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MEMORANDUM <br />To: Orange County Board of County Commissioners <br />Orange County Planning Board <br />From: Orange County Commission for the Environment <br />Date: June 5, 2015 <br />Subject: Proposed amendments to Orange County's impervious surface rules <br />The Commission for the Environment (CFE) has considered the draft amendments to Orange <br />County's impervious surface limitations for development in water supply watersheds. <br />Michael Harvey and Craig Benedict provided an excellent overview of the proposed revisions <br />to the Unified Development Ordinance at the CFE's May 11 meeting, and we thank you for <br />the opportunity to provide comments. <br />Although the amendment is not intended or expected to increase runoff from developed <br />properties, whether it be pervious or impervious, it is the finding of the CFE that the <br />cumulative effects from a larger developed portion of the watershed could have adverse <br />environmental impacts. If only a handful of landowners chose to pursue this option then the <br />effects would be minimal. However, with widespread use there could be an incremental loss <br />of wildlife habitat and a decrease in carbon sequestration as a result of the loss of wooded <br />areas. And although the volume or quantity of storm water runoff may not increase as a result <br />of the proposed changes, the quality of water leaving a site could worsen. <br />The CFE does not object to the proposed amendment, but the CFE cannot endorse a rule <br />change that lessens protection of the natural environment. If the County adopts the proposed <br />amendment and allows for the installation of infiltration BMPs to offset additional impervious <br />area, then the CFE would agree with the proposed requirements for engineered designs, <br />recorded maintenance agreements, annual inspections, and a viable enforcement mechanism. <br />The County should also consider requiring a performance bond and the renewal of the permit <br />after some reasonable period of time. <br />Again, the CFE appreciates the opportunity to comment on this proposed change to the <br />Unified Development Ordinance. <br />Copies: Bonnie Haminersley, County Manager <br />David Stancil, Environment, Agriculture, Parks and Recreation Director <br />