CZM outlines how it will review Army Corps nationwide permits, stresses direct PCN submissions and new response timelines

A presenter for CZM explained in a webinar that the Army Corps’ nationwide permits are scheduled to be implemented on March 15, 2026, and described how the Massachusetts Coastal Zone Management (CZM) office will apply federal consistency review to those permits.

The presenter said the nationwide permits are treated as a federal agency activity and that CZM has issued a conditional concurrence on the permits. The presentation stressed that applicants should consult CZM’s concurrence document to determine whether their project exceeds thresholds that would trigger CZM review.

Why this matters: the Army Corps adjusted the thresholds used to trigger pre‑construction notification (PCN) and individual permits under the nationwide permits, but CZM’s enforceable policies and review expectations have not changed. As a result, projects categorized as “non‑reporting” under the nationwide permits may nonetheless require CZM federal consistency review.

The presenter reviewed how federal consistency is triggered and handled in Massachusetts. Historically, Massachusetts general permits (issued in 2023) used three authorization buckets—self‑verification, PCN, and individual permits. CZM provided full concurrence for self‑verification projects under the general permits, meaning those projects did not require further CZM review. For PCN‑eligible projects, CZM has used an expedited coordination process with the Army Corps: CZM provides comments to the Corps, which relays them to applicants, and the parties exchange information until consistency with enforceable policy is reached. Projects requiring individual permits continue to follow the individual federal consistency review process, which includes a public notice and a six‑month review timeline.

Key procedural change under the nationwide permits: applicants must submit PCN notifications directly to CZM rather than relying on the Army Corps to act as the intermediary. "Applicants will submit their information directly to CZM and CZM will coordinate directly with you on your submission," the presenter said. The presenter added that individual‑permit applicants will still follow the existing six‑month individual review process.

What applicants must provide: the presenter listed required submission materials CZM expects when a project exceeds the concurrence thresholds, including copies of other permit applications, project design documents, descriptions of measures taken to minimize impacts to natural resources, and a description of coastal effects. CZM said it may request additional information as needed to determine whether federal consistency review is required.

Response timelines and process: CZM will notify applicants within seven days whether their submission is complete; once CZM confirms completeness, CZM has 14 days to provide any comments or concerns that begin a back‑and‑forth exchange with the applicant. The presenter said that only in very rare cases would CZM require an individual federal consistency review for a project applying under the nationwide permits.

How to submit and where to find materials: the presenter provided the address shown in the webinar (czm.fedconmass.gov) for submitting PCN notifications and said CZM will post a project‑status spreadsheet and an overview of the federal consistency process on its web page. The presenter also said the concurrence document, which lists the thresholds that trigger CZM review, will be posted on CZM’s website and offered to send the document directly to webinar registrants. A recording of the webinar will be posted on the CZM federal consistency web page.

The presenter closed by opening the webinar to questions and offering to follow up with registrants on the concurrence document and the planned public viewer for project status.