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17 <br />currently three at the °bottom" of the drainage area). Furthermore, the watershed model <br />which was used to model sources of nutrients in the three respective watersheds was not <br />to be revised. Currently, the watershed model is of insufficient scale and precision for any <br />kind of targeted management practices, such as to allow local governments the ability to <br />trace and correct highly localized sources of nutrients or determine true land use nutrient <br />loading rates (rather than using published sources, none of which are calibrated far our <br />soils and geology}. Revising the lake model alone would not contribute the kind of <br />information needed for adaptive management. <br />6. One possibility proposed by stakeholders prior to the first publication of the Rules in 2005 <br />was the removal of the Farrington Road (SR 1008) causeway #hat crosses the take. The <br />,causeway turns the Upper New Hope Arm into a de facto stormwater forebay for the Lower <br />New Hope Amy. The narrow opening of the causeway limits the flow of water out of the <br />Upper New Hope Arm, leading to a residence time of over a year. This nearly stagnant <br />flow leads to increased sedimentation (easily visible from the causeway but also attested <br />to by people canoeing up the tributaries), increased temperatures, and decreased <br />dissolved oxygen. These conditions are very favorable for the proliferation of algae. <br />7. The need to revise the lake model {primarily, the cost to do so) was one of two main <br />reasons given by DWQ in early stakeholder meetings for not modeling lake processing for <br />the scenario where the Farrington Road causeway were to be removed and replaced with <br />a bridge. The other reason given was the supposition that allowing water from the Upper <br />New Hope Arm to mix with that of the Lower New Hope Arm would necessarily worsen the . <br />water quality in the Lower New Hope Arm. There are scientific reasons to believe, <br />however, that were increased mixing allowed the Upper New Hope Arm (no longer strongly <br />segmented from other areas) would experience improved nutrient processing without a <br />concomitant reduction in nutrient processing in the Lower New Hope Arm. The very <br />purpose of a revised lake model would be to truly test the assumption that water quality <br />would worsen if the causeway were to be removed. <br />15A NCAC 028.0263: NUTRIENT MANAGEMENT <br />1. The ten-acre threshold established in §.0263(3)(d) should be deleted. All contracted <br />nutrient applicators should be subject to these requirements. <br />2. Please provide a definition for °nutrient management consultants." {§.0263(3)(e)) <br />3. Nutrient management training or completing and implementing a nutrient management <br />plan is insufficient to modify any behavior tending towards overapplication of fertilizers <br />(§.0263(4)). A statewide.licensing and certification .program is needed so that persons <br />hiring an applicator can readily check that the applicator has been properly trained <br />((§.0263(4}(b}). <br />15A NCAC 026.0264: AGRICULTURE <br />In §.0264(7), "sufficient level of farm stewardship" appears to establish a standard for <br />compliance. Please provide a defrnition for this term. <br />15A NCAC 026.0265: STORMWATER MANAGEMENT FOR NEW DEVELOPMENT <br />Page 2 of 9 <br />