Note: recommended changes to specific passages are in bold italics
02.1: Second sentence: ….An APOD shall be designated only after geo-technical and/or hydrological study determines the area is a recharge area for an existing or proposed groundwater supply wells.
Comment: Does the term “land disturbance” include plowing/row cropping?
04.0 Designation of APOD
04.1 An APOD, as designated herein, includes those areas that require water resource protection in order to protect aquifer recharge areas associated with existing or proposed groundwater supply wells.
04.2 The boundaries of an APOD shall be based upon….. “and/or hydrogeologic data and analysis completed by a groundwater hydrologist, in conjunction with staff, who by education, training, and experience, is qualified in such regard”.
05.0 Uses Prohibited Within APODS
05.1 a: Does this include agriculturally applied sludge?
05.1 c: Is this written to exclude conventional drainfields?
05.1 e: Does this include existing gasoline stations?
05.1 g: Should retail only be ok?
05.1 k: What about home heating oil USTs?
05.1 n: This line item appears to be in need of completion-it seems like more of a “note” to oneself “not to forget”. Additionally, “large” in large volumes probably should be defined.
Section 06.0 Uses Allowed Within APODS, Subject to
06.1 d: It might be helpful to define “impervious”.
The intro talks
about preventing uses that lead to “depletion” of aquifers/recharge.
Staff may want to consider guidelines related to impervious
surfaces and land disturbances too,
such as clearing/disturbance of forests, since they play a major role in
infiltration and recharge.
07.1 g: Storage
containment requirement is only really practical for above ground storage
tanks (ASTs). Staff may want
to consider language requiring stringent underground storage (UST)
protection; possibly more stringent than the state regulations.