Work Plan & Progress Report - Rhode Island Department of ...

• Need to discuss with the Region for FY 2011 on what an appropriate mix of LQGs and SQGs
for RCRA inspections.
• Short term priority is participating in the discussions about the permitting/enforcement intersect
coming out of the CWA action plan. There is an interest in a meeting with the other authorized
states to discuss the topics.
• EPA was interested in DEM’s Mystic River approach focusing on bacteria.
• RI sees a lot at stake for FY 11 in permit/enforcement issues and the “resetting of the state/EPA
relationship.”
• Frequency of RCRA inspections at either good or bad facilities is an issue.
• State does not have a relationship with its tribes. The lack of one is a fallout from other actions
not involving RIDEM.
• Wetlands enforcement is difficult post-Rapanos; but more importantly the staff reduction of
staff (5 FTEs down to 2 FTEs) is posing a problem. Wetlands enforcement is a specialty area
that needs specific training particularly with construction storm water overlay. DEM could use
assistance from Army Corps.
• Lead RRP is DOH issue. DOH has applied and has been given primacy for rule
implementation and enforcement.
Meeting Summary
• RIDEM needs flexibilities from Region I going into FY 2011 in recognition of staff/resource
limitations
• RIDEM will identify training needs and work with region.
• Post 06/2011 may cause concern and consternation. Region needs to be prepared to factor in to
EOY FY 2011 activities.
• Data quality/transparency is an on-going issue that needs constant attention.
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