Technical Summary 



State wetlands and other environmental pennit requirements. Pass-through of funds would 

 be contingent on local review and inspection performance. 



Mandatory training and licensing programs should be established for 

 local building inspectors, surveyors, designers, contractors, state agency 

 professionals, environmental officers, site evaluators, and others involved 

 with designing, building, reviewing, or regulating facilities which contribute to non-point 

 source pollution. To retain licenses and professional standing, licensees and others above 

 should be required to attend periodic "review and update" woricshops on state policy, 

 regulations, and procedure. 



Appeals 



The regulatory appeal procedure applied in Rhode Island creates a presumption that the 

 burden of proof should fall to regulatory bodies to justify enforcement of regulations. The 

 appeal procedure is cumbersome and gives excessive power to the judiciary in interpreting 

 technical regulatory mandates of executive agencies. The Administrative Procedures 

 Act needs to be amended to allow state administrative bodies to submit staff 

 reports as fact, to provide the appeal procedure strict criteria of entry, and 

 to ensure that the burden of proof falls to the applicant to demonstrate that 

 strict application of the regulatory provisions at issue is unwarranted. 



Coordination 



Communication and coordination among and within agencies needs to be activated. 

 Present problems are deep-seated, and are due to competition for available resources, 

 conflicts over interpretation of mandate and allocation of responsibility, firiction between the 

 legislature and the administration, regulatory inconsistency, and other issues. These 

 divisions present serious obstacles to implementation of a successful non-point source 

 control program. An outgoing forum for communication needs to be put in 

 place to ensure improved consistency among state agency objectives and 

 programs implemented. 



Reorganization 



The Division of Planning should be moved out of the Department of Administration, 

 given departmental status, and reorganized. 



Responsibility for administration of the Coastal Community Assistance Program should 

 be given to CRMC, and should be used to fund local programs which meet specific 

 standards and selection criteria related to CRMC's mandate and program priorities. 



An interagency executive level council should be formed to facilitate 

 communication and cooperation among state programs concerned with land 

 use and water resource management, and to monitor agency progress in 

 improving program effectiveness. 



A permanent interagency science advisory group should be formed to 



keep managers abreast of developing scientific information relevant to estuarine 

 management, to create a forum for debate regarding the methods to be used in developing 



12 



