Falmouth Board of Health backs sending RME draft to DEP, seeks clarification on sampling and oversight

The Town of Falmouth Board of Health voted in concept to support a draft cover letter and Responsible Management Entity (RME) framework prepared by the water quality management committee and to forward that material to the select board for transmittal to the Massachusetts Department of Environmental Protection (DEP).

Members said the draft is intended to open a dialogue with DEP before the town commits consultant funds or finalizes watershed management plans. Board members repeatedly emphasized the need for DEP input on two technical questions the town faces: an acceptable monitoring/sampling scheme for IA systems integrated into watershed plans, and which nitrogen-reduction technologies DEP will allow towns to count in plan load reductions.

"All we want is open a dialogue with DEP," a board member said, arguing the town should get a response on sampling and RME roles before spending consultant money. Several members said monthly sampling for every IA system (a model DEP staff had previously proposed in other contexts) would be cost-prohibitive and urged quarterly or randomized sampling approaches; others recommended running simulations (Monte Carlo) with existing town data to show DEP whether less-intensive sampling could produce comparable watershed results.

Board members also discussed the distinction between methods (measuring concentration versus load), how the town would treat novel technologies (for example, urine-diversion or composting toilets that are not on DEP lists), and enforcement/oversight questions for an RME. One member said: "We need somebody in the town that bears oversight responsibility if the subcontractor is doing the work — the management entity must have someone to oversee implementation." The board agreed that the letter should be clear that the draft is a ‘‘straw man’’ intended to solicit comment and that the town seeks DEP feedback by Oct. 1, if possible.

The board agreed to coordinate with the select board and asked staff to schedule joint meetings with the water quality management committee and other stakeholders to refine the RME language and implementation details. Members noted near-term deadlines for select-board packet scheduling and said the chair would forward a cover memo and the draft to the select board in time for the select board’s packet cycle.

What happens next: the board’s chair said she will send the cover memo to the select board; the water quality management committee will proceed with its watershed-plan work while the town seeks DEP guidance to avoid spending funds on approaches DEP may later reject.