ISDS 



Communication among DEM sections concerned with ISDS within the Division of 

 Groundwater and Freshwater Wedands, and among decision-makers at DEM, the Division 

 of Planning, and CRMC is incomplete. This is due in part to staffing limitations, in part to 

 the overlapping sequences of procedures surrounding review of permits andvariances, and 

 in part to differences in technical training and inconsistencies in interpretation of mandate. 

 There is a clear need to establish better coordination and consistency of approach among 

 these groups, through formal and informal means. 



There is a clear need for improved coordination between point source 

 and non-point source control programs at DEM, particularly where 

 wastewater treatment issues concerning package plants and septage disposal 

 are concerned- The Office of Environmental Coordination should take the lead in 

 improving coordination. 



In all of the agencies concerned with ISDS-related permitting (in fact, 

 in all of the state's permitting programs), staff limitations and the burden 

 of permit review create a focus on achieving efficient permit decision- 

 making to the exclusion of broader program development, strategic 

 planning, program coordination, or review of cumulative effects. 



CRMC, tiirough the Coastal Resources Management Program and particularly through 

 die implementation of Special Area Management Plans, possesses broad authority to 

 regulate ISDS siting in view of the potential impact of these systems on the coastal 

 environment CRMC authority complements that of DEM's Division of Wedands and 

 Groundwater, which issues ISDS permits to ensure that minimum standards are upheld 

 with respect to the siting, design, and construction of the systems. 



While ISDS Task Force Recommendations, and the recommendations of 

 this study, attempt to broaden the consideration of groundwater impacts in 

 DEM ISDS permitting, current regulations are oriented toward system 

 function and relate primarily to public health considerations. For these 

 reasons, effective interpretation and implementation of CRMC's strong 

 coastal resource protection mandate is of key importance. As described in 

 related sections, CRMC has interpreted its jurisdiction narrowly and has 

 been unable to enforce many of its policies and permit requirements. 



Concerns ax the Local Level 



The present regulatory system relies on town building inspectors to 

 ensure adequacy of system sizing, and to assume the primary inspection 

 role. Almost without exception, building inspectors have neither the time, 

 the training, nor the political independence to perform this task adequately. 



Further, inspectors have no presumed authority to notify DEM of instances of violation. 



In general, planning capability at the local level is woefully inadequate. 



Aldiough some towns have moved to develop quahfied local planning staff within the past 

 several years, many rural communities in the Bay watershed, where ISDS problems are 

 most severe, have no planning staff at all, let alone the planning capability to address 

 difficult wastewater management issues. Research in other Bay Project 

 watersheds shows that local planning capability is strongly correlated with 

 development of effective non-point source control programs. 



50 



