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14 <br />,~pW N OF <br />-' `'i <br />OtiA p E t N~~~ <br />September 13, 2007 <br />Dr. David H. Moreau, Chair <br />North Carolina Environmental Management Commission <br />1617 Mail Service Center <br />Raleigh, NC 27699-1617 <br />Mr. Rich Gannon <br />DENR-Division of Water Quality, Planning Section <br />1617 Mail Service Center <br />Raleigh, -NC 27699-1617 <br />OFFICE OF THE MANAGER <br />405 Martin Lathes King, Jr. Blvd <br />Chapel Hill, NC 275I4-5705 <br />Telephone (919) 968-2743 <br />Fez (919) 969-2063 <br />www.townofchapelh171. org <br />RE: TOWN OF CHAPEL HILL STAFF COMMENTS ON THE PROPOSED NUTRIENT STRATEGY <br />RULES FOR THE B. EvERETT JORDANRESERVOIR <br />Dear Dr. Moreau and Mr. Gannon: <br />Enclosed are comments from the Town of Chapel Hi11 staff regarding the proposed Nutrient <br />Management Strategy Rules ("Jordan Rules' for the B. Everett Jordan Reservoir. Our <br />comments and questions involve elements of the Jordan Rules that require further <br />clarification/explanation, requirements in the Jordan Rules that are contradictory and/or will <br />impair the ability of local governments to achieve reasonable compliance, and issues that need <br />further consideration and study to assure that the most practical and effective approaches are <br />implemented to reduce nutrient levels and algal blooms in the Reservoir. <br />We strongly support the over-arching goals of improving the water quality of the B. Everett <br />Jordan Reservoir and improving the health of the streams flowing to the reservoir. The Town of <br />Chapel Hill has been a leader among local governments in supporting the goals of water quality <br />protection as demonstrated through implementation of a number of environmental protection <br />initiatives over the past quarter century. During this time, the Town Council and staff have <br />created and refined local development ordinances that reflect current scientific understanding of <br />environmental processes, the latest engineering practices, and the importance of environmental <br />quality and protection as emphasized in the Town's Comprehensive Plan. We have involved the <br />public at all levels of this process, from holding public hearings and receiving public comment, <br />to soliciting review and comment by Town Boards and Commissions. <br />We are concerned, however, that the Town's established and continuing pro-active <br />environmental protection efforts have not been acknowledged in the process of devising methods <br />for managing water quality in Jordan Reservoir. This is especially evident in the selection of the <br />baseline(s) proposed for measuring compliance with the rules, since the Town's initiatives prior <br />to implementation of the rules would receive no credit. <br />We believe that the control of nutrients solely through the management of stormwaxer runoff and <br />point source discharges will fail to significantly improve the Reservoir's water quality. We think <br />