Agenda - 08-26-1991 - Laserfiche WebLink

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EMC WATERSHED COMMENTS Page 3 We support the establishment of a buffer for agricultural activities but believe that setting it at a mere 10 feet is grossly inadequate. The rules should require a nominal 100 foot buffer, the same as for other activities, with the provision that it can be reduced in practice by the use of BMP's which provide an equivalent level of protection. The proposal for only a ten foot buffer, besides perpetuating the appearance of special provisions for agriculture, increases pressures for other interests to seek reduced buffers thereby further diluting needed protection. The proposal to require BMP's only for "animal operations with more than 100 animal units" is also inadequate. BMP's should be required for all animal operations in water supply watersheds. Many small operations add up to as big a problem as one larger one, and controls for small operations need not be extensive or expensive. The ACSP may also provide some assistance. We believe the process for developing the proposed changes for agricultural operations was seriously flawed. DEM's Public Information Package states that, because of comments received at last year's hearing, "the EMC instruct[ed] the DEM staff to review [agricultural] activities and -fit- meetings with representatives from [agricultural] groups tadiscuss possible protection measures." [p. 9] Whatever review and meetings took place, the process was selective at best. ARC, among other agricultural groups, was not informed, contacted, consulted, or invited to any meetings on the subject despite the fact that we have expressed concerns about the impact of agricultural operations, testified at last year's hearings, and submitted written comments on the subject a year op. .01040) Cooperation Among Jurisdictions: This section provides encouragement for cooperative efforts among jurisdictions to protect water supplies. Since it is common for water supplies for one community to be located in the jurisdiction of another, such action is much needed to be commended. However, the proposed rules inappropriately stop neighborliness at the state's borders. Classification of waters where the downstream users are out of state are to be downgraded so as to not interfere with development within North Carolina. [Public Information Packet, p. 5.1 Being good neighbors should apply as much to folks out of state as It does to those in adjacent watersheds within NC. Or have we determined that we don't need "foreigners" cooperation to protect any of our water supplies? .0104(n) Road Construction: The proposed rules take a step forward in requiring the Department of Transportation ( DOT) to follow best management practices. However, BMP's as developed by DOT in its "Water Supply Watershed Best Management Practices" document are, inadequate. They do not, for example, require such obvious practices as limitations on applications of pesticides, including herbicides, in regulated watersheds. Use of these chemicals, many of which are known water contaminants, is inconsistent with water supply watersheds. Regulation of fertilizers to prevent excessive nutrification from runoff is also needed. Construction of new or expanded roads and bridges in critical watersheds has important water quality consequences. The EMC should require an environmental review for all such construction in regulated watersheds as many, including ARC and the Triangle J Council of Oovernments (COO), recommended last year. The purpose such assessments is to ensure that all reasonable alternatives and consequences are considered and to allow a more informed public debate for the benefit of decision makers. .0104(s) Existing Development: The definition of "existing development" is too broad. It should not include all "projects with a recorded plat or areas zoned" by the date of these hearings.