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4-7 <br />9/18/91 <br />COMMENTS RELATING TO WATERSHED RDLES ISSUS OR DEFINITIONS <br />1. DEFINITION OF "CRITICAL AREA" <br />The Planning Board feels that the best methodology to <br />determine the true geographic area critical to protecting <br />water supplies is the concept of stream "travel time" for <br />pollutants to reach water supplies. However, it is recognized <br />that detailed research must be completed to reasonably project <br />travel time. <br />Given this. the P <br />R €> .: >.; .. <K >€ e # zo oe usea as a <br />"de au,. . " "sta ew de m`*n mwa:`" t` sfio 3` ae noted that local <br />governments can adopt regulations that expand the critical <br />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 th nnfiffiffIRIM8926d. f����ecc�m��«: >�?:l::e��1:�' >`" <br />3. STORMWATER MANAGEMENT CONTROLS AND RESPONSIBILITIES <br />a�� a€ , allowing stormwater controls to be used only as <br />acc ed+ protection. The low - density method is the "preferred" <br />approach by the Environmental Management Commission, and the <br />Board commends the retention of this statement in the rules. <br />The Board further commends the requirement of local government <br />responsibility for stormwater control facilities (if they are <br />to be utilized) to ensure adequate monitoring and maintenance. <br />Added flexibility for civil penalties to be imposed by local <br />governments may be advisable. <br />4. NON- RESIDENTIAL DEVELOPMENT <br />also oppose any new interpretations of the rules to allow non- <br />residential development on an unrestricted basis in such <br />2 <br />