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21 <br />2. In §.0267(9), Table of Uses, `wildlife passage" is considered an Allowable Use in the <br />riparian buffer only if a determination of no practical altematives is made. `Wildlife <br />passage" is not defined in §.0267(2). If `wildlife passage" is the maintenance of a forested <br />or other natural corridor connecting natural areas {as the term is used in conservation <br />biology), why is it considered a land use impacting the riparian buffer to the extent that a <br />determination of no practical alternatives is necessary'? <br />15A NCAC 026.0268: MITIGATION FOR RIPARIAN BUFFERS <br />No comments. <br />15A NCAC 026.0269: OPTIONS FOR OFFSETTING NUTRIENT LOADS <br />No comments. <br />15A NCAC 028.0270: WASTEWATER DISCHARGE REQUIREMENTS <br />No comments. <br />15A NCAC 026.0271: STORMWATER REQUIREMENTS FOR STATE AND FEDERAL <br />ENTITIES ' <br />The requirements and schedule for the state and federal agencies need to be identical to those <br />for local govemment. The state agency implementation schedule appears to lag local <br />govemment by 18 months. Further, comparable requirements to those contained in <br />§.0266(3)(o-e) for local governments appear to be missing for non-DOT agencies. <br />15A NCAC 026.0272: RIPARIAN BUFFER MITGATION FEES <br />No comments. <br />15A NCAC 026.0311: CAPE FEAR RIVER BASIN <br />No comments. <br />FISCAL ANALYSIS <br />1. The Fiscal Analysis includes no new costs to the Division to implement these rules (pg. <br />xviii), which is not realistic. <br />2. To avoid complexity, cost calculations were carried out at the scale of the entire watershed <br />(pg. xx). This likely greatly overestimates costs for those in the Lower New Hope Arm <br />subwatershed, somewhat overestimates costs for the Haw Arm, and underestimates costs <br />for those in the Upper New Hope Arm. This is attributable to the significantly greater <br />amount of nutrient reduction that must be achieved in the Upper New Hope Arm. The <br />Fiscal Analysis needs to provide more realistic cost analyses for the separate <br />subwatersheds. Further, the estimated costs for each local government should be <br />identified. <br />3. At the Carrboro public hearing, some Haw dischargers asserted that they will be required <br />to remove closer to 20% in order to meet the 8% nitrogen reduction at the lake because of <br />Page 6 of 9 <br />