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Orange Water and Sewer Authority <br />Comments to Orange County <br />Commissioners and Planning Board <br />August 26,.1991 <br />Page 2 <br />Both House Bill 156 and Section .0104(k) of the state regulations <br />allow the EMC to "designate water supply watersheds or portions <br />thereof as critical water supply watersheds and impose management <br />requirements that are more stringent than the minimum statewide <br />water supply . . . requirements." <br />In order to preserve the status of University Lake, both OWASA <br />and Chapel Hill have asked the EMC to designate University Lake <br />as a Critical Water Supply Watershed, as provided by state <br />statute and regulations. We believe that the 1969 Camp Dresser <br />and McKee report and the stringent zoning and subdivision <br />requirements adopted last year by Orange County and Carrboro <br />solidly document University Lake's need for protection that goes <br />beyond the "statewide minimum." I am aware that Critical Water <br />Supply Watershed designation is easily confused with the critical <br />areas delineated around each water supply. Critical Water Supply <br />Watershed designation, as provided by state law, would reinforce <br />the Camp Dresser McKee and Orange County recommendation that the <br />entire University Lake watershed be treated as a critical area. <br />Such designation by the EMC would help protect the currently <br />strong University Lake program from future actions that might <br />weaken it. Similar protection may be needed for Cane. Creek, <br />depending in part on the findings of a special analysis that <br />OWASA plans to sponsor during the 1992 -93 fiscal year. <br />Although it's unlikely that the EMC will designate either <br />University Lake or Cane Creek as Critical Watersheds until after <br />completing the reclassification process and after reviewing our <br />current local standards and ordinances, OWASA urges the County to <br />support this request now in order to emphasize to the EMC the <br />importance that Orange County places on its water supp -lies. <br />Regarding stream buffers around new development, you'll note that <br />we asked the EMC to extend the 100 foot buffer, requirement to all <br />perennial and intermittent streams in WS —II wate- rsheds shown on <br />USGS topographic maps. Present state rules apply only to <br />permanent streams. Although Orange County's and Carrboro's <br />