Wetlands and The CSPA are apart of the same department, but they are different permiting processes. Breakwaters, docks, moorings, etc fall under a wetlands permit and not under CSPA. The criteria for a permit is different the process is different. As I said, CSPA will surely be involved regarding the parking and access issues.
You only have to count trees if your impermiable surface area exceeds 20% of your land. These rules and this program make it easier to develop on waterfront, but it does restrict the ability to completely destroy the water front buffer zone.
Some serious time needs to be spent with DES through their outreach seminars to get up to speed with how these programs interact.
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