CRMC 



clear illustrations. Staff work with project designers to encourage installation of adequate 

 practices on a case-by-case basis. 



As in other aspects of its program implementation, CRMC does not have 

 sufficient staff to make site visits as necessary to ensure proper design, 

 construction, and maintenance of control structures, to measure their 

 effectiveness over time, and to require remedial action as necessary. 



Recommendations 



***Revise CRMC regulations to specifically incorporate the technical 

 requirements, recommendations and language of the Stormwater and 

 Erosion Control Committee regarding stormwater management planning, 

 design and installation of best management practices, and maintenance and 

 repair of facilities. Attach applicable stormwater controls and maintenance 

 and repair provisions to all permits. 



***Revise CRMC regulations to specifically incorporate the technical 

 requirements, recommendations and language of the Stormwater and 

 Erosion Control Committee regarding erosion and sedimentation control, 

 design and installation of best management practices, and maintenance and 

 repair of facilities. These technical requirements will be defined in the updated Rhode 

 Island Sediment and Erosion Control Handbook, currentiy in preparation. Attach 

 applicable erosion and sedimentation controls and maintenance and repair 

 provisions to all CRMC permits. 



**In coordination with the Division of Planning and DEM, assist towns in 

 developing wastewater management policies and plans (including 

 mandatory ISDS upgrading), and in establishing wastewater management 

 districts. 



**Work with DEM, the Division of Planning, and Conservation Districts to 

 assist towns in developing comprehensive stormwater management and 

 erosion and sedimentation control programs. 



COORDINATION AND CONSISTENCY 



Findings and Concerns 



Issues surrounding water quality permitting authority in the Bay itself are complicated. 

 Because the Bay as a whole has not been designated as water quality 

 limited, DEM has not used waste load allocations to translate existing 

 criteria into discharge limits for permits. In a series of permit review 

 procedures, CRMC and DEM have been at odds regarding application of 

 discharge criteria. (CRMC overrode DEM three times in tiie early 1980's on the Hunt 

 ChemicS discharge permit, for example.) 



DEM denies water quality certifications where degradation of classified 

 waters is anticipated, but has not prepared guidance or evaluation standards 

 to govern the certification process. Because designated uses are based on 

 goals, rather than on existing conditions, and because clear evaluation 



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