Agenda - 08-26-1991 - Laserfiche WebLink

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EMC WATERSHED COMMENTS Page 4 .0104(u) Forestry Activities: Forestry activities should be subject to the same type of requirements and equivalent buffers as other activities with the potential to threaten water supplies. They should not be permitted in WS -I and severely restricted in critical areas of other watersheds. Following the NC.Forest Practice Ouidelines, as the draft proposal would require, is a step forward and should provide substantial protection to water supplies and partially remove the forestry exemption from the state's sedimentation laws. We applaud the efforts of the NC Division of Forest Resources and the NC Forestry Association in cooperating to develop and implement the Forest Practice Ouidelines. It is important, however, to recognize their limitations. The standards only apply to tree harvesting not to other forestry operations, including land clearing and pesticide applications, and need substantial increased financial support for technical assistance, compliance monitoring, and enforcement. As with the case of agricultural operations, the new House Bill 124, which prohibited localities from regulating forestry activities more strictly than the state, clearly intended for the state to take sufficient action protect water supplies. The EMC should do so. ..0202( 14) Critical Areas: The rules should retain the one mile limit for defining critical areas. The EMC is to be commended for accepting one mile, instead of the original proposal for one -half mile, in the adopted rules. Any less would be inadequate. Engineering studies show that even 1 mile is not enough for some important watersheds. .0202(39) Protected Area: The existing S and 10 mile limits should be retained. Boundaries should follow ridge lines and natural watershed boundaries to the greatest extent possible. Substituting, "major landmarks such as highways or property lines" for natural boundaries should be the exception granted only after a clear demonstration of need. .021 1 { d){ 3)(B)(ii)(I I) BMP's in Critical Areas: The existing section with this designation, which prohibits engineered storm water controls in critical areas of WS -I I watersheds, should be retained. Intensive development, including cluster development, which requires structural BMP's is inappropriate in critical areas of WS -I i water supply watersheds. .0211 (d)(3)(13)(1XV) Maintenance of BMP's: Because operation and maintenance of engineered storm water controls is so important, and because the track record of private owners of such facilities is so poor, public inspection and maintenance of such BMP's are critical to protecting water supply watersheds from adverse effects of development. Public ownership would provide an even greater margin of safety. This section and similar ones for WS -111 & IV should be maintained and strengthened Alternative Community Sewage Systems: The performance record of community waste water treatment systems is so poor that they should not be allowed in water supply watersheds. The economics of such systems does not allow sufficient supervision and maintenance to achieve acceptable routine performance. The state, despite its best efforts, is unable to monitor and Inspect such systems often enough to ensure compliance -- inspections average only once in 5 years! The risk of failure poses too great a risk to public water supplies to be consistent with their use Community systems should be prohibited in WS -I I watersheds. Landfills: Landfills should not be allowed in WS -11 watersheds. They are not compatible with the needed level of protection of public health and safety. Sludge Applications: The use of sludge is inappropriate in high quality watersheds. Caution is required for the use of any sludge. Composition, quantity, and location of application sites are all critical to the appropriate use of sludge. Sludge applications should be prohibited in WS-1,11 & I I I watersheds. Controls on the composition, quantity and location should be required.