Stonn water and Sediment 



Trained enforcement officers on the CRMC staff need to be available to 

 undertake inspections and other field enforcement duties. Use of technical 

 personnel in this capacity without the support of officers has long been a subject of debate 

 with DEM wetlands enforcement, and reliance on technical personnel should be avoided. 

 Although staff biologists and engineers involved with specific project applications are most 

 familiar with site characteristics and permit conditions, their technical capabilities and 

 professional standing are best applied in a neutral implementation role. 



Full implementation of non-point source control practices will require 

 more than doubling the present engineering staff of CRMC, because of the 

 need to undertake site-specific design and inspection surveys to ensure 

 proper use of design criteria. Although die Wedands Section welcomes 

 standardization of design requirements between the Section and municipalities, the Section 

 will be required to prove non-conformance with design specifications in order to talce 

 enforcement action against violators. The inspection process is expected to be labor 

 intensive, and to very heavily involve engineering staff. 



Recommendations to CRMC 



(See also other sections of Pan 2, and Chapter 3.1) 



♦♦♦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 ail CRMC 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 press. Attach applicable 

 erosion and sedimentation controls and maintenance and repair provisions to all CRMC 

 permits. 



♦♦♦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. 



♦♦Providing that currently proposed and recommended legislation 

 providing for land evidence record permit attachment is acted upon, work 

 with the State Building Commissioner to improve local permit enforcement. 



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 CRMC 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 assuring compliance with stipulations before a building or occupancy permit is issued. 



148 



