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38 <br /> surface water quality protection plan. It would seem appropriate to require such a plan for the golf <br /> holes where tree removal was necessary. This plan could be included in the site management/BMP <br /> plans that are already required. <br /> It seems that 6.23.7 number three should be included in the plans discussed within number 2. This <br /> helps to avoid redundancy and to encourage comprehensive planning, thus the plan encompasses <br /> the use of new vegetation to prevent erosion, minimize sedimentation, and to maximize the <br /> assimilation ofpotentially mobile pollutants. <br /> Comment#5-Within the applicability section of 8.8.7.1, the requirement for existing golf courses <br /> should be defined as 50%or more of the total acreage of playable golf holes. Often greens are <br /> reconstructed in order to help with BMP's. Greens constitute less than 5%of the total acreage on <br /> a golf course, but renovation of nine greens would constitute 50%of the holes as the draft <br /> currently states. The total acreage requirement would seem more reasonable. <br /> Within 8.8.7.2 "A categorized biological inventory"may be more appropriate to a given site and <br /> much less subject to misinterpretation, with the exception of species currently protected under the <br /> Endangered Species Act. <br /> Within subpart h., a requirement to submit a comprehensive Strategic Environmental Management <br /> (SEM)plan that includes a Resource Management and Mitigation Plan as a part of(or in addition <br /> to)the BMP submitted,once again avoids redundancy and encourages greater integration. The <br /> IPM plan could serve a component of the SEM plan. Suitable IPM program requirements would <br /> include: 1)a summary of the predominant types vegetation and approximate total acreage to be <br /> managed along with, 2)the pest problems associated with each that could occur within the first few <br /> years of operations, and 3) when possible,provide a list of the types of compounds that may be <br /> used(categorized by chemistry rather than trade names)and the biological methods appropriate, in <br /> the event the previously identified pest problems should occur. Within this plan,the proposed <br /> methods of oversight should be summarized as well(scouting,hand sampling,mechanical <br /> monitoring techniques, etc.). <br /> j. -This is already required by law <br /> Within 8.8.7.3 part a, numbers three and four- these requirements may not be unreasonable but <br /> more detail as to the basis or the foundation for the selected parameters should be stated(statistics, <br /> hydrogeological data, insurance requirements, etc.). In number five, a 50'to 75'minimum would <br /> seem adequate if the facilities are designed with the appropriate containment and recycling systems <br /> in place. The presence of closed loop systems and/or facility design should provide for the option <br /> for lesser distance requirements on a site by site basis. <br /> Within part c-number 2 strike screened(enhanced may be a better term). In number 3, facilities <br /> shall either provide on site composting and recycling . . . or provide a proof of contract with public <br /> or privatized composting and recycling vendors. <br /> Within part e-the requirement in(1)f is unreasonable unless the county is willing to provide <br /> assistance with capital costs for handling the trees for timber purposes. In(2), strike screened, <br /> (enhanced may be a better term). In(5),selection of turfgrasses should be based on local <br /> 2 <br />