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16 <br />TOWN OF CHAPEL HILL STAFF COMMENTS AND QUESTIONS REGARDING PROPOSED <br />JORDAN LAKE NUTRIENT STRATEGY RULES -SUBMITTED SEPTEMBER 13, 2007 <br />45A NCAC 026.0262: WATERSHED NUTRIENT REDUCTION GOALS <br />1_ Rule .0262(3) states reduction goals are in terms of a percentage reduction in delivered <br />nutrient loads to the lake. What transport factors were used, if any, to determine how <br />much of an individual site's nutrient load is delivered to the lake? Does this transport factor <br />apply to both percentage reductions (as for existing development- see §.0266(3)(a}) and <br />the unit-area mass loading rates (as for new development -see §.0265(3)(a)(i))? <br />2. Aerial deposition of nitrogen (from local and distant combustion sources) is a significant <br />contributor to nitrogen loads in area water bodies. Aerially-deposited nitrogen as a nutrient <br />source is addressed by the rules in §.0262(8) only as an acknowledged limitation, and <br />suggests the EMC could undertake separate rule-making in the future to support the <br />Jordan Rules. <br />Achieving success in reducing nitrogen loads to Jordan Lake may be highly dependent on <br />addressing aerial sources. Urban impervious surfaces such as sidewalks and roofs <br />typically do not produce nitrogen and phosphorus; they do co(lec~ dry particulates that get <br />washed off during precipitation events. <br />Addressing local combustion sources such as the heavy traffic in the Triangle and Triad <br />regions is certainly feasible and has a variety of human health and environmental benefits. <br />Emissions control has worked very well in the past for controlling lead pollution. Current <br />methods for emissions control also offer carbon-reduction benefits. Carbon reduction is a <br />stated goo[ of both the Chapel Hill Town Council and the University of North Carolina, and <br />will become increasingly adopted by other jurisdictions as our climate shows signs of <br />change. <br />!s it more cost-effective to be treating aerially-deposited nitrogen using stormwater <br />management rather than limiting its creation through combustion sources? Wouldn't it be <br />cheaper to control nitrogen at the source rather than try to treat it secondarily through <br />stormwater management? <br />3. Biosolids application is currently allowed in the Upper New Hope Arm subwatershed. <br />What is the estimated nutrient contribution from this application? Would it be considered a <br />fertilizer? Since biosolids application has the potential to be a significant nutrient source, it <br />needs to be regulated as part of the Jordan Rules, in spite of the fact that it's already <br />subject to existing regulatory and compliance programs. These existing programs were <br />not developed with the goal of watershed nutrient management. <br />4. There are no existing programs to control nutrient loads from onsite wastewater systems <br />(e.g. septic systems). Land uses with septic systems were considered to contribute a large <br />amount of nutrients in the Division of Water Quality's reckoning of nutrient allocations by <br />land use type. It is not clear if local governments have the authority to require regular <br />inspections and/or maintenance of onsite wastewater systems or must rely on the county <br />or state environmental health programs to enforce these provisions. <br />5. The Division of Water Quality held four stakeholder meetings to design an adaptive <br />management plan for the lake. The results of this plan would revise the lake model to <br />have more computational "cells" to better model in-lake processes. The plan would also <br />add new lake monitoring sites, and new watershed monitoring sites on small tributaries in <br />the Lower New Hope Arm and in the Haw Arm of the lake to better estimate nutrient <br />delivery loads. No new sites would be added in the Upper New Hope Arm (there are <br />Page 1 of 9 <br />