ISDS 



Force, SepL 9, 1986) Mr. Janaros stated that shortage of staff to pursue enforcement 

 through the court system had been the limiting factor, and that a new staff person had 

 recentiy been dedicated solely to action on major ISDS violations. 



As more stringent standards are adopted, instances of violation will undoubtedly 

 increase. DEM must possess sufficient legal staff to pursue ISDS violations of all types 

 with the resources appropriate to a significant public health hazard. 



Recommendations to the Department of Administration 



**Consolidate ISDS investigation and enforcement responsibilities with 

 DEM, and provide resources adequate to fuifili enforcement 

 responsibilities. 



♦Develop a budget process which allocates to the ISDS section a basic annual budgetary 

 allotment, to be augmented by dedication of fees collected by the section. 



Recommendations to RIDEM 



***Increase staff of ISDS Section or related Division Sections to ensure 

 that adequate inspection and enforcement capability exists, and can be 

 dedicated to these purposes. Hiring sufficient soil scientists, hydrogeologists, and 

 engineers will require, at a minimum, tripling the number of the staff available to undertake 

 inspection and enforcement. 



I *Increase legal staff devoted to action on ISDS violations. 



**Develop and implement a comprehensive on-line data management system 

 for the ISDS Section, enabling the Section staff to: 



a) retrieve permit and enforcement data by applicant name plat number, lot number, 

 zoning designation, etc.; 



b) retrieve permit data by site specification (e.g., soil or percolation rate category); 



c) generate educational materials on necessary maintenance to permit holders 

 automatically at appropriate intervals; and 



d) generate enforcement-related documents automatically. 



**Develop a comprehensive data tracking system (coordinating the data 

 management system described above with those of the Wetiands and Groundwater Sections 

 and odier relevant data management systems at CRMC and the Division of Planning) 

 which would enable decision makers at the state, regional and local levels 

 to target efforts effectively, assess results of model programs, learn the 

 strengths and weaknesses of various approaches, and balance priorities 

 among the range of non-point source pollution problems requiring 

 attention. 



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