ISDS 



In addition to reconimending a raring system. The ISDS Task Force recommended that 

 specific changes be made in the current variance review procedure. These formed the basis 

 for the following recommended procedural changes, which should apply until a more 

 efficient point-based rating system can be established. 



**Expand the variance advisory board to five regular and three alternate 

 members. In addition to DEM, DOH, and local building inspectors, include 

 professionals with expertise in siting and design of ISDS and 

 understanding of public health/environmental issues. The board should include 

 soil scientists, hydrogeologists, town planners, representatives from CRMC or the DEM 

 Groundwater or Wetiands Sections, or others as appropriate to address the specific 

 concerns at hand. 



**Forward all requests for variances and special exceptions made to the 

 RIDEM ISDS Section (before action is taken) to the appropriate Town or 

 WWMD authorities so that pertinent data on the system and affected areas can be 

 colleaed and recorded in the WWMD accounting system, and so that consistency with 

 WWMD and Town policies can be assured if Town policies are more stringent than the 

 minimum state provisions. Forward all requests for variances and special exceptions 

 relating to coastal areas to CRMC so that potential impacts can be evaluated as part of the 

 subcommittee review and Council public hearing process. 



**Formalize notification procedures for variance board meetings to include 

 written notice to local communities, WWMDs, public water supply authorities, 

 watershed associations, CRMC, and other interested parties. Institute a system whereby 

 formal notification can be requested within affected resource areas. (See also TOWN 

 COUNCILS/WWMDs.) 



♦Forward copies of RIDEM actions on variance requests, and conditions attached, to the 

 appropriate Town or WWMD authorities so that data can be effectively recorded in the 

 WWMD accounting system. 



***Clearly place the burden of proof on applicant to demonstrate that 

 approval of a variance will not result in a reduced level of protection of 

 environmental quality or public health than that afforded by strict 

 application of regulatory standards. Further, require that the applicant furnish proof 

 that enforcement of the regulations would do manifest injustice. 



SITING AND DESIGN 



Findings and Concerns 



Rhode Island minimum design standards provide that a percolation rate slower than 40 

 min/inch is unsuitable for ISDS siting, and that a percolation rate slower than 20 min/uich 

 is unsuitable for siting of large systems having flows exceeding 20(X) gpd. These 

 standards do not adequately address site suitability. 



Regulatory standards governing the siting, design and construction of large systems, 

 and multiple systems in concentration, are insufficientiy detailed. 



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