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56 <br />The "Middle Eno" sub -basin lies between <br />Lake Ben Johnson (intake point 103.0) and <br />Corporation Lake. This sub -basin includes <br />the proposed Seven -Mile Creek reservoir. <br />orange County recommends that this sub - <br />basin be classified WS -3 to reflect its <br />land use pattern. Future land uses in this <br />basin should not affect this sub - basin's <br />potential for meeting WS -3 standards. <br />For the "Lower Eno" basin (from Lake Ben <br />Johnson through Hillsborough into Durham, <br />Orange County recommends that the Eno <br />emergency intake in Durham be protected as <br />follows: <br />As a primary approach, the use of <br />vegetative stream buffers rather than any <br />watershed classification, is recommended <br />(as proposed by the Durham City - County <br />Planning Department. Failing this, <br />Orange County requests that the <br />Lower Eno Protected Area continue to <br />be classified WS -4 - applying to the 10- <br />mile "protected area" only. <br />Summary: Upper Eno: WS -2 <br />Middle Eno: WS -3 <br />Lower Eno: Buffers, or WS -4 <br />Finally, regarding the classification of watersheds, orange County <br />requests that completion of special watershed studies be used as <br />the primary criterion for determining whether other watersheds may <br />qualify for CRITICAL WATERSHED (CW) STATUS. <br />COMMENTS RELATING TO WATERSHED RULES ISSUES OR DEFINITIONS <br />I. DEFINITION OF "CRITICAL AREA" <br />orange County feels that the best methodology to determine the <br />true geographic area critical to protecting water supplies is <br />the concept of stream "travel time" for pollutants to reach <br />water supplies. However, it is recognized that detailed <br />research must be completed to reasonably project travel time. <br />Given this <br />� .• ro ne usea as a ,aeraulL, <br />: {�. , f ••'i#•;•;o.::4s ..}:. EiE3• s, Y)3:��s;:eo-x't4ax'a'�5.%Sr:;:✓ 3r�wY�:�'f�:F::f;:;;: 'suss; ^.•- :i,3s;:::::. <br />stat grange bo <br />_wide minimum. unty further applauds the <br />provisions in the rules that allows local governments to <br />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 />a <br />