Technical Summary 



State administrative agencies need to give increased consideration to the 

 close relationship between non-point source control and flood hazard 

 management, evaluating cumulative impacts of hydrologic modification and hazard area 

 alteration as key components of land use review and permit evaluation. Accounting 

 methods should be u^ which evaluate watershed land and water resources as interrelated 

 components of the hydrologic cycle. 



Consistency 



The inconsistencies evident between state and local provisions, among 

 various agency provisions, and within the permit review processes are due 

 in part to staffing limitations, and in part to the overlapping sequences of 

 procedures surrounding review of permits and variances. Inconsistencies are 

 also attributable 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 review bodies, through formal and informal means. 



Incongruities among state agency practices are a major concern. For 

 example, non-point source control efforts would be significantiy enhanced by resolution of 

 inconsistencies between existing non-point source initiatives and certain DOT policies, as 

 well as the practice of DOT contractors. It is critical that a comprehensive review 

 of state and federal highway construction safety and engineering 

 requirements be undertaken to identify all inconsistencies between those 

 provisions and the recommendations of the Stormwater and Erosion Control 

 Committee and other state task force groups regarding non-point source 

 pollution control practices. 



Statutes in general should encourage consistent compliance on the part of local, state, 

 and federal governments, by specifically including self-regulation of public uses. State 

 regulations should ^ply consistent tecluiical requirements and design and maintenance 

 specifications for non-point source control measures. As a key aspect of improved 

 consistency, provisions and requirements of state regulations need to be 

 speciflcally referenced in the statewide building code, and in individual 

 town ordinances and requirements. 



Enforcement 



Neither DEM nor CRMC have sufficient resources to monitor initial or 

 long-term compliance with permit conditions. Full implementation of non-point 

 control practices will require more tiian doubling the present engineering staff assigned to 

 permit review and inspection at bodi DEM and CRMC, because of the need to undertake 

 site-specific design and inspection surveys to ensure proper application of design criteria. 

 Because non-point source controls are especially vulnerable to poor 

 maintenance, permits should also 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. 



A local enforcement and review fee should be required of all state permit 

 applicants. The fee required should be commensurate with the size of the project and 

 with potential watershed impact. The funds collected should be passed through to the town 

 in question to support hiring of local environmental officers responsible for enforcement of 



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