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LIM.— . May 6, 2015 ORANGE WATER AND SEWER AUTHORITY A public, non-profit agency providing water, sewer and reclaimed water services to the Carrboro- Chapel Hill community. Chair Earl McKee Board of County Commissioners County of Orange Post Office Box 8181 Hillsborough, NC 27278 SUBJECT: OWASA Comments on Orange County's Draft Changes to the Unified Development Ordinance Regarding Impervious Surface Limits in Water Supply Watersheds Dear Chair McKee: Michael Harvey presented Orange County's draft changes to its unified development ordinance (UDO) to modify the impervious surface thresholds in water supply watersheds at the April 23, 2015 OWASA Board of Directors meeting. Thank you for the opportunity to comment on this consideration to amend the UDO. OWASA and its customers have long benefitted from the progressive watershed protection requirements implemented by Orange County and Carrboro in the University Lake and Cane Creek Reservoir watersheds. Those efforts have been guided by the technical evaluations and recommendations from local watershed management studies funded by OWASA. Orange County has planning and zoning control over about 90% of the University Lake and Cane Creek watersheds; therefore, the County's requirements will be a primary factor affecting the long -term quality of our community's existing drinking water supplies. We commend the County's protection standards for our two watersheds as set forth in the County's UDO, as we recognize those include some of the most restrictive development densities, riparian buffer requirements, and impervious surface limits in the State. They far exceed the State's minimum statewide watershed protection requirements established under North Carolina General Statute 143 -214.5 and the North Carolina Department of Environment and Natural Resources' (DENR) regulations at 15A NCAC 02B .0214. It is our understanding that the County's UDO allows landowners to exceed their impervious surface requirements through a variance process or by transferring allowable impervious surface requirements from a neighboring property through the establishment of a conservation easement. The County is proposing to add a third option to modify the impervious surface limits in response to citizen requests to allow modest increases in the allowable limits. As we understand it, this third potential process — if approved — would generally increase the allowable impervious surface limit for the University Lake and Cane Creek Reservoir watersheds from the current 6% limit to as much as 9 %, provided that the property owner: 400 Jones Ferry Road Equal Opportunity Employer Voice (919) 968 -4421 Carrboro, NC 27510 -2001 Printed on Recycled Paper uvuvuv.ou- asa.org