Orange County NC Website
Ufti t iFT <br />And maintain erosion control devices annually, etc. <br />"Silviculture activities are required to implement the provisions of the Forest Practices Guidelines Related <br />to Water Quality." <br />The proposed rules require agricultural activities to comply with existing federal laws. In addition, in <br />critical areas, agricultural activities would need to have a 10 -foot vegetated buffer along all perennial <br />waters; and animal operations, greater than 100 animals, must employ BMP's recommended by the Soil <br />and Water Conservation Commission. <br />1. The State and local governments do not have adequate staff to enforce current sedimentation and erosion control <br />laws; these rules add new requirements without adding new staff, <br />2. An Agricultural Extension Agent told Triangle I that these rules would be difficult for small dairy famiers who <br />would need to build ferues to provide buffers for the streams and to Guild new watering source-; for their livestock. <br />RECOMMENDATION <br />Though these sections may need revisions to make them more work=able, Triangle j believes that the <br />1.MC has taken steps in the right direction by addressing pollution from agriculture, silviculture, <br />and transportation activities - significant contributors to runoff pollution, <br />(4) Discharges & Stormwater <br />The proposed rule states that in areas where some category of a new wastewater discharge is prohibited <br />(such as domestic discharges), expansions of existing discharges of that category will be allowed if there <br />Js no increase in the pollutant loading.. <br />The wastewater discharge approach adds flexibility, at the same time providing for no net loss of water <br />quality protection. <br />1. Federal regulations require state and local governments to begin tradting stormwater as a discharge, requiring <br />'a permit for storrnwater running off a particular Fite. The proposed rules, however, do not provide the same <br />lcxibility forstormwater "discharges " as they do for other discharges. <br />2. The requirement for wet detention ponds controlling the first 1 " of runoff may preclude other runoff control <br />measures that, far a given site, may provide equal or more zuater duality protection. <br />RECOMMENDATION <br />Apply the performance- based approach to all discharges, including stormwater. <br />Revise the rules as follows., <br />b211(e)(3)(i)IV; 0211(e)(3)(101I1; 0211(f)(3)(i)IV; &. 0211(f)(3)(WIll <br />J <br />Add; control runoff front the first Inch of rainfall QLpLrQyjdF, Cg nt Wat 12rottction <br />ULYUAUW _ <br />measures thrmh ureservatlon oL na a aj 9 =Sjwalga,, construe f w . g� <br />