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10 <br />Orange Water and Sewer Authority <br />Jordan Lake Comments to NC Environmental Management Commission <br />July 10, 2007 <br />Page 2 of S <br />Jordan Lake to implementation of the Strategy and Rules remains highly uncertain. We urge the <br />Commission to adopt and implement rules that will accommodate the notable uncertainty that <br />continues to characterize most expert predictions of the lake's response. <br />Need for Flexibility and Adautive Managemeat <br />We urge the Commission to actively apply the principles of adaptive management, as provided <br />for in Rule .0262, Section (7) to help ensure that Jordan Lake water quality management <br />decisions aze based on the best and most up to date experience and information. It is essential <br />that the nutrient reduction goals and implementation schedule be re-visited at regular intervals <br />of not more than five years in order to fully apply new and additional data, including -water <br />quality trend analyses from Jordan Lake and its main tributaries, as well as the ongoing practical <br />experiences of local entities trying to reduce nutrient loads from many different point and <br />nonpoint sources. <br />An October 15, 2004 technical memorandum from the Modeling and TMDL Unit of DWQ's <br />Water Quality Branch reported a statistically significant trend of decreasing total nitrogen <br />concentrations of 0.17 mg/L per year in New Hope Creek, a principal tributary to the Upper <br />New Hope Arm of Jordan Lake. The analysis included 13+ years (January 1990 -March 2004) <br />of ambient water quality data that were statistically adjusted for seasonality and streamflow. <br />The report did not offer an interpretation or explanation of this significant improvement in water <br />ual~. Until this and other such existing trends can be identified and understood, it will be <br />extremely difficult, if not impossible, to evaluate the future effects - if any - of the Jordan Lake <br />nutrient management strategy and rules. The flexible and thoughtful application of adaptive <br />management practices will help ensure that well-informed decisions are made with the best <br />knowledge available. <br />Inadequate Standards and Criteria for Nutrient-Related Water Ouality Problems <br />We urge the Commission and DWQ to support and carry out as expeditiously as possible the <br />North Carolina Nutrient Criteria Implementation Plan, which has been approved by Region IV <br />of the United States Environmental Protection Agency (LTSEPA). This document provides an <br />important blueprint for overhauling the State's one-size-fits-all 40 ug/L chlorophyll a water <br />quality standazd, which is unnecessarily stringent for Jordan Lake's Upper New Hope Arm and <br />may provide little or no protection of the public water supply and recreational uses of the Lower <br />New Hope Arm. <br />OWASA's own University Lake and Cane Creek water supply reservoirs, whose drainage areas <br />may be the most stringently protected WS-II watersheds in North Carolina, periodically exceed <br />the chlorophyll g standard during the summer months, but few of our 80,000 drinking water <br />customers or low-impact recreational users would consider either of these lakes to be <br />"impaired." With no point source wastewater dischargers, mandatory large-lot (S+ acres) <br />residential zoning, agricultural operators complying with individual conservation plans, and <br />