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37 <br />COMMENTS RELATING TO WATERSHED RILES ISSUES OR DEFINITIONS <br />1. DEFINITION OF "CRITICAL AREA" <br />Staff feels that the best methodology to determine the true <br />geographic area critical to protecting water supplies is the <br />concept of stream "travel time" for pollutants to reach water <br />supplies. However, staff recognizes that detailed research <br />must be completed to reasonably project travel time. <br />Given this <br />`• ¢ XMR to ne usea as a "ctetau_.t� statewide <br />mnimum: shou'd`'be "noted that local governments can adopt <br />regulationd that expand the critical area, where warranted. <br />2. IMPERVIOUS SURFACE LIMITATIONS <br />The use of a sliding scale for impervious surfaces is a part <br />of the comprehensive water quality protection package for <br />University Lake watershed. It is not clear from the state <br />rules that such a sliding scale, based on lot size, would be <br />permitted. ��t;::;: ����7�dt��fi��> �����:'. �:' �1�:::: ?��r:�::a.l:����d::;�or;: »suc�i <br />3. STORMWATER MANAGEMENT CONTROLS AND RESPONSIBILITIES <br />`': <wa s.8, a.. lowing <br />V :; .. :..... <br />{ K.'{ i•.} i:: k.{ 4• C :•Mioi}.;%:tiv:::.;: •neve'tt,::r::' {'J\s..i:\Ri <br />sormwa er control`s to be used onlv'•as addeprotection. The <br />low- density method is the "preferred" approach by the <br />Environmental Management Commission, and staff commends the <br />retention of this statement in the rules. Staff further <br />commends the requirement of local government responsibility <br />for stormwater control facilities ( if they are to be utilized) <br />to ensure adequate monitoring and maintenance. Added <br />flexibility for civil penalties to be imposed by local <br />governments may be advisable. <br />4. NON- RESIDENTIAL DEVELOPMENT <br />.:�mFe?€a€a?aa zna� nave peen ana Will <br />con inue to be raised. Staff` would also oppose any new <br />interpretations of the rules to allow non - residential <br />development on an unrestricted basis in such watersheds. The <br />WS -4 category, which provides few limitations on non- <br />residential development, would seem more appropriate for this <br />sort of interpretation. <br />