Agenda - 10-07-1991 - Laserfiche WebLink

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19 AGRICULTURAL RESOURCES CENTER 'RESTicide Mucation project 15 West Main Street Carrbara, North Carolina 21, S i O, 919/967 -1886 COMMENTS TO THE NORTH CAROLINA ENYIRONMENTAL MANAGEMENT COMMISSION ON PROPOSED AMENDMENTS TO RULES FOR SURFACE WATER SUPPLY WATERSHEDS August 19, 1991 Please accept these comments by Alen Spalt, Director of the Agricultural Resources Center (ARC) and its PEST icide EDucstion project (PESTed), a private, non - profit public interest organization with offices in Carrboro and Raleigh which is particularly interested in the effects of agriculture on water quality. These comments are made on behalf of ARC /PESTed and Protect Our Water ( POW), citizens of Carrboro and Orange County concerned about watershed protection. Thank you for the opportunity to comment to the Environmental Management Commission ( EMC) on proposed amendments to rules for surface water supply watersheds [ I SA NCAC 28.0101, .0101,.0202,.02 1 1, &.03011 under House Bill 156 [GS 193- 219.5 -6). It is ayear since we testified in support of strong watershed protection standards before this commission. We were pleased that the EMC adopted rules in December, 1990 to carry out the mandate of 1-113-156 which offered significant protection to the state's surface water supplies. The EMC is to be commended for those rules. They are not overly burdensome and deserve a chance to operate. We are dismayed, however, that we must come back so soon asking you to maintain the rules which are now threatened by short - sighted pressure from special interest groups. The current rules are not perfect, but they are better in almost every respect than the proposed modifications. If anything, the rules should be strengthened, not relaxed. General Comment: The Division of Environmental Management's (DEM's) Public Information Package asked for comments, "on areas you would like to see remain the same or become more stringent as well as those that you feel should become more flexible." [p.3) P lease consider these comments a request for all areas not specifically addressed below "to stay the same or become more stringent." We do not oppose "flexibility "in principle, but we do oppose it where it is used as a euphemism for weakening need levels of protection. Specific Comments: The following comments are on specific changes as proposed: .0101 (c) Freshwater Classifications: We support the use of four classifications for freshwater water supply watersheds with a gradation of levels of protection ranging from WS- 1, for natural and undeveloped watersheds, to WS- IV, for generally moderately to highly developed ones. We reject totally the view that WS -II & I I I are unnecessary and /or too burdensome. It is completely appropriate for the EMC to adopt a hierarchical system with various levels of protection depending on the nature of the watershed, including its present level of development.