19970722 Ver 1_More Info Received_19980228

t
Page 1
Note for Boyd DeVane
From: Bradley Bennett
Date: Mon, Feb 23, 1998 6:06 PM
Subject: Randleman
To: Boyd DeVane
Cc: Coleen Sullins; Don Safrit
Boyd,
First of all, let me go ahead and admit that I haven't reviewed the plan like I probably should
have, so my comments are fairly general.
• A lot of the areas in the upper reaches of the watershed currently have water supply
programs that include extensive stormwater requirements. On paper these programs are, in
some cases, more stringent than the state minimums. You should talk with Lisa about how
they are being implmented.
• They indicate that they "assume" a few of the local governments will adopt ws ordinances
that expand their coverage to the Randleman watershed area. They should have a
committment.
• Should be pointed out that the WS requirements are not designed for nutrient control.
They have included some other measures like public education. It may be appropriate to ask
them to consider the urban components from the Neuse rules. This would require changes to
their buffer requirements to protect existing riparian buffers vs. the vegetative buffers the WS
rules allow and may also increase the buffer widths in some areas. They should also
consider illicit connections programs, nutrient management plans, etc.
• The draft includes estimates of load reductions from the proposed mesures, but does not
give details on how the numbers were developed. What efficiencies were used'? Where did
these numbers come from? % reduction numbers - is this reduction from existing conditions
or from buildout without any BMPs. It looks like it is based on builout without BMPs.
• Regional BMPs. They have an instream pond (the 5th one) propsed for completion in
summer of 1998. According to their numbers, it drains 9,800 acres. Under our guidance for
instream ponds, they need to get approval from us for this one. They would have to do
modelling studies of the instream wq levels and provide upstream onsite BMPs for some
levels of development, etc.
• They state, on page 3-18, that the state minimum requirements are control of the first inch
of rainfall. The minimums actually require design for 85% TSS removal AND control of the
first inch.