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Attachment 4 <br />Because the UDO has been amended since these comments were made, referenced sections may be slightly off as some portions of the UDO have been <br />renumbered. <br />14 <br />Implementation Bridge - Future Phase Suggestions Planning Staff Comment <br />42. <br />Need to update Lighting Standards. Height requirements for <br />outdoor light poles and potential impacts on County recreational <br />facilities is one of the areas that should be revisited. <br />This issue is being addressed in a UDO text amendment slated for <br />presentation at the November 2012 Quarterly Public Hearing. <br />43. <br />In the section concerning golf courses, Pollutant Monitoring <br />Program, I would suggest some thought be given to the locations <br />of the sampling stations for surface water, groundwater and <br />sediment. Perhaps the intent is to establish upgradient sampling <br />locations as well as sampling locations down-gradient of some <br />potentially contaminating source or specific location?? I think this <br />section needs a bit of discussion as to what the objective is. In <br />addition, under (3) Parameters for Sample Testing- I think that <br />some description of approved analytical methods and minimum <br />detection limits would be helpful. I am not familiar with the EPA <br />HAL thresholds described in this section but I would be willing to <br />look into this. There are various NC soil, water and groundwater <br />limits that may be worth considering for this section. [staff note: <br />this is in 5.7.3(G)] <br />There could be a policy or separate criteria governing locations. It should <br />not become part of the UDO. One main issue is that the criteria could <br />change from watershed to watershed, issue to issue. There really is no <br />universal governing standard. <br />44. <br />5(b) of this section- Management Response to Pollutant <br />Monitoring- I would recommend that the responsible party also be <br />required to contact appropriate state regulatory officials if <br />thresholds are exceeded, not just OC do so. I also recommend that <br />the phrase "for thresholds" be removed from this sentence -- <br />Section 5.5. [staff note: this is now Section 5.7.3(G)(5)(b)] <br />45. <br />Compare Durham’s ordinance requirements for environmental <br />review of subdivisions with Orange County’s environmental review <br />process. <br />72