Permit Application Public Notices

The United States Congress authorizes the U.S. Army Corps of Engineers to regulate activities that may impact wetlands and waters of the United States. This authority is granted and defined under Section 10 of the Rivers and Harbors Act of 1899 and Section 404 of the Federal Water Pollution Control Act Amendments of 1972, also known as the Clean Water Act.

Public involvement is a key element of the Corps’ permit review process. During an application review, the Corps considers the views of other federal, state and local agencies, Native American tribes, interest groups, and the general public. The results of this careful public interest review are fair and equitable decisions that allow reasonable use of private property, infrastructure development, and growth of the economy, while offsetting the authorized impacts to the waters of the United States.

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Portland District
Published Feb. 28, 2022
Expiration date: 3/30/2022

Application for Permit

Issue Date: February 28, 2022
Expiration Date: March 30, 2022
                            U.S. Army Corps of Engineers No: NWP-2020-428

30-Day Notice

Interested parties are hereby notified the U.S. Army Corps of Engineers, Portland District (Corps) has received an application for a Department of the Army permit for certain work in waters of the United States, as described below and shown on the attached drawings. The Corps is soliciting comments on the proposed work.

Applicant:    Mr. Clifford Glover    
                       4849 Lower Smith River Road 
                       Reedsport, Oregon 97467
                       Telephone: (541) 707-0090

Applicant’s Agent:     Partnership for the Umpqua Rivers
                                        Attention:  Mr. Eric Riley
                                        3012 West Harvard Avenue 
                                        Roseburg, Oregon 97471
                                        Telephone: (541) 673-5756

Location: The project site is located on 98 acres of levee protected tidelands adjacent to the Smith River, river mile 4.5 located at 4849 Lower Smith River Road near Reedsport, Douglas County, Oregon. The site is in Sections 17, 19 and 20, Township 21 South, Range 11 West.  Latitude and Longitude:  43.739712° North, -124.051657° West.

The proposed project lies on private land behind the 1.05-mile Tract C levee of the larger Smith River Flood Damage Reduction (FDR) Project. The Smith River FDR is a U.S. Corps of Engineers federally authorized and non-federally operated and maintained agricultural flood levee project located northeast of Reedsport, Oregon.  

Camp Seven Gulch Creek and an unnamed tributary flow into two stream channels within the project area which drain to the Smith River estuary on the northwest and northeast sides of the property.  Flows enter the property through culverts maintained by Douglas County on Lower Smith River Road.  The streams contribute to an extensive wetland complex. A network of 9 existing drainage ditches are directly or indirectly connected to the two stream channels which transmit water between the subject property and the Smith River. The two channels are fitted with culvert and tide gate structures that contribute to the flooding of 98 acres of wetland pasture during the summer and winter months. 

Waterways: The Corps has not verified the wetland boundaries. The applicant has identified 11 stream channels (the two tributaries and the nine ditches) within the project area consisting of a minimum of 9,050 linear feet.   For clarity, the channels are assigned letters.  Channel A is a former drainage ditch that would become a permanently controlled channel. Channels B, C, D, E, F, G, and H are existing drainage ditches. Channels I and J are existing channels with tide gates. The location of the ordinary high-water mark (OHWM) and High Tide Line (HTL) shown on the project drawings have not yet been verified by the Corps. If the Corps determines the boundaries of the wetland/waters are substantially inaccurate a new public notice may be published.

Project Purpose: The applicant’s stated purpose is to improve the capacity of agricultural land by managing tidal flows and seasonal water inputs, and to provide fish passage to Camp Seven Gulch Creek.  The water management plan would result in 40 acres of wetland and channel inundation during the winter months and 3 acres of inundation during the summer months through improved drainage.  All summer inundation would occur in 4,160 linear feet of channel.

Project Description: 
The project would require a combined total of 3,503 cubic yards (cy) of permanent fill in approximately 6.7 acres of wetlands and waters to replace the existing failing tide gates (relocating one of them), establish one new permanent stream channel, regrade the existing ditches, and establish livestock crossings and a livestock watering system.

With the exception of Channels A and I, there would be no change to the lengths of all channels on site.  Channel A would gain 300 linear feet and a direct connection to the Smith River. Channel I would lose approximately 35 linear feet under the federal levee and its direct connection to the Smith River due to the permanent removal of the culvert and tide gate structure. 

The applicant would seek an in-water work variance to allow all ground disturbing work to occur during the driest season. This would facilitate construction activities and avoid king tides which occur during the recommended in water work window of November 1 through January 31. The applicant would work sequentially to ensure that fresh water entering the site consistently has an outlet to the Smith River.

Project Component 1: Tide gates and Water Management

Waters in which work would occur for this project component include Channels A, J, and I, as well as immediately adjacent wetland areas. For this component, the applicant would access the worksites and stage materials utilizing the existing levee.  The existing tide gates within the project site at Channel I and Channel J are attached to culverts that reach the Smith River under the federal levee.  The tidegates are in disrepair and no longer efficiently drain water entering the project area.

The applicant would replace the failing tide gate at Channel J with a six-foot diameter culvert fitted with a tide gate and controlled by a muted tidal regulator (MTR) assembly. The applicant would create a new channel outlet at Channel A with two five-foot diameter culverts fitted with tide gates and controlled by a single MTR. As proposed, the project would reduce tidal inundation from an estimated 98 acres within the project area to 40 acres of wetland and channels between November 1 through April 1 of each calendar year. Inundation levels would be further reduced between April 2 through October 31 annually to 3 acres within 4,160 linear feet of channel to provide for seasonal livestock grazing. The water management plan would manage for tidal channels and ditches to attain a water level one foot below field level during the summer.

All tide gate work would occur during outgoing tides. The applicant would discharge 1,236 cy of fill in 0.08 acre of Channels A and J and 122 cy of fill in 0.28 acre of wetlands to conduct tide gate replacement and new construction activities. The applicant would discharge 222 cy of fill material into Channel I to reconstruct a 0.02-acre section of levee. Channel A and J would have up to two culverts fitted with a side-hinged tide gate and one MTR.  We will refer to the combination as a “structure” in this public notice.

Channel A Tide Gates Installation Details
To install the tide gate at the newly constructed terminus of Channel A (see Channel and Ditch Modification section (Channel Profile Updates subsection) below for ditch construction details), the applicant would remove a 0.3-acre segment of the federal levee to install two 5-foot side hinge tide gate structures side by side with one controlling MTR. The applicant would construct a new 150 linear foot channel outlet at this location. This modification would permanently convert Channel A to an extension of Camp Seven Gulch Creek measuring 2,300 linear feet by 25-50 feet wide.  

Prior to installation, the applicant would isolate the work area on both sides of the levee at low tide. Any water within the isolated area would be pumped onto the fields to minimize sediment inputs to the Smith River. Once isolated, the applicant would excavate the prior mentioned 0.3-acre section of the levee to install the culverts. The applicant would discharge 295 cy of soils and riprap into 1,120 sf of soils into the excavated area where the levee was, on each side of the newly installed structure connecting Channel A to the Smith River.  This will hold the structure in place.  In addition, the applicant would discharge 660 sf of riprap into Channel A and the Smith River for splash aprons to decrease the potential for scour.  The applicant would limit heavy equipment use and materials staging to the top of the levee for this component. The new 150 linear foot section of channel would conform to the proposed channel profile described further below in the Channel and Ditch Modifications section.

Channel J Tide Gates Installation Details
Prior to tide gate installation, the applicant would isolate the work area on both sides of the levee the same as described for Channel A above.  This would occur during low tide.  A temporary coffer dam would also be constructed in Channel J to route flows from Channel J into Channel B. Any water remaining within the isolated area would be pumped onto the adjacent field. A professional fish biologist would conduct fish salvage within the work area before any excavation.

The applicant would replace an existing tide gate and culvert with one 6-foot diameter culvert, side-hinged tide gate, and MTR unit. The applicant would discharge 740 cy of soils and riprap in 0.03 acre (1,100 square feet of armoring and 540 square feet of splash apron) on each side of the newly installed structure connecting Channel J with the Smith River to decrease scour potential. 

Once all installation of the structure is complete, coffer dams would be removed and prior flows would return to Channel J.

Heavy equipment needed to transport and place the coffer dam materials at Channel J would occur in wetland due to the distance of Channel B from the levee. All other culvert, tide gate and MTR activities would occur from the levee. 

Channel I Tide Gates Removal Details
The applicant would permanently isolate Channel I from the Smith River. Existing flows from Camp Seven Gulch Creek which currently exit through Channel I would be permanently routed through the reconfigured Channel A. The applicant would access the existing culvert at Channel I by utilizing the federal levee. The applicant would work from the top of the bank to remove the culvert/tide gate structure with heavy equipment. The applicant would discharge 222 cy of fill material into 0.02 acre of Channel I to reconstruct the levee to a height of 13 feet. The source of fill material would be excess soils derived from the excavation of Channel A. Also, the applicant has stated that for all fill activities, there is the potential for material to be derived from an upland area on the east side of the property. All culvert material would be removed and taken to an upland area. With the exception of Channel K (which drains to Channel J), all other channels, including Channel I, would drain to the Smith River through Channel A. The remaining portion of Channel I on the landward side of the former tide gate structure is described in more detail below under the Channel and Ditch Modifications section.

Project Component 2: Channel and Ditch Modifications

Waters in which work would occur for this project component include fill in 4.3 acres of wetland and 12,310 linear feet of Channels A, B, C, D, I, J and K. Stream profiles would be adjusted to improve drainage capacity and reduce fish entrapment potential. 

Channel A Connection to the Smith River
The applicant proposes to redesign Channel A to replace Channel I as the Camp Seven Gulch Creek outlet to the Smith River. From the existing road culvert where Camp Seven Gulch Creek enters the property, the applicant would conduct 60 linear feet of channel armoring at the junction of Channel A and Channel I to address scour associated with transferring flows from Channel I to Channel A. The applicant would also construct two 150 linear foot segments of channel in wetland. The first segment is perpendicular to Channels E and C and connects two currently separate portions of Channel A together. The second segment connects Channel A to the Smith River just downstream of the confluence of Channel A and Channel B.  

Channel Profile Updates
To implement the Water Management Plan, the applicant would primarily modify Channel A and J stream channel profiles. The applicant would use heavy equipment within wetlands working from the top of the stream bank to establish a maximum depth of 3.5 feet in all channels. Channel depths would vary from 1 to 3 feet deep with 2V:1H slopes on one side of the channel. The applicant would excavate approximately 2,977 cy of soils and sediments in all channels total. The applicant would thin spread this material in wetland on the modified side of the channel not more than 40 feet from each channel and not more than three inches deep, in an area 4.3 acres. No loss of wetlands would occur from the thin spreading.  With the exception of Channel A and J, 4,650 linear feet of channels, would have a bottom width of 6 feet.  Channel A and J would have a bottom width of 10 feet. 

Table 1 Channel and Ditch Modifications at the top of the bank.
Channel    Existing Length (ft)    Existing Width(ft)    Existing Depth(ft)    Proposed Width(ft)    Proposed Depth(ft)
A    2000    25-50    1-3    25-50    1.5-3.5
A1 at C (proposed channel)    150 (proposed)    0    0    35    3.5
A2 at G (proposed channel)    150 (proposed)    0    0    35    3.5
B    1250    15-20    1-3    15-20    1.5-3.5
C    900    10-15    1-3    10-15    1.5-3.5
D    1025    10-20    1-3    10-20    1.5-3.5
I    525    23    1-3    23    1.5-3.5
J    2000    40    1-3    40    1.5-3.5
K    950    10-20    1-3    10-20    1.5-3.5

Project Component 3: Pool construction

Waters in which work would occur for this project component include wetlands, as well as Channels A and I.

The applicant would also excavate 80 cy soils from 0.04 acre of wetland at the confluence of Channels A and I to construct an in-channel pool, addressing the orientation of the existing culvert and reallocation of flows from Camp Seven Gulch Creek into Channel A. The applicant would armor 60 linear feet of the pool’s bank to prevent the force of water leaving the culvert from uncontrolled erosion.  The pond would also provide a jump pool for migrating adult salmon. No work would be conducted to alter the culvert. Excess material derived from channel modifications would be thin spread across wetlands, preferentially in low-lying areas with fish stranding potential to attain positive drainage.  No loss of wetlands would occur from the thin spreading. 

Project Component 4: Livestock Crossings 

Waters in which work would occur for this project component include wetlands.

The applicant would install four 16-foot by 24-foot pre-cast concrete bridges across channels supported by concrete footings within project area wetlands to allow for livestock crossing and field maintenance. Two livestock crossings would be placed across Channel A and two across Channel J. Each bridge location would include one 1,080 sf gravel approach, for a combined fill of 4,320 cy in 0.03 acre of permanent fill in wetland. The two bridges over Channel A would receive 501 sf and 450 sf of riprap armoring in wetland respectively while the two bridges over Channel J would receive 429 sf of armoring each in wetlands. The total placement of armoring in wetlands would be 1,808.5 sf or 0.04 acre. 

Project Component 5: Livestock Watering System Installation

Waters in which work would occur for this component include wetlands.

The applicant would install a gravity-fed livestock watering system. The system would include a discharge of gravel into 700 sf of wetland to create gravel pads for the system.  To install the system, the applicant would temporarily trench 4,080 linear feet of wetland up to 2-feet deep to install a 1.5-inch diameter polyvinyl chloride (PVC) water line to service seven watering trough sites 

Project Component 6: Livestock Fencing

Waters in which work would occur for this project component include 19 sf of wetland spanning 5.2 miles of the project area.

The applicant would install 27,378 linear feet of exclusion fence around Channel A and Channel J to prevent livestock from effecting the channel’s new configuration. The applicant would use a post pounder to set into concrete fill approximately 684 four-by-four wooden posts 40 feet apart. 

Mitigation: The applicant proposes to avoid and minimize impacts from the project by working during the driest time of the year to avoid sedimentation potential into the Smith River. The applicant would also ensure fill is clean if brought into the site to decrease the potential for weed dispersal. The applicant did not propose compensatory mitigation in the permit application. The Corps will determine the type and amount of compensatory mitigation necessary to offset environmental losses from the proposed project.

Drawings: Thirty-two (32) drawings are attached and labeled Corps No. NWP-2020-428 Copies of this public notice, which have been mailed or otherwise physically distributed, feature project drawings in black and white. The electronic version features those drawings in color, which we think more accurately illustrates the proposed project. To access the electronic version of this public notice, go to the Portland District Regulatory website at and under Regulatory Pages select Permit Application Public Notices.

Authority: The proposed project will be evaluated under the following:

Section 10, Rivers and Harbors Act 1899 (33 U.S.C. 403), for work in or affecting navigable waters of the United States.

Section 14, Rivers and Harbors Act 1899 (33 U.S.C. 408) (referred to as “Section 408”), for work to alter a Corps civil works project. An alteration is defined as any action that builds upon, alters, improves, moves, occupies, or otherwise affects the usefulness, or the structural or ecological integrity of a Corps federally authorized project. The proposed project may alter the Smith River Flood Damage Reduction (FDR) Project. 

Section 404, Clean Water Act (33 U.S.C. 1344), for discharge of dredged or fill material into waters of the United States.

Clean Water Act Section 404(b)(1) Guidelines: The described discharge will be evaluated for compliance with guidelines promulgated by the U.S. Environmental Protection Agency under authority of Section 404(b)(1) of the Clean Water Act. The 404(b)(1) Guidelines are the substantive criteria used in evaluating discharges of dredged or fill material into waters of the United States. The Corps will evaluate the fill material source (i.e., borrow site) prior to finalizing a permit decision.

Water Quality Certification: Section 401 of the Clean Water Act (33 U.S.C. 1341) requires applicants to obtain a water quality certification for proposed discharges into waters of the United States. A permit for the described work will not be issued until certification has been issued or is waived from the certifying state. Attached is the state's notice for a water quality certification.

Coastal Zone Management: Section 307(c) of the Coastal Zone Management Act of 1972, as amended (16 U.S.C. 1456(c), requires non-Federal applicants seeking a federal license or permit to conduct any activity occurring in or affecting the coastal zone to obtain a Consistency Certification which indicates the activity conforms with the State’s Coastal Zone Management Program. The applicant believes the proposed project would comply with and be conducted in a manner consistent with the Oregon Ocean and Coastal Management Program. Attached is the state's notice for a consistency certification.

Endangered Species: Section 7 of the Endangered Species Act (ESA) (16 U.S.C. 1536) requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and/or U.S. Fish and Wildlife Service (USFWS) on all actions that may affect a species listed (or proposed for listing) under the ESA as threatened or endangered or that may adversely modify designated critical habitat. The Corps’ preliminary review indicates the described activity may affect an endangered or threatened species or designated critical habitat. The Corps has initiated consultation under Section 7 of the ESA. 

Essential Fish Habitat: Section 305(b)(2) of the Magnuson-Stevens Fishery Conservation and Management Act (MSA) as amended (16 U.S.C. 1855), requires Federal agencies to consult with the NMFS on all actions, or proposed actions, permitted, funded, or undertaken by the agency, that may adversely affect Essential Fish Habitat (EFH). The Corps’ preliminary review indicates the described activity 
would not adversely affect EFH at the project location or in its vicinity. The Corps will make a final determination on the need to consult on EFH after receipt of comments from this public notice including any comments provided by the NMFS.

Historic Properties/Cultural Resources: Section 106 of the National Historic Preservation Act of 1966, as amended (54 U.S.C. 306108), requires Federal agencies to consult with the appropriate State and/or Tribal Historic Preservation Officer to take into account the effects of actions they undertake or permit on historic properties listed in or eligible for listing in the National Register of Historic Places. The Corps’ preliminary review indicates to the best of our knowledge, the described activity is not located on property registered or eligible for registration in the latest published version of the National Register of Historic Places. At this time the applicant is completing a cultural resource survey for the project area.

This notice has been provided to the Oregon State Historic Preservation Office (SHPO), interested Native American Tribes, and other interested parties. If you have information pertaining to cultural resources within the permit area, please provide this information to the Corps’ project manager identified at the end of this notice to assist in a complete evaluation of potential effects.

State and Local Authorizations: The applicant has obtained approval from Douglas County. The applicant has applied a Removal-Fill Permit from the Department of State Lands (DSL) (DSL No. 63228).

Public Hearing: Any person may request in writing within the comment period specified in this notice that a public hearing be held to consider this application. Requests for public hearings shall state with particularity the reasons for holding a public hearing.

Evaluation: The decision whether to issue a permit will be based on an evaluation of the probable impact, including cumulative impacts, of the described activity on the public interest. That decision will reflect the national concern for both protection and utilization of important resources. The benefit, which reasonably may be expected to accrue from the described activity, must be balanced against its reasonably foreseeable detriments. All factors, which may be relevant to the proposal will be considered including the cumulative effects thereof; among those are conservation, economics, aesthetics, general environmental concerns, wetlands, historic properties, fish and wildlife values, flood hazards, floodplain values, land use, navigation, shoreline erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, mineral needs, consideration of property ownership and, in general, the needs and welfare of the people.

The Corps is soliciting comments from the public; Federal, state, and local agencies and officials; Native American Tribes; and other interested parties in order to consider and evaluate the impacts of the proposed activity. Any comments received will be considered by the Corps to determine whether to allow an alteration of a federally authorized project or to issue, modify, condition, or deny a permit for this proposal. To make this decision, comments are used to assess impacts on endangered species, historic properties, water quality, general environmental effects, and the other public interest factors listed above. Comments are used in the preparation of an Environmental Assessment and/or an Environmental Impact Statement pursuant to the National Environmental Policy Act. Comments are also used to determine the need for a public hearing and to determine the overall public interest of the proposed activity.

Submitting Comments: Interested parties are invited to provide comments on the proposed project. Comments may be submitted by conventional mail or email. All comments received will be considered in determining whether authorizing the work would be contrary to the public interest. 

Either conventional mail or e-mail comments must include the Corps reference number as shown on page 1 and include the commenter’s name and address. In order to be accepted, e-mail comments must originate from the author’s e-mail account and must include on the subject line of the e-mail message the Corps reference number. All comments received will become part of the administrative record and are subject to public release under the Freedom of Information Act including any personally identifiable information such as names, phone numbers, and addresses.

Additional information about the proposed project may be obtained from the Corps Project Manager listed below. All comments, whether by conventional mail or email, must be received no later than the expiration date of this public notice to ensure consideration. Comments should be submitted to the following mailing address or email address:


        U.S. Army Corps of Engineers
        Ms. Anita Andazola
        Eugene Field Office
        211 E. 7th Avenue, Suite 105
        Eugene, Oregon 97401-2763
        Telephone: (541) 465-6894


Oregon Department of Environmental Quality (DEQ)
Water Quality 401 Certification

Notice Issued: February 28, 2022
Written Comments Due: March 30, 2022

Corps of Engineers No: NWP-2020-428
Oregon Department of State Lands No: 63225-RF    

WHO IS THE APPLICANT: Mr. Clifford Glover

LOCATION OF CERTIFICATION ACTIVITY: See attached U.S. Army Corps of Engineers public notice.

WHAT IS PROPOSED: See attached U.S. Army Corps of Engineers public notice on the proposed project.

NEED FOR CERTIFICATION: Section 401 of the Federal Clean Water Act requires applicants for Federal permits or licenses to provide the Federal agency a water quality certification from the State of Oregon if the proposed activity may result in a discharge to waters of the state.

DESCRIPTION OF DISCHARGES: See attached U.S. Army Corps of Engineers public notice on the proposed project.

WHERE TO FIND DOCUMENTS: Documents and materials related to water quality issues as a result of the proposal are available for examination and copying at Oregon Department of Environmental Quality, 401 Water Quality Permit Coordinator, Northwest Region, 700 NE Multnomah Street, Suite 600, Portland, Oregon 97232. Other project materials are available by contacting the Corps per the attached public notice.

Scheduling an appointment will ensure that water quality documents are readily accessible during your visit. To schedule an appointment please call DEQ Water Quality at Northwest Region at (503) 229-5623.

Any questions on the water quality certification process may be addressed to the 401 Permit Coordinator at (503) 229-5623 or toll free within Oregon at (800) 452-4011. People with hearing impairments may call the Oregon Telecommunications Relay Service at (800) 735-2900.


Public Hearing: Oregon Administrative Rule (OAR) 340-48-0032 (2) states that “The Corps provides public notice of and opportunity to comment on the applications, including the application for certification, provided that the department (DEQ), in its discretion, may provide additional opportunity for public comment, including public hearing.” Additional Section 401 process information is available on DEQ’s webpage (

Written comments: Written comments on project elements related to water quality must be received at the Oregon Department of Environmental Quality by 5 p.m. on the date specified in the upper right section on page one of this notice. Written comments may be submitted electronically through Your DEQ Online ( For questions regarding account registration, system navigation, or training resources, please visit the Your DEQ Online help webpage ( 

WHAT HAPPENS NEXT: DEQ will review and consider all comments received during the public comment period. Following this review, certification of the proposal may be issued as proposed, issued with conditions, or denied. You will be notified of DEQ's final decision if you submit comments during the comment period. Otherwise, if you wish to receive notification, please call or write DEQ at the above address. Public records can be accessed through the Your DEQ Online public records portal webpage

ACCESSIBILITY INFORMATION: DEQ can provide documents in an alternate format or in a language other than English upon request. Call DEQ at (800) 452-4011 or email


Date: February 28, 2022

U.S. Army Corps of Engineers No: Corps No. NWP-2020-428
Oregon Department of State Lands No: 63225-RF

For projects subject to coastal zone review, notice is hereby given that the project is being reviewed by the Department of Land Conservation and Development (DLCD) as provided in Section 307(c) of the Coastal Zone Management Act. The applicant believes that the activities described in the attached materials would comply with and be conducted in a manner consistent with the Oregon Ocean and Coastal Management Program. Project information can be made available for inspection at DLCD's Salem office.

DLCD is hereby soliciting public comments on the proposed project's consistency with the Oregon Coastal Management Program. Written comments may be submitted to DLCD, 635 Capital Street NE, Suite 150, Salem, Oregon 97301-2540. Comments may also be sent by fax to (503) 378-6033 or by email to All comments must be received by DLCD on or before the comment deadline listed in the accompanying Corps of Engineers’ Public Notice Application for Permit. For further information, you may call DLCD at (503) 373-0050.

Comments should address consistency with the applicable enforceable policies of the Oregon Coastal Management Program. These enforceable policies are found in the following:

•    Acknowledged Local Comprehensive Plans & Implementing Ordinances
•    Statewide Planning Goals
•    Applicable State Authorities incorporated into the Oregon Coastal Management Program (e.g. Removal-Fill Law, Water Quality Standards, Beach Bill, etc.) as applicable.

A list of specific enforceable policies can be found at the following link:

If you believe this project is inconsistent with the Oregon Coastal Management Program, your comments to DLCD should explain why you believe the project is inconsistent and should identify the Oregon Coastal Management Program element(s) in question. You should also describe how the project could be modified, if possible, to make it consistent with the Oregon Coastal Management Program.