beneficial use should work with
    navigation sponsors and identify ways to share the costs of environmental
    improvements across a broader spectrum of users.

  • Even apart from the  funding for beneficial uses, many participants felt  that
    the base funding  for federal and state programs involved  with dredged
    material management is too low. This resource limitation undercuts those
    agencies' abilities to engage in early planning and cooperation.

  • Federal and state participants felt that agencies need more flexibility to use
    the resources that they have. Narrowly targeted appropriations tie an agency's
    hands and should be avoided where possible.

D.  INCREASE SCIENTIFIC  KNOWLEDGE AND PUBLIC
    AWARENESS ABOUT BENEFICIAL USES

There is a continuing need for more scientific knowledge about the environmen-
tal consequences of dredging, dredged material disposal, and habitat creation and
restoration efforts. Improved understanding of these issues would help regulatory
agencies make better decisions and would inform managers and the public about
beneficial uses and how to pay for them.

  • There is a need to monitor some beneficial-use sites after their completion,
    particularly in the case of demonstration projects. However, the funding for
    the dredging project usually does not provide for subsequent monitoring
    activities. Federal and state managers should investigate how funding for this
    aspect of the project can be assured.

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Some participants urged the Corps to allow district engineers more latitude
in funding planning studies related to dredged material and beneficial uses.
State agencies and the public often seek to know more about proposed plans,
but the district engineer is limited in the anlount of investigation that he or
she can pursue.

Proponents of the beneficial use of dredged material need to address public
fears and indifference about dredged-material management. In some parts of
the country, the public is largely unaware of many of the environmental
benefits of beneficial-use projects.

Efforts should be made to ensure that advances in the technology of dredging
and dredged material placement are publicized.

Dredging  planners  should try to market dredged material as a valuable
resource. In some cases,  the material has ready applications, but potential
users are not aware of its availability.

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                                                PART
                        Workshop Proceedings
A.  OPENING REMARKS: WHAT'S AT STAKE

William Travis, Executive Director of the San Francisco Bay Conservation and
Development Commission, outlined several key themes that were discussed through-
out the workshop. Travis explained that dredging is an excellent issue to illustrate the
value of the Coastal Zone Management Act, which provides the essential framework
for federal-state cooperation.

First, dredging  presents a classic  tension between economic development and
environmental protection. The CZMA is a tool to reconcile those interests because
it allows local coastal areas to balance environmental values and economic inter-
ests. Second, Travis noted that the federal government is the main dredging actor,
whereas die major economic benefits and environmental impacts of dredging are
local and regional. The CZMA provides a framework for cooperation between the
state and federal governments. In particular, the CZMA provides a measure of
leverage for states in their relationship with the federal government. Third, dredg-
ing management often involves more than one state, and the CZMA has a mecha-
nism for achieving interstate cooperation. Finally, the  CZMA  permits diverse
approaches to coastal management, which is necessary and appropriate, because
the issues and challenges involved in dredging vary greatly by state and region.

Travis concluded by noting a theme common to all regions: it costs more to "do dredg-
ing right" than to use the old methods of "dredge and dump." Despite the increased
cost, Travis said that beneficial use of dredged material has long-term economic and
environmental benefits. Our challenge is to make a persuasive case that the nation
should make the current investment needed to realize these long-term benefits.

Tom Chase, Director of Environmental Affairs of the American Association of Port
Authorities, predicted that dredging issues will increase in importance in the years
to  come. First, the volume of commercial shipping is expected to double by the
year 2010, according to projections by the U.S. Customs Service. Ships will get
                                                                           A
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bigger, and deeper channels will be needed for those ships to reach harbors. Ports
will continue to undergo redevelopment. In some cases, ports will expand, but in
other  cases,  ports  will  be  redeveloped to handle  different types  of cargo.
Improvement and maintenance dredging will continue to occur. Chase also pre-
dicted that there would be no national port planning (i.e., there would be no explicit
federal decision to invest in a few ports but not others), and that changes in the roles
and vitality of the ports will be largely driven by market forces.

Chase then provided a list of his "top 10" considerations to the workshop participants:
   10.  Beneficial use features should be designed into projects, not added later.
   9.   Beneficial use is a feature of multi-objective projects and should be cost-shared
       accordingly.
   8.   Dredging managers should make greater use of existing funding authorities.
   7.   Workshop participants should avoid "what if arguments, such as "what if the harbor
       maintenance tax were replaced by something else?"
   6.   It is important to find additional local cost sharing partners for beneficial use, as ports
       may not be appropriate partners for environmental aspects of project.
   5.   Congress is not funding the base navigation program at an adequate level, much less
       meeting new challenges. Dredging proponents need to identify strategies to raise
       appropriations for the federal share.
   4.   As public agencies, ports are uniquely positioned to build partnerships for acceptable
       navigation projects with beneficial use features. Coastal management isn't just a matter
       of regulation; it should also involve alliance building.
   3.   The Corps should educate its districts about the use of budget authorities to fund
       beneficial uses. The Corps should begin to  advertise its cost-share authorities to
       potential sponsors.
   2.  State coastal programs should use their special area  management tools to identify
       and streamline the permitting process for beneficial use sites. Project users—ports,
       user groups, and state and local governments—should take a more active role in
       planning projects.
    1.  Have fun! That is the best way to build partnerships.

 John  Burns, Chief, Planning Management Branches, Corps of  Engineers, gave  an
 overview of the Corps of Engineers' Civil Works Program as it pertains to navigation
 and dredging. The civil works program receives annual funding  of about $5 billion,
 including funds received for work for other federal agencies. Almost all of the con-
 gressional appropriations are funded on a project-by-project basis.

 The  Corps' navigation program maintains 12,000 miles of inland and intracoastal
 waterways. The Corps dredges 300 major seaports, and over 600 smaller harbors. Each
 year, the Corps dredges 250 million to 300 million cubic yards of dredged material at
 a cost of about  $500 million. About 30 percent of this material is now used beneficially.

 Burns emphasized that the Corps  is playing a growing environmental restoration role.
 The Corps was formerly an engineering organization, but has evolved into  a full-ser-
 vice engineering and environmental services organization.  In fact, the Corps now
 manages about 18,000-square miles of project lands for environmental purposes.

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 B.  STATE COASTAL MANAGEMENT PROGRAMS AND THE
     FEDERAL DREDGED-MATERIAL  PLANNING PROCESS
                                           -               ..   * •

 Tony MacDonald, Executive Director of the Coastal States Organization, introduced
 the first panel of the day, consisting of Joe Wilson, David Kaiser, and Craig Vogt. In his
 comments, MacDonald noted that while ports are very important economic clients of
 dredging programs, state coastal management programs needed to take a broader view
 that encompasses the interests of smaller coastal  communities, harbors, and fisheries.
 MacDonald also pointed out that this workshop was part of an ongoing process of dis-
 cussion and dialogue. Nationally, the Coastal States Organization is engaged in a  dia-
 logue with  the American Association of Port  Authorities  to develop a vision of
 sustainable maritime communities. Local governments are trying to develop synergies
 between navigation, monitoring, and coastal management to improve transportation
 and environmental values.

Joe Wilson, an aquatic biologist in the Dredging and Navigation Branch of the Corps
 of Engineers, reviewed the history of the Corps of Engineers' dredging regulations as
 they relate to the relationship with the states. In 1972, Congress enacted the three
 statutes that still govern the dredging arena:  the  Marine Protection, Restoration,  and
 Sanctuaries Act, the Federal Water Pollution Control Act (later known as the Clean
 Water Act, or CWA), and the Coastal Zone Management Act. With the amendment of
 the CWA in  1977, the Corps was required to seek water-quality certifications from
 states. That change led to a period of increasing  conflict between the Corps and the
 states. In 1988, the Corps issued a revised regulation that clarified the process by which
 the Corps would seek arid obtain state approval under the CWA and CZMA. That reg-
 ulation, which defines the "federal standard," was intended to accommodate state
 needs while protecting the federal dredging budget. Wilson stated that since the pas-
 sage of that regulation, the Corps and states have attempted to  work out their differ-
 ences on a project-by-project, state-by-state basis.

Wilson concluded with the observation that the Corps' budget has been flat or stable in
 real dollars for the last 20 years. Congress has consistently refused to provide additional
 funding for navigation projects, and Wilson was not optimistic that this would change
 for the better. Nevertheless, Wilson stated that workshop participants could use addi-
 tional legislative authorities and a better understanding of the budget process to achieve
 additional beneficial-use goals.

David Kaiser, Federal Consistency Coordinator for the Office of Ocean and Coastal
Resource Management, NOAA,  explained that the workshop  was conceived as an
opportunity to focus on the tensions between the CZMA federal consistency require-
ments and the Corps' dredging operations. The CZMA requires that any federal agency
activity that affects any coastal use or resource in the coastal zone must be carried out
in a manner consistent to the maximum extent practicable with enforceable state poli-
cies. As a result, requirements of an NOAA-approved coastal management program are
just as binding as other federal regulation that affects dredging practices. For this rea-
son, enforceable state coastal management policies should be factored into the calcula-
tion for establishing the federal standard for each dredging project.


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Kaiser emphasized that the Corps' dredging planners need to include the costs of com-
plying with state requirements in federally funded dredging projects. The workshop is
an opportunity to learn how to work together better and to coordinate earlier; how pro-
ject sponsors can better use other legal authorities to achieve their objectives; and how
and when states can build their requirements into a projects design and budget.

Craig Vogt, Deputy Director of EPAs Office of Oceans and Coastal Protection, provided
an historical overview of the development and work of the National Dredging Team
(NDT). According to Vogt, then-Secretary of Transportation Frederico Pena convened an
interagency working group in October 1993 to study the difficulties in the existing
dredging permitting process. This group issued a report in December 1994, that identi-
fied four major categories of problems:
   1. There was too little communication between federal and state agencies.

   2. There was not enough project planning.
   3. Some problems were related to numerous scientific uncertainties.
   4. The cost-sharing formulas were inconsistent or created difficulties.

The administration created the National and Regional Dredging  Teams in response to
the first problem. The role of the NDT is to allow top-level interaction between federal
agencies, to prepare national guidance, and to promote national consistency of policies.
the NDT is composed of the Corps of Engineers, the Environmental Protection Agency,
the Office of Ocean  and Coastal Resource Management and  the National Marine
Fisheries Service of NOAA, the U.S. Fish and Wildlife Service of the Department of
Interior, and  the Maritime Administration  of the  Department  of  Transportation.
Regional Dredging Teams (RDTs) were conceived as a forum for resolving regional
issues. Neither the NDT nor the RDTs were conceived as having a direct role in any
 dredged-material management planning or review. Those issues were to be handled by
 Local Planning Groups (LPGs).

 In June 1998, the NDT issued a guidance document entitled Local Planning Groups and
 Development of Dredged Material Management Plans. Vogt emphasized that this docu-
 ment was not prescriptive guidance, and that the structure, participation, and extent of
 work can vary to suit the local needs. Membership in the LPG can be very broad and
 can include such interests as federal agencies, state agencies, port representatives, recre-
 ational boaters' groups, environmental groups,  and  sport fishing organizations. The
 guidance describes an approach that is built around the Corps' planning process. Co-
 chaired by the Corps with states or ports, the LPG are  to develop comprehensive
 dredged material management plans.

 Discussion: The ensuing discussion emphasized the need for flexibility and creativity
 in the financing process. One speaker cautioned that one shouldn't expect either the
 ports or the Corps to pay for all of the beneficial-use projects. Several speakers urged
 participants to build partnerships to get increased funding and suggested exploring
 linkages with other funding sources, including FTUD grants for waterfront redevelop-
 ment, brownfield grants to clean up port areas, and alliances between highway, rail, and
 dredging projects to capture funding under the Transportation  for Equity Act for the
 21st Century ("TEA 21").

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Another thread of discussion concerned whether the country needed a national process
for overall port planning. In particular, were there some dredging projects that simply
shouldn't be done, because the cost was too highj or the benefits too low? On this
point,  the workshop yielded no general consensus. Some participants thought that
national port planning was appropriate and necessary to make  the most of limited
resources, while others thought that it was politically and practically unrealistic. A third
viewpoint held that even in the absence of an explicit national policy, there would be
a national policy by default: Congress would eventually fund some major projects
while others would not come to pass. Congressional funding will flow to those regions
where  broad multi-purpose coalitions are forged that simultaneously advance
both the environmental and economic interests in the region.

Workshop participants also discussed whether the  Corps  of Engineers must
apply  for and receive permits from state coastal management programs before
dredging a channel.  David Kaiser explained that the CZMA requires the Corps
to  conform to enforceable  state coastal management policies, but does not
require the Corps to comply with state permitting procedures. However, other
federal laws, such as the Clean Water Act, may contain a waiver of federal sov-
ereign immunity and require the federal agency to follow state permit proce-
dures. The CZMA does not have such an effect by itself. Joe Wilson stated that,
as a matter  of policy, the Corps does not apply for states permits absent clear
congressional instruction to do so.


C.  CASE  STUDIES IN DREDGED-MATERIAL MANAGEMENT
     PLANNING

John Carey, Chief Administrative Officer of the Alabama State Docks, introduced
the second panel, which focused on two case studies in dredged material dis-
posal.  Carey noted that it was important to "think outside the box" in consider-
ing new ways to use dredged material. The Alabama State Docks had adopted a
variety of new approaches, including selling dredged material  to contractors as a
raw material for asphalt, for use in base stabilization for road building, and to cap
landfills. Public entities can also withdraw materials from disposal areas for beach
nourishment projects and for the stabilization of public properties.  Carey also
described a disposal island project undertaken by the Alabama State Docks that
has become a rookerie for endangered brown pelicans.

Wayne Warren, Chief of Land Management and Real Estate for the  Ohio
Department of Natural Resources, described recent efforts by Ohio  to  address
dredging issues in the Toledo Harbor. Toledo is a major port on the Great Lakes
that handled 14-million tons of diverse cargo in 1998. Eighty percent of the water-
shed is agricultural, which contributes to the high sediment loads in the river. By
one estimate, the Maumee River carries about 1.3 million tons  of suspended sedi-
ment into the harbor and channel each year.

In years past, the channel was dredged with sidecast dredging, but this resulted in
shallow areas adjacent to the channel. Later, hopper dredges  were used  to haul

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      sediment to the open lake, but this form of disposal became unpopular because
      open-lake disposal led to the re-suspension of contaminants.  Lake Erie is used for
      drinking water by many shore-side communities. With the passage of the Clean
      Water Act, disposal of dredged material was limited to confined disposal facilities.

      In 1992, the Water Resources Development Act provided for the establishment of
      a long-term dredged material management strategy for Toledo Harbor. This was a
      joint federal, state, and local effort. In early years, the planning process ran into
      conflict with the Corps' federal standard. After a lengthy and sometimes acrimo-
      nious process, the final report is nearing completion.

      The plan identifies three key areas where work needs to be done: (1) Soil conser-
      vation measures are needed to lower the rate of sedimentation in the channels. The
      Natural Resources Conservation Service is leading the effort to implement modi-
      fied and no-till farming practices throughout the watershed, and to expand buffer
      strips along waterways. A demonstration project has already resulted in a dis-
      cernible reduction in sediment transfers. Activities in this area will continue. (2)
      The capacity of the confined disposal facilities should be  conserved. The Toledo
      port authority has taken the lead in developing a recycling  approach that mines
      clean'material from confined disposal facilities and mixes it with sewage sludge to
      create topsoil. (3) It is important to plan for the  future capacity of confined dis-
      posal facilities. Planners are exploring several options, such as raising dikes  at
      existing disposal facilities to increase capacity, and constructing a new facility that
      would serve as a protective barrier for a sensitive wetland area.

      Jeff Willis, Marine Resources Specialist from the  Rhode Island Coastal Resources
      Management  Council,  described how the historical deadlock  over dredging  in
      Rhode  Island is being resolved. In the last 25 years, there have been no  major
      dredging  projects in state waters because there were no designated-material dis-
      posal sites. Willis stated that there are  19 major federal navigation  projects and
      numerous nonfederal projects in need of dredging. A 1979  report estimated that
      Rhode Island waters needed 2.6 million cubic yards of dredging, but only 123,000
      cubic yards (5 percent) have been dredged since then.

      In the early 1970s, the state closed existing disposal sites out of concern for their
      impact on fisheries. State efforts in 1979, 1987, and 1992 looked for solutions to
      the dredged material disposal, but did not bear fruit. Willis  offered several expla-
      nations for the states failure to identify feasible dredged-material disposal sites:
          1. There was no systematic state planning for dredged-material disposal.
          2. There was strong stakeholder opposition to in-water disposal.
          3. A long list of agencies were responsible for dredging,  with no state agency
           with a lead role.
          4.  Policy inconsistencies and conflicting regulations by state agencies eliminated
            much of Rhode Island Sound and Narragansett Bay as potential disposal sites.
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In recent years, the deadlock has eased greatly, and the state Coastal  Resources
Management Council (CRMC) is nearing the final designation of dredged material dis-
posal sites. Several factors were instrumental in,breaking the deadlock:
   1. User groups who would benefit from dredging, such as the pilots association and
     marine trades association, pushed hard in the political process.
   2. The  Corps refused to plan dredging  projects without a state commitment to
   •  resolve the disposal issues.

   3. The state legislature enacted the Marine Infrastructure Maintenance Act, which
     designated CRMC as the lead state agency to coordinate all state interests, develop
     a dredged material management plan, and identify in-water sites. The statute also
     directed that state water quality regulations should be no more strict than federal
     requirements.

   4. The CRMC established a planning process that included both stakeholder groups
     and  expert  groups. In late  1996, the planning process reached  a general
     agreement about potential sites and uses, and the  CRMC is close  to a  final
     designation of disposal sites. Willis said that the changed dynamics in the  state
     had also improved the state agencies' relationships with both the Corps and EPA.

D.  LOUISIANA'S USE OF THE COASTAL WETLANDS
     PLANNING, PROTECTION, AND RESTORATION ACT

Terry Howey, Administrator of the Louisiana Coastal Management Division, intro-
duced the luncheon speaker, Katherine G. Vaughn, the Assistant Secretary of the
Louisiana Department of Natural Resources. Vaughn focused her remarks on the
Coastal Wetlands Planning, Protection, and Restoration Act of 1990 (called the Breaux
Act in Louisiana, after Senator Breaux's sponsorship of the bill in the Senate).

Louisiana has 40  percent of the total salt marsh wetlands in the United States, and
almost 80 percent of the wetlands that are lost in United States are lost in Louisiana.
Vaughn called Louisiana's wetlands "a national economic treasure," because they sup-
port oil and gas extraction, waterborne commerce, and extensive  commercial and
recreational fishing industries. Beyond that, these wetlands provide vitally important
ecological functions  as habitat for fish, shellfish, and waterfowl. The wetlands also
underpin cultural values important to the whole nation. Louisiana's coastal plain is
home to  2 million people, supports a growing eco-tourism industry, and provides
important buffers from hurricane and storm impacts along the Gulf coast.

These wetlands are being lost at an alarming rate. Without intervention, it is fore-
casted that Louisiana will lose between 25 and 35 square miles of wetlands each
year, amounting to a projected loss of 527,000 acres by 2040. Numerous natural
and human influenced factors are involved, including subsidence, sea level  rise,
shoreline erosion, salt water intrusion, lack of fresh water and sediment input from
rivers, and altered hydrology.

Vaughn explained that Louisiana cannot afford to be uncreative or complacent in light
of this serious threat. The Breaux Act gives Louisiana an important tool to respond to
the wetlands loss.  Title III of the Act establishes a joint state-federal task force to plan,
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      design, construct, maintain, and monitor vegetated wetlands restoration projects for the
      long-term conservation of wetlands and dependent fish and wildlife populations in
      coastal Louisiana. Using this framework, Louisiana has entered into partnership with the
      Corps of Engineers, EPA, the National Marine Fisheries Service, the National Resource
      Conservation Service, and the Fish and Wildlife Service.

      Under the auspices of the Breaux Act, Louisiana state government, its federal partners,
      and local governments and stakeholder groups are engaged in a restoration planning
      process called Coast 2050. The project uses the coastal zone management structure to
      encourage local and private-sector involvement in an ecosystem planning initiative. In
      the fall of 1998, the first joint task force meeting resulted in an unanimous adoption of
      principles for coastal management.

      Vaughn also discussed a number of wetlands restoration projects that were completed
      or under way, and described how each of the projects involved creative partnerships.
      One project was built by an oil and gas company as a mitigation measure for other pro-
      jects in state waters.  Four-fifths of the projects involved lands that were not under gov-
      ernmental control. Since the Department of Natural Resources has no  expropriation
      authority, voluntary private-sector participation was critical. Vaughn also emphasized
      that the program relied on as many different partners and legal authorities as possible.
      The projects were performed in cooperation with a diverse mix of federal agencies,
      including the National Marine Fisheries Service, the Corps, EPA, and the Fish and
      Wildlife Service. In Vaughns view, every federal partner expands the states capa-
      bility to address its wetlands loss.

      Vaughn closed with several points of advice. First,  she urged all public organiza-
      tions to adapt to working with the private sector; failure to do so will ensure  the
      failure of one's programs. Second, she encouraged attendees to understand that
      wetlands restoration is actually in the interest of navigation, rather  than a collat-
      eral issue, since so  much of the coastal infrastructure depends upon it. Finally, she
      encouraged ever-wider cooperation by all parties, explaining that cooperation acts
      like a starburst that sets off a chain reaction in other locations.

      Discussion: A participant explained that the  Breaux Act also includes two provi-
      sions that provide funds for wetlands restoration  in states outside of Louisiana.
      Fifteen percent of  the CWPPRA funds are set aside for wetlands preservation in
      coastal states, and another 15 percent is available for wetlands restoration any-
      where in the United States. The U.S. Fish and Wildlife Service administers these
      programs.


       E.   UNDERSTANDING AND USING THE FEDERAL BUDGET
            PROCESS

       Mike Carter, Director of the Office of Environmental Activities of the Department
       of Transportations Maritime Administration, described the  Marine Transportation
       System (MTS)  initiative. In early 1998,  the  Secretary  of  the Department of
       Transportation  initiated a dialogue between  federal agencies and state and local
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interests on improving the federal coordination of the U.S. marine transportation
system. The goal of the initiative is to identify the key maritime transportation
issues in the next century. The Maritime Administration, Coast ;Guard, Corps of
Engineers, NOAA, EPA, and other federal agencies held a major conference in
November 1998. Private- and public-sector organizations were also represented at
the meeting, including shippers, ship builders, environmental interest groups, and
port authorities. The Maritime Administration is now convening a series of meet-
ings in port cities across the country to continue and broaden this dialogue.

The November MTS conference touched on dredging issues in several ways:
   1. Workshop participants felt that it was critical to deepen navigation channels to
     meet maritime industry needs.
   2. It is important to shift from project-to-project permitting longer-term planning for
     dredging and disposal.
   3. The process for developing the marine infrastructure needs to be reinvented
     based on principles of smart growth and watershed management.
   4. The  nation needs to integrate the  different pieces  that affect the marine
     transportation system and to link the marine transportation system to the rest of
     the country's transportation system.

To date, the MTS discussion has avoided specific funding issues such as replacement
of the Harbor Maintenance Tax. These issues will arise and be discussed in the future.
Carter pointed but that the MTS dialogue process may offer an opportunity to address
some of the funding issues associated with dredging and dredged material disposal.

Pete Luisa, Branch Chief in the Program Management Division of the Corps of
Engineers, described the Army Civil Works budget process. The budget and appropri-
ations process stretches over a period of approximately 20 months. It starts in February,
two years before the budget year (which Luisa abbreviated as "BY-2"), when the Office
of Management and Budget (OMB) provides the Corps with an overall budget ceiling
for the budget year. The Corps breaks that down by program, and the Corps' district
offices set priorities and amounts for each of the projects in their area. By September of
BY-2, the Corps submits its proposed budget to OMB, which then "passes back" the
budget proposal  with comments. In February BY-1, the administration proposes its
budget for the next fiscal year. Congress takes that proposal, holds hearings, and pro-
ceeds to mark up the bill. If all goes well, an appropriations bill is enacted by October
and the funds are then available for the budget year.

This budget schedule has special significance for dredging projects, because almost all
dredging projects are funded by name with specific appropriations for each project.
Luisa outlined four "zones of influence" during which state and local interests can affect
the Corps' budget:
   1. Since the budget plan starts in the field, states and potential sponsors should work
     closely with the district engineer to identify and characterize the dredging projects
     that are needed. The Corps field staff need to know the sponsors' views by
     February BY-2.
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  2. Sponsors also can visit Washington at the time of the headquarters' presenta-
     tion to the Assistant Secretary of the Army for Civil Works Qvly to August BY-
     2), in order to urge inclusion of specific projects or specific funding levels in
     the Corps' proposed budget.
  3. When the appropriations committees hold hearings on the administration's
     budget, committee members may be influenced by letters  from constituents
     and the entreaties of individual members of Congress.
  4. Luisa also explained that the appropriations committees themselves must live
     within the  limitations  imposed by their respective  budget committees.
     Consequently, project proponents may want to talk to the budget committee to
     encourage adequate budgetary authority for dredging and navigation projects.

Luisa warned that the Corps' operating and maintenance budget was under strong and
continuing pressure. In order to adequately maintain existing navigation projects, and
to maintain new  construction projects  that have been authorized by Congress, the
Corps needs more funding. The balanced budget amendment, however, continues to
reduce the appropriations available to the Corps. The consequence is an ever-increas-
ing gap between needed funds and those that may be appropriated.

Rich Worthington,  Senior Policy  Advisor, Policy Division,  Corps of Engineers,
described five  existing authorities under which the Corps can perform beneficial use
projects in connection with dredging activities:

(1) A beneficial use component can be included within the base plan of a navigation
project. In this situation, the beneficial use aspect is incorporated into the federal stan-
dard, in that it is the least-cost alternative consistent with applicable environmental
standards. Worthington noted that the Corps uses about 30 percent of dredged mate-
rial beneficially, and the majority of this is done under navigation base plans. Even
though the beneficial use is part of the federal standard, there can be a cost-sharing
component. For  maintenance dredging projects, the transportation and placement
costs are borne wholly by the federal government. But projects involving  the mainte-
nance  of disposal facilities are cost-shared,  with the nonfederal party paying between
10 and 60 percent of the cost. In addition, the construction projects involving trans-
portation and  pkcement of dredged material may involve nonfederal costs of between
10 and 60 percent, depending on the depth of the channel. These types of cost-shar-
ing do not depend on paying the incremental additional cost of beneficial use, but
instead hinge  on the fact that the underlying project is itself a cost-shared  project.

(2) Beneficial  uses can also be included in specifically authorized projects. Congress
sometimes authorizes  and funds multi-use projects that involve beneficial use of
dredged material. This involves doing a cost-shared feasibility study, working to get the
authority and  the appropriations, and forging a partnership for the nonfederal share of
the project costs. In this type of project,  the nonfederal share needs to cover 25 percent
of the  increase in incremental cost and  100 percent of the costs of nonfederal mainte-
nance. Worthington stated that this was a "winning" approach because of the appeal of
combining navigation  and  environmental goals.  As examples of  this approach,
Worthington cited the Sonoma Baylands and Houston marsh creation projects, both of
which were discussed kter in this workshop.

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(3) Section 204 of the Water Resources and Development Act (WRDA) of 1992 provides
programmatic authority for the protection, restoration, or creation of aquatic and related
habitats. Since this is  a programmatic authority, the Corps does not need to go to
Congress for individual project appropriations. It is applicable both to maintenance and
construction. Under Section 204, the nonfederal sponsors must pay 25 percent of incre-
mental cost and 100 percent of nonfederal maintenance cost. The Corps is authorized
to expend up to $15 million per year under this authority. Nevertheless, this authority
has been underused in the past, and the Corps has received only $2 million to $3 mil-
lion for this program in recent years. In fact, Congress appropriated only $350,000 in
FY 99 for this authority because so little was expended last year. Worthington encour-
aged workshop participants to consider how they could better use this authority

(4) Section 207 of WRDA 96 is similar to Section 204, but is not programmatic.
Like Section 204, it can be used both for construction and maintenance projects,
and it expressly allows projects that include a disposal method other than least-
cost. This authority can be used to add a big environmental project to navigation
projects, but requires specific appropriations by Congress.

(5) Section 145 of WRDA 76 gives the Corps the authority to place suitable material
on beaches, and can be used in conjunction with construction and maintenance dredg-
ing projects. The nonfederal sponsor must bear 50 percent of the incremental cost, and
100 percent of any nonfederal maintenance costs that are incurred. Worthington stated
that this authority was not used as much as one might expect. Like Section 207, this
provision requires specific project appropriations.

(6) Section 1135 of WRDA 86 provides authority for the Corps to modify projects to
improve environmental quality or address environmental degradation caused in whole
or part by the project.  This authority and funding could be used for environmentally
beneficial use of dredged material, but the Corps has chosen to use the more specific
authorities of Section 204 as the primary vehicle to accomplish beneficial use projects.

Worthington closed by noting that the administration supports environmental goals.
Congress has been a little cooler to environmental projects, but likes the combination
of navigation and environmental objectives in dredging projects. Worthington sees an
opportunity to develop more beneficial use projects in the future.

Tom Nuckols, Director of the Coastal Division of the Texas General Land Office, noted
that the experience with the Houston ship channel project has significantly "raised the
bar" for new construction projects in Texas. There is now a strong expectation that a
new project will include a significant environmental restoration component, with the
consequence that a least-cost project simply would not get off the ground today.

In the area of maintenance projects, Nuckols agreed that there is  a good statutory
framework for the Corps and states to meet dredging needs. But at a practical level,
there  are more conflicts. First, funding is always a problem.  More  money would
improve the situation,  but even if there were more funding, there would still be some
problems because navigational interests and environmental goals are not coordinated.


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      Second, Nuckols said that there are a variety of procedural hurdles to the Corps and
      states working together. In his view, the federal standard regulation creates an obstacle
      to the use of Section 204. The federal standard was designed to protect the Corps' oper-
      ations and maintenance budget, and implicitly tells a district engineer to say no to any
      incremental cost. In essence, the federal standard says, "this money is for navigational
      purposes; if you want to do something that costs more than the base plan, don't expect
      it to come out of O&M."

      Nuckols said that the Corps could give states wider latitude and still protect the
      O&M budget. Nuckols  proposed that the Corps amend  the federal standard to
      give  district engineers more incentive to pursue projects  under Section 204. He
      urged the Corps to open up the dialogue during the project planning process to
      reflect the additional legal authorities for sharing incremental cost. The state con-
      sistency process can be  used as the way to make sure  that alternative plans and
      alternative funding schemes are fully considered.

      Discussion: Several participants noted that, aside from beach replenishment, the idea
      of beneficial uses of dredged material was not popular in the North Atlantic coastal
      states. This was possibly due to the absence of good projects that would have demon-
      strated the benefits from  beneficial use. Other speakers noted that it was very impor-
      tant for user groups, such as Ducks Unlimited and the Sierra Club, to be informed and
      involved in proposing these types of projects. It was also stated that it would be good
      if nonprofit organizations could become sponsors of the nonfederal share.

      The  workshop participants also discussed why the Section 204  authority has been
      underused. Some said that the trouble was in getting nonfederal sponsors to come for-
      ward. Others said that there were willing sponsors, but that the bureaucratic barriers
      were too high.

      F.   CASE STUDIES OF BENEFICIAL-USE  PROJECTS

      Jim McGrath, Environmental Manager of the Port of Oakland, introduced the last
      panel of die day, which described several beneficial-use projects. On the basis of
      his experience with the 1996 Oakland Harbor dredging project, McGrath stated
      that it is not easy to build beneficial use into projects, but that there are tools avail-
      able that can be used for that purpose.

      Steve Goldbeck, Program Director for Dredging and Legislative Affairs of the San
      Francisco Bay Conservation and Development Commission (BCDC), described a
      number of beneficial-use projects. The San Francisco Bay area dredges  about 6
      million cubic yards annually. Historically, dredged materials were disposed at an
      in-bay disposal site near Alcatraz Island. This site was supposed to be a dispersive
      site, but was not, with the consequence that a large mound of material was formed.
       Fishermen and the environmental community objected to further disposal at this
       site. In response, dredging activities stopped for a while.
20

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In 1990, a number of interested parties joined forces to draft a long-term management
strategy (LTMS) for the Bay. The partnership included the BCDC, the state water qual-
ity agency, the state water resource control board, the EPA, and the Corps of Engineers.
The goals of the process were to
   1. maintain the necessary navigation channels,
  2. dredge those channels in an environmentally and economically sound manner,
  3. maximize the reuse of dredged material, and
  4. establish a cooperative-permitting framework.

The final environmental impact statement for the long-term management strategy is
now nearing completion. The plan will involve a major shift in dredged material dis-
posal. Less material will be deposited in the Bay, and more will be disposed of on
upland sites and in the ocean. The long-term management strategy envisions that this
transition will occur over a period of about 10 years. It will be important to get the
alternative dredged material disposal sites online to achieve the long-range goal. This
program will cost more than the past practice of in-bay disposal. The ocean disposal
site has abundant capacity, but is approximately 50 miles offshore and is expensive to
use. The potential upland disposal sites will also be more costly than in-bay disposal.

A major focus of the LTMS is using dredged material to  improve habitat. Over 90
percent of the tidal wetlands in San Francisco Bay have been diked or partially filled
and used for agriculture. The consequence has been pressure on endangered species
and stresses on estuaries. The LTMS program will use dredged material in some sig-
nificant restoration projects. Some material will also be used to rebuild levees in the
delta. Goldbeck described four restoration projects that are under way or planned:

(1)  Sonoma Baylands tidal wetlands project. The California Coastal Conservancy
purchased an 830-acre site of former tidal and  seasonal wetlands  for  habitat
restoration. The project uses a "design  with nature" approach, in which subsided
diked lands were built up with dredged materials. The dikes were then breached,
resulting in new wetlands. The harbor-deepening project  at the Port  of Oakland
was the source of most of the dredged material. The project is still evolving.

(2) The Hamilton wetlands were part of a former Air Force base whose runway was
to be restored to habitat. The  Coastal  Conservancy is developing  a wetlands
restoration project that involves building levies, building internal peninsulas, plac-
ing a gradient of fill material on the site,  and breaching the levees.  The result will
be tidal and seasonal wetlands that provide a series of habitats. This project design
process included a large amount of public participation.

(3) A private sponsor proposed the Montezuma wetlands project. This project will
alter diked bay lands to restore its tidal action. The plan anticipates that 17 mil-
lion cubic yards of material will be placed on the site. The sponsors plan to charge
a tip to recoup the costs of construction.  The Corps of Engineers is also exploring
the feasibility of a Section 204 project to  deliver dredged material to the site.

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      (4) The Oakland Port Authority is pursuing a plan to restore shallow-water habitat in
      a portion of the harbor that was formerly used by the U.S. Navy. The port will take
      dredged material from a new terminal construction project and use it to fill an old
      deep-water Navy site to form a new shallow water site. The site will be stocked with
      eel grass and salt grass for habitat restoration, and will also be used for beach and recre-
      ation purposes. With the cost savings reaped by this project, the port is subsidizing the
      delivery of dredged material to the Hamilton wetlands project.

      Greg Ducote, Louisiana Department of Natural Resources, described his states empha-
      sis on beneficial use of dredged material. In his view, beneficial use is more than just
      what to do with the material when the Corps is cleaning out these channels. Instead,
      it is the single best way to address the serious land loss that the state is experiencing.
      Ducote stated that the Corps has constructed over 7,000 acres of vegetative wetlands
      in Louisiana. While that is a real achievement, more needs to be done.

      As a matter of policy, Ducote urged that the federal standard be amended to
      include the broader environmental benefits that may flow from beneficial uses of
      dredged material. Rebuilding Louisiana's wetlands is valuable because those wet-
      lands protect all of the infrastructure south of Interstate 10. With respect to  fund-
      ing,  Ducote  said that it's a  waste of resources  not to rebuild marshes  while
      rebuilding channels. States need to be partners with the Corps to get more money
      for beneficial-use projects.

      Ducote said that  communication between agencies is  improving. The state
      entered into a  memorandum  of understanding with the Corps on a process for
      handling  CZMA consistency  determinations.  This has had a  good effect, as it
      lends  predictability to the process. In  addition,  Louisiana and the Corps have
      begun a  series of  regular meetings to discuss how to develop projects  using
      Sections 204 and 1135. Proactive efforts at communication are crucial to making
      progress.  Ducote noted that the state wanted to have more communication with
      the dredging and shipping industries.

      One of the keys to increased use of dredged material is the development of dredg-
      ing technology. In Louisiana, the Corps dredges between 60 million and 90 mil-
      lion cubic yards each year.  Not  all  of  those dredging sites are immediately
      adjacent  to places where  sediment is needed. Ducote called for demonstration
      programs for improved  technologies to  move large amounts of sediment for
      longer distances than is currently possible.

      The  Louisiana legislature directed  the  coastal  management division  of the
      Department of Natural Resources to develop a long-term management strategy for
       dredged materials. Ducote said that the statute .is fairly strict, and requires benefi-
       cial use of the material from every project where  more than 500,000 cubic yards
     '  of material is dredged. The agency is now attempting to obtain approval  for its
       long-term management strategy.
22

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Phil Glass, a wildlife biologist at the U.S. Fish & Wildlife Service, described the
extensive wetlands  creation project under  way in Galveston Bay. The original
dredging plan for the Houston Ship Channel called for disposal in the bay. This
plan met with strong opposition by environmental groups, who complained about
contaminated sediments and possible changes in the salinity of the bay. The dis-
pute was eventually referred to the Council on Environmental Quality. The dispute
was eventually resolved with a  commitment that the channel deepening project
would include beneficial-use components.

With a new vision of the project, an interagency coordination team began to plan
a more complex project with more environmental aspects. The project was framed
within a 50-year time horizon, and  explored all aspects  of dredged-material dis-
posal, including engineering considerations, hydrodynamics of the bay, the types
and distribution of materials, and conflicts with pipeline structures. A beneficial-
uses group (BUG) was  formed in 1990, and went out to all the users in the area.
The BUG found wide support for the construction of marshes and bird islands and
various recreational features, which were then integrated with the long-term plan.

The ultimate plan is to build 4,200 acres of marshlands in the bay. The project will
start with some smaller-scale projects first. In 1994, the port of Houston  built a
6,000  foot levee (for  which it will be reimbursed from  federal funds later).
Adjacent areas were then filled with dredged material to create about 220 acres of
marshland. The demonstration is now a verdant green, and Glass believes that it
augurs well for the large-scale project.

Discussion: The  discussion touched on issues involving the relative costs of cre-
ating wetlands and the needier testing of materials prior to placement in wetlands.
Another issue concerned how to pay for the costs of wetlands monitoring after the
material is placed at the site. Currently monitoring costs are borne completely by
the nonfederal sponsor. Wetland restoration will inevitably involve substantial
costs for monitoring physical conditions, water quality, and habitat, and the fund-
ing possibilities for  those activities need to be further developed.
                                                                                23

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                                   APPENDIX
                               List of Acronyms
   AAPA  American Association of Ports Authorities
    CDF  Confined disposal facilities
    CMP  State coastal management program
    CSO  Coastal States Organization
   CWA  Clean Water Act
CWPPRA  Coastal Wetlands Planning, Protection, and Restoration Act of 1990
  CZMA  Coastal Zone Management Act of 1972
  DMMP  Dredged material management plan
    EPA  U.S. Environmental Protection Agency
    FWS  Fish and Wildlife Service, U.S. Department of the Interior
    LPG  Local Planning Group
   LTMS  Long-term Management Strategy
 MARAD  Maritime Administration, U.S. Department of Transportation
  MPRSA  Marine Protection, Research, and Sanctuaries Act of 1972
    MTS  Marine Transportation System, an initiative of the Department of
          Transportation
    NDT  National Dredging Team, a standing federal interagency work group
   NEPA  National Environmental Policy Act
  NMFS  National Marine Fisheries Service, NOAA,  Department of Commerce
  NOAA  National Oceanic and Atmospheric Administration, U.S. Department of
          Commerce
   O&M  Operations and maintenance dredging activities; often contrasted to
          dredging associated with new construction projects
  OCRM  Office of Ocean and Coastal Resource Management, NOAA
    ODA  Ocean Dumping Act—a popular name for the MPRSA
    RDT  Regional Dredging Team
    RHA  Rivers and Harbors Act of 1899
  USAGE  U.S. Army Corps of Engineers
  WRDA  Water Resources Development Act—authorizes bills for water projects;
          generally enacted every two years.
                                                                          [25

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                                  APPENDIX
           Sources of Further Information
U.S. ARMY CORPS OF ENGINEERS

The Corps' civil works program offers extensive information about the regulatory
and   budgetary   aspects   of   its   national   dredging   program   at
http://www.usace.arrnymil/inet/functions/cw/cw_home.htm.  The Corps' Dredging
Operations and Environmental Research program maintains a large volume of tech-
nical information about dredging, environmental  impacts, and beneficial uses at
http://www.wes.army.mil/el/dots/doer/. Detailed historical data on navigation and
dredging projects can be downloaded from http://www.wrsc.usace.army.mil/ndc.

ENVIRONMENTAL PROTECTION AGENCY

The Office of Water's Oceans and Coastal Protections Division has a website at
http://www.epa.gov/OWOW/oceans/index.html. Information about the National
Dredging Team and documents such as the local planning group guidance can be
found at http://www.epa.gov/owow/oceans/ndt/.

MARITIME ADMINISTRATION, DEPARTMENT OF
TRANSPORTATION

The reports on the Marine Transportation Initiative are available at the  MARAD
website at http://marad.dot.gov/reading_room/MTS/index.htm.


NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION

NOAA% Office of Ocean and Coastal Resource Management offers information about
federal consistency requirements under the CZMA and details on state coastal man-
agement programs at http://wave.nos.noaa.gov/ocrm/czm/welcome.html. The National
Marine Fisheries Service homepage  is located  at http://www.nmfs.gov/, and
includes links to information about implementation of the Magnuson Stevens Act

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AMERICAN ASSOCIATION OF PORT AUTHORITIES

AAPAs website at http://www.aapa-ports.org/ includes materials relevant to dredg-
ing and financing issues.


COASTAL STATES ORGANIZATION

CSO has a website at http://www.sso.org/cso/.


NATIONAL ACADEMY OF PUBLIC ADMINISTRATION

This report will be available at the website of the National Academy of Public
Administration at www.napawash.org,  under the link to the  Center for the
Economy and the Environment. That location also offers the text of the overhead
presentations made by the five regional breakout groups on the last day of the
workshop.


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                                 APPENDIX
                            Workshop Agenda
                  A WORKSHOP TO IMPROVE
 COORDINATION OF FEDERAL DREDGING ACTIVITIES AND
             STATE COASTAL MANAGEMENT PROGRAMS

                        January 20-22, 1999
                  Crowne Plaza Hotel, New Orleans
           333 Poydras Street, New Orleans, Louisiana 70130
                          (800) 522-6963

        SPONSORED BY THE NATIONAL DREDGING TEAM, THE
     OFFICE OF OCEAN AND COASTAL RESOURCE MANAGEMENT
             AND THE COASTAL STATES ORGANIZATION

Workshop Objectives: To bring together state coastal management program (CMP),
federal agency, and port representatives to learn about Coastal Zone Management Act
(CZMA) and federal dredging requirements and processes, to improve coordination
and cooperation, to avoid conflicts between state CMPs and federal agencies, and to
develop effective and efficient procedures to review dredging and dredged-material dis-
posal activities. Specific workshop objectives include the following:

  • Identify next steps and actions to address dredging issues and state CMPs.

  • Determine void state CMP-federal agency conflict late in the planning and
    approval of dredging activities.

  • Explore ways that federal agencies can seek and state CMPs can provide early
    input into the federal agencies' dredging planning and budget process.

  • Determine how to address state CMP enforceable policies in an effective and
    efficient manner.


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        Workshop participants will receive at the workshop a package of materials
        which will include several one-pagers on many of the issues. These one-pagers
        will help foster meaningful and focused discussions. The agenda is designed to
        limit presentations (presentations will be limited to 10-15 minutes each) to
        maximize discussion and participation. Issues and case studies not specifically
        included on the agenda may be raised during the discussions. The workshop is
        moderated by the National Academy of Public Administration (NAPA).


      DAY 1, WEDNESDAY, JANUARY 20

      8:15-8:30
      8:30-9:30
      9:30
Welcome (Workshop Moderator, Rick Minard, NAPA)
(purpose, objectives, agenda, format, materials)

Opening Remarks: What's at Stake. Speakers will discuss the eco-
nomic and environmental importance and consequences of dredg-
ing activities, as well as an overview of other dredging issues, from
their different perspectives.

• State representative (William Travis, BCDC)

• Corps representative (John Burns, Corps)

• Port representative (Tom Chase, AAPA)

Discussion 1—Coordinating the Federal Dredged  Material
Planning Process with State Coastal Management Programs
      Objective: To provide information on CZMA requirements and dredged material
      management planning opportunities; to discuss how CZMA activities and dredged
      material management planning can be coordinated to meet common economic
      and environmental objectives.

      9:30-9:35   Moderators Remarks (Rick Minard, NAPA)

      9:35-10:15  Session Chair: Tony MacDonald, CSO

                    • Interaction of Corps Navigation Programs, the Federal  Standard
                      and CZMA Requirements (Joseph Wilson, Corps)

                    • CZMA Requirements and Dredging—Recurring  Issues (David
                      Kaiser, OCRM)

                    • National Dredging Team Guidance on Local Planning Groups and
                      Development of Dredge Material Management Plans (Craig Vogt, EPA)

       10:15-10:45  Open Discussion

       10:45-11:00  Break
30

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 11:00-11:30  Case Studies in Dredge Material Management Planning; Successes
              and Problems:

              Session Chair: John Carey (Alabama State Ports)

              • Toledo Harbor: Up-strearn source control, watershed planning,
                arid recycling dredge material (Wayne Warren, OH DNR)

              • Rhode Island: State led  effort  in local dredge planning and
                regulatory reform (Jeff Willis, RI CRMC)

 11:30-12:15  Open Discussion

 12:15-1:30   Lunch, provided by workshop. Speaker: Katherine Vaughan, Esq.,
              Assistant Secretary for Natural Resources Department, Louisiana.
              The Coastal Wetlands Planning, Protection, and Restoration Act.
              Introduction: Terry Howey, LA CMP.
 1:30
Discussion 2—Federal and State Partnering Opportunities to Meet
Dredging and CZMA and State Objectives
Objective: To demonstrate how the beneficial use of dredged material can result
in efficient and  effective dredged material placement to meet navigation goals
while at the same time accomplish state CMP objectives. Provide practical infor-
mation on how this can be accomplished (funding, planning framework, coordi-
nation, etc.). Address problems and impediments to achieving beneficial use.
1:30-1:40
1:40-2:15
2:15-3:00

3:00-3:15
Moderator's Remarks (Rick Minard, NAPA)

Session Chair: Mike Carter, MARAD

Understanding and using the Federal Budget Process (Pete Luisa,
Corps)

• Beneficial Use of Dredged Material—Available Corps Authorities,
  Programs, and Funding (Rich Worthington, Corps)

• Meeting State CMP Dredging and Disposal Needs (Tom Nuckols,
  Texas CMP)

Open Discussion

Break
3:15^:15    Case Studies in Beneficial Use; Successes and Problems:

             Session Chair: Jim McGrath (Port of Oakland)


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      4:15-5:00

      5:00-5:30
• San  Francisco  Bay   Development   and  Beneficial   Use:
  Comprehensive planning  and  large-scale  marsh  restoration
  (Steve Goldbeck, BCDC)

• Louisiana: Beneficial-use issues (Gregg DuCote, LA CMP)

• Houston-Galveston Bay Marsh: Building stakeholder consensus
  (Phil Glass, USFWS)

Open Discussion

Closing observations for Day 1 and preparation for breakout discus-
sions for Day 2 (Rick Minard, NAPA)
      6:30-7:30     Reception

      DAY 2, THURSDAY, JANUARY 21

      Discussion 3—Identifying Efficient and Effective Processes for State, Federal, and
      Project-Sponsor Coordination

      Objective and charge to workgroups: To (1) identify issues, (2) determine whether
      an issue should be addressed at the local, regional, and/or national level, (3) whether
      there currently exists the means, authority,  or control to address the issue, and (4)
      possible next steps and actions to resolve the issues.

      8:15-8:30    Observations from day 1, setting up the breakout sessions, charge to
                    group (Rick Minard, NAPA)

      8:30-1:00    Regional  Breakout  Sessions: North Atlantic  Region (Maine  to
                    Virginia);  South Atlantic and Carribean Region (North Carolina to
                    Florida East Coast); Gulf Region (Florida West Coast to Texas); Great
                    Lakes Region; and  West Coast and Pacific  Islands Region.  Each
                    Regional meeting will have a facilitator and a recorder (each selected
                    from meeting participants).

      8:30-10:15   Regional breakout discussions

       10:15-10:30  Break

       10:30-12:00  Regional breakout discussions continue

       12:00-1:00   Working lunch, provided by workshop. Each Regional Group will
                    finish discussions and prepare report for Day 3.
32

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Some issues to consider in the regional discussions:

   • Implementing state CMP beneficial use policies when it is not the least cost
     alternative (Federal Standard)

   • Consolidating regulatory and CZMA actions (CZMA consistency, 404, 401,
     MPRSA, etc.)

   • Role of local, state, and federal laws, policies, and regulations in determining
     the base disposal plan (Federal Standard)

   • Flexibility in establishing the base plan (Federal Standard)

   • Role of watershed planning in addressing dredging issues

   • Best way to deal with the existing budget process

   • Funding future projects for beneficial use

   • Others?

2:00-5:30     Field Trip/bus tour to Port of New Orleans


DAY 3, FRIDAY, JANUARY 22

8:30-9:30     Reports  from  regional breakout  groups to entire  group.  (One
              spokesperson from each group lists the major issues and proposed
              actions. No discussion.) (Rick Minard, NAPA)

9:30-11:15    Open discussion of issues and development of action plan and next
              steps.

11:30-12:00  Short closing remarks by  Corps (Rich Worthington), EPA (Craig
              Vogt),  American  Association of Port Authorities (Tom  Chase),
              Coastal States  Organization (Tony MacDonald), OCRM (David
              Kaiser), and NAPA (Rick Minard).
Workshop Ends
1:30
Workshop  Committee Meeting (CSO, OCRM, Corps, EPA, and
NAPA)


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                                     APPENDIX
                         Workshop Participants
Arabatzis, Mike
USCOE
New York, New York
T-718/491-8721
F-718/491-8865
E-mail: Minas.M.Arabatzis@usace.army.mil

Babb-Brott, Deerin, Dredging Coordinator
Coastal Zone Management
100 Cambridge Street, 20th Floor
Boston, Massachusetts 02202
T-617/727-9530
F-617/723-5408
E-mail: DBABB-BROTT@STATE.MA.US

Bailey, William, Physical Scientist
U.S. Corps of Engineers
100 W. Oglethorpe Avenue (PD-E)
Savannah, Georgia 31401
T-912/652-5781
F-912/652-5787
E-mail: william.g.baileyusace.army.mil

Baier, Lawrence, Chief, Dredging       :
Dept. Environmental Protection
401 East State St,  6th Floor
Trenton, New Jersey 08625
T-609/292-8838
F-609/777-19140
E-mail: lbaier@dept..state.nj.us
Barnard, Thomas
Virginia Institute of Marine Science
Box 1346
Gloucester Point, Virginia 23062
T-804/684-7383
F-804/684-7179
E-mail: barn@virns.edu

Bellis, Caroline, Fed Consistency Specialist
Dept. Environment & Natural Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687
T-919/733-2293
F-919/733-1495

Booser, John
Dept. Environmental Protection
P.O. Box 8555
Harrisburg, Pennsylvania 17105-8555
T-717/787-5259
F-717/787-9549
E-mail: booser.john@al .dept..state.pa.us

Boyt, Jeb
Texas General Land Office
1700 North Congress Avenue, Rm-626
Austin, Texas 78701
T-512/475-3786
F-512/463-6311
E-mail: jboyt@glo.state.tx.us


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      Bradley, Paul
      USCOE—CESAM-OP
      P.O. Box 2288
      Mobile, Alabama 36602-3630
      T-334/690-2570

      Braun, Eric
      U.S. Corps of Engineers
      P.O. Box 2946 (CENWP-OP-NW)
      Portland, Oregon 97208-2946
      T-503/808-4768
      F-503/808-4344
      E-mail: eric.p.braun@usace.army.mil

      Burns, John
      U.S. Corps of Engineers (CECW-P)
      20 Massachusetts Ave., N.W
      Washington, D.C. 20314
      T-202/761-1853
      F-202/761-0140
      E-mail: john.j.bums@usace.army.mil

      Burns, John
      U.S. Corps of Engineers
      (CEPOA-EN-CW-ER)
      P.O. Box 898
      Anchorage, Alaska 99506-0898
      T-907/753-2630
      F-907/753-2625
      E-mail:
      john.a.burns@poa02.usace.army.mil

      Carangelo, Paul,
      Coastal Environmental Planner
      Corpus Christi Port Authority
      P.O. Box 1541
       Corpus Christi, Texas 78401
      T-512/882-5633
       F-512/882-3079
       E-mail: paul@pocca.com

       Carey, John, Chief Administrative Officer
       Alabama State Docks
       P.O. Box 1588
       Mobile, Alabama 36633
       T-334/441-7206
       F-334/441-7149
       E-mail: jcarey@ASDD.com
Carter, David
Dept. Natural Resources &
Environmental Control
89 Kings Highway
Dover, Delaware 19901
T-302/739-3451
F-302/739-2048
E-mail: dcarter@dnrec.state. de.us

Carter, Michael
U.S. Dept. of Transportation
400 Seventh Street, N.W, Rm-7209
Washington, D.C. 20590
T-202/366-8887
F-202/366-6988
E-mail: michael.carter@marad.dot.gov

Charles, Lynda
Dept. Environmental Protection
3900 Commonwealth Boulevard
(MS-300)
Tallahassee, Florida 32399-3000
T-850/487-4471
F-850/488-5257
E-mail: charles.l@epic5.dept..state.fl.us

Chase, Thomas, Director, Envir Affairs
American Association of Port Authorities
1010 Duke Street
Alexandria, Virginia 22015
T-703/306-4715
F-703/684-6321
E-mail: tchase@aapa-ports.org

Chesnutt, Charles, Coastal Engineer
U.S. Corps of Engineers (CECW-PF)
20 Massachusetts Ave., N.W
Washington, D.C. 20314
T-202/761-1853
F-202/761-1972
E-mail:
charles.b.chesnutt@usace.army.mil

Christerson, Neil,
Costal Mgmnt. Specialist
NOAA (SSMC4/11200/NORM3)
 1305 East-West Highway
Silver Spring, Maryland 20910
T-301/713-3113
 F-301/713-4367
 E-mail: neil.christerson@noaa.gov
36k.

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 Clark, Carrol
 Dept. of Natural Resources
 P.O. Box 94396
 Baton Rouge, Louisiana 70804
 T-225/342-418
 F-225/342-6801

 Darryl Clark
 U.S. Fish & Wildlife Service
 646 Cajundome Boulevard, Suite 400
 Lafayette, Louisiana 70506
 T-318/291-3111
 F-291-3139
 E-mail: R4fwe.lala@fws.gov

 Coye, Stephen
 National Academy of Public
 Administration
 1120  G  Street, N.W., Suite 850
 Washington, D.C. 20005
 T-202/347-3190
 F-202/393-0993
 E-mail: scoye@napawash.org

 Creef, Edward
 USCOE—CEMVN-OD-T
 PO. Box 60267
 New Orleans, Louisiana 70160-0267
 T-504/862-1337

 Crum, Bo
 U.S. Environmental Protection Agency
 61 Forsyth Street
Atlanta,  Georgia 30303-8960
 T-404/562-9352
 F-404/562-9343
 E-mail: crumb.bo@epa.gov

 Cunningham, Cathy
 Dept.  Environmental Quality
 P.O. Box 30458
 Lansing, Michigan 48909
T-517/335-3456
F-517-335-3451
E-mail: cunningc@state.mi.us
 Curfman, R. David
 Naval Facilities Engineering Command
 1510 Gilbert Street
 Norfolk, Virginia 23511-2699
 T-757-322-4203
 F-322-4416
 E-mail:
 CurfmannRD@efdlant.navfac.navy.mil

 DeLuca, Carl, Water Pollution Biologist
 Dept. of Environmental Protection
 PO. Box 8640
 Harrisburg, Pennsylvania 17105-8640
 T-717/772-5320
 F-717/772-0409

 Ducote, Greg
 Dept. Natural Resources
 P.O. Box 44487
 Baton Rouge, Louisiana 70804-4487
 T-225/342-5007
 F-504/342-9439
 E-mail: GREGDU@DNR.STATE.LA.U.S.

 Dunn, Dolan
 U.S. Corps of Engineers
 P.O. Box 1229
 Galveston, Texas 77550-1229
 T-409/766-3044
 F-409/766-3064
 E-mail: dolan.d.dunn@usace.army.mil

 Everson, Alan, Ecologist
 U.S. Corps of Engineers (CEPOH-CO-
 OR)
 Building 230
 Fort Shafter, Hawaii 96858
T-808/438-9258
 F-808/438-4060
 E-mail: Alan.Everson@usace.army.mil

 Fielland, Carl, Port Engineer
 Dante Fascell Port of Miami
 1015 North America Way, 2nd Floor
Miami, Florida 33132
T-305/347-4916
F-305/347-4893

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      Fisher, Ellen, Chief
      Dept. of Transportation
      4802 Sheboygan Ave, Rm-155B,
      P.O. Box 7914
      Madison, Wisconsin 53707-7914
      T-608/267-9319
      F-608/267-3567
      E-mail: ellen.fisher@dot.state.wi.us

      Friis, Michael
      Coastal Management Program
      101 East Wilson Street, 6th Floor
      P.O. Box 7862
      Madison, Wisconsin 53707-7868
      T-608/267-7982
      F-608/267-6931

      Gane, Brad, Chief, Cst'l Programs
      Dept. Envir Management &
      Coastal Programs
      4171 Commanders Drive
      Mobile, Alabama 36615
      T-334/432-6533
      F-334/432-6598
      E-mail: bwg@adem.state.al.us

      Ghigiarelli, Elder,
      Fed Consistency Coordinator
      Dept. of the Environment
      2500 Broening Highway, First Floor
      Baltimore, Maryland 21224
      T-410/631-8093
      F-410/631-8084
      E-mail: eghigiarelli@wmadom.mde

       Glass, Phil
      U.S. Fish & Wildlife Service
       Clear Lake Ecological Services Office
       17629 El Camino Real #211
       Houston, Texas 77058
       T-281/286-8282
       F-281/488-5882

       Goldbeck, Steve, Prog Director
       SF Bay Conservation & Dev Commission
       30 Van Ness Avenue, Suite 2011
       San Francisco, California 94122
       T-415/557-8786
       F-415/557-3767
       E-mail: steveg@bcdc.ca.gov
Griffin, Lynn
Dept. Environmental Protection
3900 Commonwealth Blvd (MS-47)
Tallahassee, Florida 32399-3000
T-850/487-2231
F-850/922-5380
E-mail: griffin_l@epic6.dept..state.fl.us

Gunn, Robert L.
USCOE—CEMVN-OD-G
P.O.  Box 60267
New Orleans, Louisiana 70160-0267
E-mail: robert.l.gunn@mrnul.usace.armymil

Habel, Mark
U.S. Corps of Engineers
696  Virginia Road
Concord, Massachusetts 01742-2751
T-978/318-8871
F-978-318-8285
E-mail: Mark.l.habel@usace.army.mil

Harper, Patric
U.S. Fish & Wildlife Service
P.O. Drawer 1190
Daphne, Alabama 36526
T-334/441-5181
F-334/441-6222
E-mail: patric_harper@fws.gov

Harris, Jeff
Dept. Natural Resources
P.O. Box 44487
Baton Rouge, Louisiana 70804-4487
T-225/342-5007
F-504/342-9439
E-mail: JEFFH@DNR.STATE.LA.US

 Hebenstreit, James
 Dept. Natural Resources
 402 N. Washington St., Rm-W264
 Indianapolis, Indiana 46205
 T-317/232-4160
 F-317/233-4579

 Heinzelmann, Raymond, Marketing
 Port of Philadelphia
 3460 N. Delaware Avenue (Rm 207)
 Philadelphia, Pennsylvania 19134
 T-215/427-8304
 F-215/427-8330
38

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 Hinesley, Phillip, Manager
 Dept. Economics 
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      Logue, Louis
      U.S. Corps of Engineers
      P.O. Box 80
      Vicksburg, Mississippi 39181-0080
      T-601/634-5882
      F-601/634-7073
      E-mail: Iouis.h.logue@mvd02.usace.army.mil

      Lombroia, Richard
      Canaveral Port Authority
      P.O. Box 267
      Cape Canaveral, Florida 32920
      T-407/783-7831
      F-407/783-1063

      Lousberg, Macara
      U.S. Environmental Protection Agency
      401 M Street, S.W. (4504F)
      Washington, D.C. 20460
      T-202/260-1909
      F-202/260-9960
      E-mail: lousberg.macara@epa.gov

      Luisa, Pete
      U.S. Corps of Engineers
      20 Massachusetts Avenue, N.W
      (CECW-BW)
      Washington, D.C. 20314
      T-202/761-8948
      F-202/761-5245
      E-mail: pete.c.luisa@usace.army.mil

      MacDonald, Tony
      Coastal States Organization
      444 North Capitol St., N.W, Suite 322
      Washington, D.C. 20001
      T-202/508-3860
      F-202/508-3843
      E-mail: cso@sso.org

      Magee, Percy, WQ Coordinator
       NRCS, USDA
       One Maritime Plaza
       Toledo, Ohio
       T-419/245-2514
       F-419/245-2519
       E-mail: percy.magee@oh.nrcs.usda.gov
Maher, Eileen, Senior Envir Specialist
Port of San Diego
EO. Box 120488
San Diego, California 92112-0488
T-619/686-6254
F-619/686-6467
E-mail: emaher@portofsandiego. org

Malek, John
U.S. Environmental Protection Agency
 1200 Sixth Avenue (ECO-083)
- Seattle, Washington 98101
T-206/553-1286
F-206/553-1775
E-mail: malek.john@epa.gov

 Linda G. Mathies
 USCOE - CEMVN-OD-T
 P.O. Box 60267
 New Orleans, Louisiana 70160-0267
 T-504/862-2318
 F-504/862-2317

 McGrath, Jim
 Port of Oakland
 P.O. Box 2064
 Oakland, California 94607
 T-510/272-1175
 F-510/465-3755
 jmcgrath@portoakland.com

 McHugh, Martin
 NOAA/Office of Response & Restoration
 Chicago, Illinois 60604
 T-312-886-0430
 F-312/353-5541
 E-mail: marty.mchugh@hazmat.noaa.gov

 Mendoza, Carlos
 U.S. Fish and Wildlife Service
  17629 El Camino Real
 Suite 211
 Houston, Texas 77058
 T-218/286-8282
 F-281/488-5882
  E-mail: Carlos_H_Mendoza@fws.gov
40

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Mille, Keith
Dept. Environmental Protection
3900 Commonwealth Blvd (MS-300)
Tallahassee, Florida 32399-3000
T-850/487-4471
F-850/488-5257
E-mail: mille_k@epic5.dept..state.fl.us

Minard, Jr., Richard
National Academy of Public
Administration
1120 G Street, N.W, Suite 850
Washington, D.C. 20005
T-202/347-3190
F-202/393-0993
E-mail: rminard@napawash.org

Muir, William, Oceanographer
U.S. Environmental Protection Agency
1650 Arch Street (3ES10)
Philadelphia, Pennsylvania 19103
T-215/814-2741
F-215/814-2782
E-mail: muir.william@epa.gov

Nuckols, Tom, Director
Coastal Division,  Texas
General Land Office
1700 N Congress, Suite 617
Austin, Texas
T-512/463-5054
F-512/475-0680
E-mail: tom.nuckols@glo.state.tx.us

Nieves, Carmen, Roman, Coordinator
Puerto Rico Planning Board
P.O. Box 44119 Minillas Station
San Juan, Puerto Rico 00940-1119
T-787/723-6200
F-787/723-4270

Nyc, Rudy
USCOE
66 Forsyth Street, SW
Atlanta, Georgia
T-404/522-5223
F-404/522-5233
E-mail:
NycR@SAD02.SAD.usace.army.mil
O'Donnell, Edward,
Navigation Project Manager
U.S. Corps of Engineers
696 Virginia Road
Concord, Massachusetts 01742-2751
T-978/318-8375
F-978/318-8285
E-mail: e.o'donnell@usace.army.mil

Oivanki, Stephen
Dept. Marine Resources
1141 Bayview Avenue, Suite 101
Biloxi, Mississippi 39530
T-228/374-5000
F-228/374-5008

Pabst, Doug, Team Leader
U.S. Environmental Protection Agency
290 Broadway
New York, New York 10007-1866
T-212/637-3797
F-212/637-3772
E-mail: pabst.douglas@epa.gov

Pasche, Cornelia
Dept. of Natural Resources
580 Taylor Avenue
Annapolis, Maryland 21401
T-410/260-8730
F-410-260-8739
E-mail: cpasche@dnr.state.md.us

Peloquin, Michael, (MNDNR Waters)
Dept. of Natural Resources
1568 Highway Z
Two Harbors, Minnesota 55804
T-218/834-6621
F-218/834-6639
E-mail: mike.peloquin@dnr.state.mn.us

Pickard, Scott,  Ecologist
U.S. Corps of Engineers
1776 Niagara Street
Buffalo, New York 14207-3199
T-716/879-4404
F-716/879-4357
E-mail: scott.w.pickard@usace.army.mil


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Povolny, Donald,
Real Estate/Land Mgmnt
Dept. of Natural Resources
1952 Belcher Drive (C-4)
Columbus, Ohio 43224-1386
T-614/265-6649
F-614/267-2981
E-mail: don.povolny@dnr.state.oh.us

Quirin, Olga, Environmental Scientist
U.S. Environmental Protection Agency
One Congress Street, Suite 1100 (CWQ)
Boston, Massachusetts 02114-2023
T-617/918-1542
F-617/918-1505
E-mail: quirin.olga@epa.gov

Raffington, Jasmin
Dept. Community Affairs
2555 Shumard Oak Boulevard, Suite 320
Tallahassee, Florida 32399-2100
T-850/922-5438
F-850/487-2899.
jasmin.raffington@dca.state.fl.us

Rees, Susan
USCOE
P.O. Box 2288 (CESAM-PD-EC)
Mobile, Alabama 36628-0001
T-334/694-4141
F-334/690-2721
E-mail: susan.i.rees@sam.usace.army.mil

Redford, Dave, Chief, MPCB
U.S. Environmental Protection Agency
401 M Street, S.W. (4504F)
Washington, D.C. 20460
T-202/260-9179
F-202/260-9920
E-mail:  redford.david@epa.gov

Reid, Jennifer
Dept. Natural Resources 
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 Schloop, Wayne, Chief/Project         :
 Operations
 U.S. Corps of Engineers, CELRE/CO/OO,
 P.O. Box 1027
 Detroit, Michigan 48231-1027,
 T-313/226-6797
 F-313/226-3519
 E-mail:
 Wayne.Schloop@lre02.usace.army.mil

 Schmidt, David
 USCOE
 EO. Box 4970
Jacksonville, Florida 32232-0019
 904/232-1697
 904/232-3442
 E-mail:
 david.v.schrnidt@saj02.usace.army.mil

 Schwartz, Suzanne, Director, OCPD
 U.S. Environmental Protection Agency
 401 M Street, S.W (4504F)
Washington, D.C. 20460
T-202/260-1952
 F-202/260-9960
 E-mail: schwartz.suzanne@epa.gov

Shuster, Glenn, Environmental Engineer
U.S. Corps  of Engineers
P.O. Box 4970 (CESAJ-PD-EE)
Jacksonville, Florida 32232-0019
T-904/232-3691
F-904/232-3442
E-mail:
Glenn.R.Schuster@usace.army.mil

Spiers, Sherry
Dept. Community Affairs
2555 Shumard Oak Boulevard, Suite 320
Tallahassee, Florida 32399-2100
T-850/922-5438
F-850/487-2800
E-mail: sherry.spiers@dca.state.fl.us

Stevens, Stuart
Dept. Natural Resources
One Conservation Way, Suite 300
Brunswick,  Georgia 31520-8687
T-912/264-7218
F-912/262-3143
stuart@ecology.dnr.state.ga.us
Sumeri, Alex, Project Manager
U.S. Corps of Engineers
P.O. Box 3755
Seattle, Washington 98124
T-206/764-3402
F-206/764-3308
E-mail: alex.sumeri@usace.army.mil

Swanson, Terry, Assist CSO Rep
Dept. of Ecology
EO. Box 47600
Olympus, Washington 98504-7600
T-360/407-6789
F-360/407-6535
E-mail: tswa461@ey.wa.gov

Thunberg, Marcia, Principal Planner
New Hampshire Coastal Program
2-1/2 Beacon Street
Concord, New Hampshire 03301
T-603/271-2155
F-603/271-1728

Tomey, Dave
U.S. Environmental Protection Agency
One Congress Street (CWQ)
Boston, Massachusetts 02114
T-617/918-1627
F-617/918-1505
E-mail: tomey.david@epa.gov

Tong, Lester
U.S. Corps of Engineers
333 Market Street
San Francisco,  California 94105-2195
T-415/977-8170
F-415/977-8183
E-mail: ltong@smtp.spd.usace.army.mil

Travis, Will, Executive Director,
SF Bay Comm
SF Bay Conservation &
Development Commission
30 Van Ness Avenue, suite 2011
San Francisco,  California 94102
T-415/557-8775
F-415/557-3767
E-mail: travis@bcdc.ca.gov
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Turvey, Martha, Sediment Cleanup Spec.
Dept. of Ecology
3190 160th Avenue SE
Bellevue, Washington 98008-5452
T-425/649-7208
F-425/649-7098
E-mail: mtur461@ecy.wa.gov

Valentine, Christine
Coastal Management Program
635 Capitol St. NE, Suite 200
Salem, Oregon 97301
T-503/373-0050
F-503/378-5518
E-mail: christine.valentine@state.or.us

Vaughn, Catherine, Assistant Secretary
Dept. of Natural Resources
625 N. 4th Street, llth Floor
Baton Rouge, Louisiana 70802
T-225/342-1375
F-225/342-1377
E-mail: KatherineV@DNR.State.LA.US

Vining, Rick, Dredging Specialist
Dept. of Ecology
PO Box 47703
Olympia, Washington 98504-7703
T-360/407-6944
F-360/407-6904
• E-mail: rvin461@ecy.wa.gov

Vogt, Craig, Dept.uty Director, OCPD
U.S. Environmental Protection Agency
401 M Street, S.W. (4504F)
Washington, D.C. 20460
 T-202/260-1952
 F-202/260-9960
 E-mail: vogt.craig@epa.gov

 Vowinkel, Scott
 U.S. Corps of Engineers
 111 North Canal Street
 Chicago, Illinois 60606
 T-312/353-6373
 F-312/353-8666
 E-mail: scott.g.vowinkel@usace.army.mil
Walker, Mike, Special Projects
Dept. of Marine Resources
1141 Bayview Avenue, Suite 101
Biloxi, Mississippi 39530
T-228/374-5000
F-228/374-5008
E-mail: mwalker@datasync.com

Warren, Wayne, Chief,
Real Estate/Land Mgmnt
Dept. of Natural Resources
1952 Belcher Drive (C-4)
Columbus, Ohio 43224
T-614/265-6384
F-614/267-4764
E-mail: wayne.warren@dnr.state.oh.us

Willis, Jeff, Marine Resources Specialist
Coastal Resources Management Council
4808 Tower Hill Road, Rm-116
Wakefield, Rhode Island 02879-1900
T-401/222-2476
F-401/222-3922
E-mail: jeffwillis@riconnect.com

Wilson, Joe
U.S. Corps of Engineers
20 Massachusetts Ave., N.W.
Washington, D.C. 20314
T-202/761-8846
F-202/761-8839

Wilder, Trudy
 U.S. Corps of Engineers
 P.O. Box 1890
 Wilmington, North Carolina 28402
 T-910/251-4581
 F-910/251-4965
 E-mail: trudy.n.wilder@usace.army.mil

 Wingfield, Betsey
 Dept. Environmental Protection
 79  Elm Street
 Hartford, Connecticut 06106-5127
 T-860-424-3034
 F-860-424-4054
 E-mail: betsey.wingfield@po.state.ct.us

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Wisker, George, Environmental Analyst
Dept. Environmental Protection
79 Elm Street
Hartford, Connecticut 06106-5127
T-860/424-3034
F-860/424-4054
E-mail: george.wisker@po.state.ct.us

Worsham, Bill, Coastal Engineer
Texas General Land Office
1700 N Congress, Suite 617
Austin, Texas 78701-1495
T-512/463-9215
F-512/475-0680
E-mail: bill.worsham@glo.state.tx.us

Worthington, Richard,
Senior Policy Advisor
U.S.  Corps of Engineers
20 Massachusetts Avenue, N.W
Washington, B.C. 20314
T-202/761-1184
F-202/761-8839
E-mail:
richard.t.worthington@usace.army.mil
Young, Monica, Environmental Scientist
U.S. Environmental Protection Agency
(6WQ-M)
1445 Ross Ave.
Dallas, Texas 75202
T-214/665-7349
F-214/665-6689
E-mail: young.monica@epa.gov
                                                                                A

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NATIONAL
ACADEMY
OF PUBLIC
ADMINISTRATION
1120 G STREET, NW   j
SUITE 850           |
WASHINGTON, DC 20005

TEL: (202) 347-3190  i
FAX: (202) 393-0993  i
WEB: www.napawash.prg

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