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15 <br />Dr. David Moreau and Mr. Rich Gannon -Letter <br />September 13, 2007 <br />Page 2 <br />that a more thorough and multi-faceted assessment of all sources of nitrogen and phosphorus in <br />the Jordan Reservoir basin needs to be conducted, including not only the Division of Water <br />Quality but also the Division of Air Quality, the Division of Environmental Health, the Iivision <br />of Waste Management, and the Division of Land Resources. Since these divisions function <br />under the Environmental Management Commission and the Department of Environment and <br />Natural Resources, we believe this presents an excellent opportunity for cooperation between <br />and among the divisions to consider a number of different perspectives in creating a <br />comprehensive regional plan to manage nutrients in the watershed draining to the Jordan <br />Reservoir. This approach would be consistent with the three key aspects of pollution <br />management strategy -identify the sources, eliminate or reduce the sources as much as possible, <br />and then establish treatment as close to the sources as possible. <br />We believe that, although adaptive management. is encouraged as part of the Jordan Rules and <br />has been shown to encourage more effective and affordable changes in environmental practices, <br />much more information is necessary and better techniques and options must be made. available <br />such that local governments and state agencies can better target management tactics to nutrient <br />sources. We strongly recommend that the State ftuther study and evaluate all possible nutrient <br />management strategies and solutions; including a comprehensive evaluation of the role of the <br />Farrington Road {SR 1008) causeway, in the processes of lake circulation, nutrient cycling, and <br />algal population dynamics. <br />We are also concerned that the fiscal analysis significantly underestimates the costs for <br />implementing the prescribed nutrient management measures for both local governments and state <br />agencies. Given the potential costs,.we consider a thorough evaluation of alternative strategies <br />and solutions essential to good stewardship of taxpayers' money. <br />We appreciate this opportunity to comment on the proposed Nutrient Strategy Rules for B. <br />Everett Jordan Reservoir. We have attached our detailed comments and questions regarding the <br />proposed rules, and we look forward to the development and implementation of a practical, <br />effective, comprehensive, regional, multi-source nutrient management strategy that will <br />ultimately result in a cleaner, healthier B. Everett Jordan Reservoir. Please contact Ms. Sue <br />Burke, PE at 919-969-7266 if you have questions or require additional inforn~ation. . <br />oar L. ~tanctt <br />Town Manager <br />Attachment: Chapel Hill Town staff comments and questions regarding the proposed Nutrient <br />Strategy Rules for the B. Everett Jordan Reservoir <br />cc: Bruce Heflin, Assistant Town Manager <br />Ralph Karpinos, Town Attorney <br />George Small, PE, Engineering Director <br />Sue Burke, PE, Stormwater Management Engineer <br />Patricia D'Arconte, Stormwater Specialist <br />