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mangrove alteration at the sea wall site as it is very hard to tell what was there beforehand. Commissioner Bowman felt we should take "before" and "after" photographs, but Director Keating pointed out that it would be very difficult to get a "before" shot in many cases because we don't know far enough in advance what is planned. With regard to the Ambruit Development Corporation permit application, it appears that some mangroves were cut beforehand without a permit, and staff is working with the Urban Forester to determine just when they were cut. He emphasized that it is very difficult to enforce tree protection and mangrove alteration. Commissioner Bowman questioned #3, where they are proposing to build, south of Ambersand Subdivision, a 20 -ft. wide driveway across a salt pond. She emphasized that those salt ponds are already in critical shape because they were cut off from the river when the road was built; there is high salinity; and there is not enough oxygen in the water to support mangrove roots. She proposed that we require the installation of culverts under that road so that the two remaining salt ponds can wash. Commissioner Bowman recalled that a number of years ago an owner on the other side of AIA was required to put in a culvert under his roadway, but just ignored it. She believed that unless we get tough, people will continue to try and get away with these things. ON MOTION by Commissioner Eggert, SECONDED by Commissioner Bowman, the Board unanimously authorized staff to forward the comments set out above to the DER; with the added recommendation that the installation of roadway culverts be required on Item #3 - Application No. 31-130621-4. Robert Keating, Director of Planning & Development, announced that Michael Miller has been named Chief of Environmental Planning, replacing Art Challacombe who recently moved to Hawaii. BOOK 7 , r�uC 5'136 MAR 10 1987 13