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_. .. _ .. .. <br /> - , the land could not be developed. With such a system, 14 houses <br /> , are proposed for phase one , with what look like at least an 18 <br /> . - equal number proposed for later. <br /> Cluster development with communitY sYstems may be a good <br /> idea in some places. But it is not suitable for the watershed. <br /> . We have had to learn a lot about such sYstems in recent months, <br /> and the news for the watershed is not 000d. Among the problems <br /> are : <br /> • <br /> --new tethnology: these systems have not been used long <br /> enough to know how they will stand up in critical areas; <br /> OWASA plans to use University Lake until the end of the next <br /> century-- how long will these untested Ystems last? <br /> . . <br /> --elaborate equipment prone to failures: read the <br /> consultants' report on low pressure systems carefully--there <br /> are a lot of potential problems with the expensive pumps and <br /> electrical and plumbing systems. The report is a cross <br /> between a sales pitch and a technical report and is very <br /> sobering. . <br /> uncertain responsibilities: who is to maintain the system? <br /> the howeowner? a homeowners association (such groups have a <br /> very poor record in these areas)?, a public utility? It is <br /> • not clear from the proposal . Who puts up the money right <br /> away when a pump or drain field fails? <br /> --unclear jurisdiction : approval is by the Division of <br /> Environmental Manaoement if it is tobe operated by a public <br /> utility and by the Health Department if by a homeowners <br /> associatton--the proposal refers to both as if they were the <br /> same . If the permit is to be oranted by DEM, the county has <br /> little or no say and the public has no right of appeal --only <br /> the developer if he or ' she is turned down . <br /> --inadequate reoulations: the state rules on the systems <br /> make NO distiction between low pressure systems in just any <br /> watershed and those impacting public drinking water <br /> supplies; higher standards are needed for the later . The <br /> OWASA comments are very pertinent on this question . OWASA <br /> also offers further critique of the relation of this design <br /> to the state standards. It's conclusion : there is too little <br /> margin for error . "Marginal " Piedmont soils in a watershed <br /> are ndt suitable . * . <br /> • • A public water supply is not an appropriate place 'FOP <br /> reasearch on alternative waste systems. This conclusion holds <br /> • whether they are to serve 14 units or 158. It would be <br /> apprpriate for Oranoe County to consider implementing a <br /> moratorium On SUCh systems at least until the OWASA study is <br /> completed and evaluated. 1 suggest you to do just that . <br /> It is important to ask how a development such as McLennan's <br /> Farm, fit into the County policy on the watershed? I was <br /> surprised when I called the Planting Department to find that the <br />