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10 <br />It has been extremely frustrating for local governments to consider the water quality implications <br />of various watershed management measures without defined water quality objectives. Under <br />these circumstances, evaluating the relative effectiveness of alternative measures becomes little <br />more than making value judgements. For example, the City of Durham and Durham County do <br />not believe that sufficient technical basis has been established to justify a five mile Protected Area <br />around WS -IV water supply reservoirs. EMC - established water quality objectives would offer <br />local governments the ability to develop and evaluate a different mix of watershed management <br />tools that could provide the same level of protection with a minimum amount of local disruption. <br />3. The City of Durham and Durham County encourage the Environmental Management <br />Commission to allow and encourage watershed management studies for specific water supply <br />watersheds, performed in consultation with and with the approval of the Environmental <br />Management Commission,. to become the basis for alternate watershed management <br />regulations applicable to that watershed. <br />Given the absence of State resources to perform individualized water supply watershed <br />management studies, the Environmental Management Commission should provide a mechanism <br />for local governments, with EMC approval, to perform such studies. A watershed management <br />study, using EMC - established water quality objectives, would identify an individualized program <br />of watershed management techniques that takes into account local situations, needs and resources. <br />The EMC could then use the watershed management study as the basis for alternate regulations. <br />This approach allows the watershed .management program to recognize a) the tradeoffs between <br />point source and non point source pollution control, b) the benefits to downstream water supplies <br />of upstream watershed protection, c) the extended detention time in large reservoirs and d) other <br />unique aspects of specific watershed and reservoirs. <br />4. The City of Durham and Durham County encourage the Environmental Management <br />Commission to change the definition of "existing development" to exclude zoned land and <br />to be compatible with the recently adopted vested rights legislation. <br />S. The City of Durham and Durham County encourage the Environmental Management <br />Commission to ensure that the requirements for stormwater management in the water <br />supply watershed protection rules be compatible with new EPA requirements for stormwater <br />controls. <br />6. The City of Durham and Durham County. encourage the Environmental Management <br />Commission to modify the proposed rules (referring to Subsection .0104(t)) to delete the <br />provision that the rules will become effective at the end of the reclassification comment <br />period (October 31, 1991). <br />As written;. the proposed rule makes new development activities in regulated watersheds subject <br />to the proposed rules many months before the rules are adopted by the EMC acrd before local <br />governments are required to have in place watershed protection regulations. Further, the rules <br />suggest that if local governments approve developments after October 31, 1991 that are not in <br />compliance with rules that the EMC may subsequently adopt, other developments in the <br />watershed must be further restricted in order to compensate for the non - compliance. This <br />provision seems contrary to the intent of House Bill 156, which clearly provides local <br />Governments time to put the new rules into effect. <br />2 <br />