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25 <br />July 5, 2007 <br />TOWN OF CARRBORO <br />NORTH CAROLINA <br />North Carolina Environmental Management Commission <br />c/o Rich Gannon or Jason Robinson <br />DENR-Division of Water Quality, Planning Section <br />1617 Mail Service Center, Raleigh, NC 27699-1617 <br />Dear members of the NC EMC, <br />Thank you very much for this opportunity to review and comment on the proposed nutrient <br />management strategy for the B. F. Jordan Reservoir. The Town appreciates the work of the <br />committee in seeking the protection and management of North Carolina's invaluable natural <br />resources. Comments on both the March 2007 draft rule and the Fiscal Analysis prepared by <br />the staffof the North Caroina Division of Water Quality are listed below. Representatives of <br />the Town will also be on hand to provide comments during the July 12 public hearing at the <br />Carrboro Century Center. <br />1. General -Section .0262 (6)(a) of the rules states that, "rules .0265, .0266, .0267, <br />.0268, and .0269 shall apply to all incorporated municipalities within the Jordan <br />watershed as identified by the Office of the Secretary of State." However, the rule <br />goes on to state that, "those municipalities shall include," and provides a list of <br />municipalities. The rule should be modified so that it does not include a list of any <br />municipalities; instead the phrase, "shall apply to all municipalities within the Jordan <br />watershed as identified by the Office of the Secretary of State," should control. <br />Newly incorporated municipalities within the Jordan Lake watershed, and <br />municipalities previously outside of the Jordan Lake watershed but that annex <br />property within the Jordan Lake watershed, must become subject to the rule. <br />2. General - Carrboro's long-standing commitment to watershed protection through land <br />use planning and development management strategies in the years prior to 2001 <br />makes it difficult to do more without raising the cost of living significantly or further <br />limiting new growth. This effect stands to undermine the regional commitment, as <br />defined in the Joint Planning Agreement between Orange County and the Towns of <br />Chapel Hill and Carrboro, of the maximization of urban services within a defined <br />boundary. Two current examples of the Town's commitment to watershed protection <br />include the Bolin Creek Watershed Restoration Team, and the Greenhouse Gas <br />Emissions Inventory and Reduction Planning Effort. <br />301 West Main Street, Carrboro, NC 27510 <br />AN EQUAL OPPORTUNITY EMPLOYER <br />