Coastal Services Center

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General Features of Management Programs (4 of 7)

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Standards for Administration (Continued)

Standards should be at once

• Definitive
  They should advise applicants of general requirements and policies regarding the use of submerged lands.
• Flexible
  They shoud allow for case-by-case determinations.

Any lack of definitiveness in substantive standards should be compensated for with procedural standards to ensure that substantive issues are decided in a fair and reasonable manner.

• A bedrock principle of government is fairness. At least in a procedural sense, the principle applies no matter what the nature of government activities, even if there is no entitlement to a privilege.
• Thus, current licensees and leaseholders have a right to due process whenever a modification or revocation may result from agency action.