CRMC 



measurements will be used in evaluating the adequacy of stormwater, erosion, and 

 sedimentation control measures and facility designs. Similarly, they should define how 

 water quality measures will be used in measuring adequacy of facility performance through 

 time, and in initiating enforcement procedures where maintenance schedules are not 

 adhered to and non-point source controls are allowed to become insufficienUy effective. 



***As an aspect of the preceding responsibility, a two-part management 

 oriented water quality standard should be established in which each agency 

 responsible for regulating activities with a potential for contaminating 

 waterbodies would set both a preventive action limit and an enforcement 

 standard. The preventive action limit would be a small fraction of the companion 

 enforcement standard; violation of this limit would trigger an examination of possible 

 responses by the administrative body having jurisdiction over the source. Depending on 

 the actual or potential seriousness of the contamination, the agency could require site- 

 specific remedial action, revise agency rules to address the problem, or take no action. 

 Violation of the enforcement would trigger an immediate enforcement action against the 

 violator. 



**Prepare a geographically-based mapped record of potential cumulative effects to be used 

 in coordination with DEM permitting and wasteload allocation. 



Planning 



As outlined above, project permit applicants and Council Staff are to be guided by 

 elements of the Rhode Island CRMP, applicable SAM plans, and the State Guide Plan 

 Overview. Land use guidance provided by the State Guide Plan provides valuable support 

 to CRMC in meeting its ecosystem management mandate. In consideration of this program 

 linkage, CRMC management procedures stipulate that the Division review applications to 

 ensure their conformance with the objectives of the State Guide Plan. 



In fact, coordination between the Division of Planning and CRMC is 

 incomplete, although the Division receives nearly ten percent of the federal coastal 

 program implementation funds which come into the state. A Division planner reviews a 

 portion of CRMC applications, but his comments are not binding on CRMC, and he is not 

 included in subcommittee or staff review of the applications. CRMC can issue an assent 

 before comments from the Division are received or reviewed. The Division has no 

 specific authority to provide technical evidence in Council hearing 

 proceedings, nor to rebut incorrect evidence which may be presented by a 

 developer or a town. 



Similarly, with regard to A-95 review, the Division's comments are 

 accorded little formal weight in permit evaluation. The Division's broad role in 

 outer continental shelf development planning gives it much valuable expertise to contribute 

 in evaluating broad impacts of federal facility siting issues. 



Recommendations 



**Revise applicable regulations and procedures to provide for fiill incorporation of 

 Division of Planning comments at the subcommittee review stage of application 

 assessment. Appoint an appropriate technical staffperson and an appropriate community 

 affairs staffperson from the Division of Planning to serve as members of each 



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