Stonnwater and Sediment 



environmental pennit requirements. Pass-through of funds would be contingent on 

 Wetlands Section spot-checks of pennit compliance consistency among town land evidence 

 records, state permit requirements, and evidence in the fielA 



**In permits, ensure that responsibility for maintenance of permit 

 conditions is established, along with a clear mechanism for transfer of responsibility 

 at the time of a change in ownership. 



***In cooperation with the State Building Commissioner, develop an 

 administrative mechanism to ensure that building inspectors or other town 

 officials (such as environmental officers) obtain the land evidence records 

 on all relevant properties to verify that wetlands permit application data is 

 fully recorded. Develop a permit bonding fee or other legal mechanism to make the 

 inspector or the town in question liable for assming compliance with stipulations before a 

 building or occupancy permit is issued. Because severe non-point pollutant impacts are 

 associated with project construction, this program linkage is crucial. 



**Expand the practice of taking action on properties in which violations go uncorrected. 

 Ensure that land evidence records are not tampered with during periods of anticipated 

 property transfer. 



Slewing 



**Hire additional staff as necessary to allow the Section to: < 



a) issue cease and desist orders wherever unpermitted actions have the 

 potential to degrade the environment and wherever permit conditions 

 are not being complied with; 



b) make timely site visits to ensure compliance with orders; 



c) issue timely notices of violation if orders are not complied with; 



d) refer violations for timely legal action if necessary. 



*Consider separating staff implementation and enforcement roles. A number of potential 

 approaches could be considered. A team of staff biologists might be dedicated specifically 

 to responding to complaints and testifying as expert wimesses in violation cases. These 

 staff members could coordinate with pennit review staff as necessary. Alternatively, 

 conservation officers or other enforcement personnel could be trained to serve cease and 

 desist orders and to follow up on compliance. CRMCs experience with shellfish 

 enforcement officers could be drawn upon in the latter case. 



Recommendations to DOT 



**In cooperation with the state Attorney General's Office, standardize 

 contract stipulations so as to penalize contractors not adhering to design 

 speciflcations, such as those regarding installation and maintenance of soil 

 erosion and sediment control practices. 



***In cooperation with the state Attorney General's Office, develop a 

 contract bid review procedure which escalates performance bonding 

 requirements based on past conformance with contract provisions relating 



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