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26 <br />Comments on March 2007 Drag Rules -Jordan Reservoir <br />9/17/2007 <br />Page 2 of 5 <br />3. General - Carrboro's population of neazly 18,000 citizens occupies a municipal area <br />from which the tax revenue is 90 percent residential and 10 percent commercial. <br />Though the town has made a commitment to diversifying its tax base, a significant <br />alteration of the mix and associated revenue generation will take some time, and <br />could be severely limited by these rules. What happens if Carrboro finds that it <br />cannot achieve the required nutrient reductions through load reducing activities <br />without bankrupting the Town, either through budgeting that applies the bulk of town <br />resources to Jordan Rules implementation or the payment of fines due to its lack of <br />compliance? What will be acceptable time frames for implementing the local plan, <br />and how will the state ensure/support/work with the Town to yield the shared desired <br />outcome of water quality enhancement without financial ruin? <br />4. General -The Upper New Hope Arm of Jordan Lake has demonstrated water quality <br />characteristics lower than those of the remainder of the lake. It is the town's opinion <br />that this difference is substantially due to the configuration of the lake, particularly <br />the causeway that supports Farrington Road and the constriction of water flow that <br />occurs between the Upper New Hope Arm and the remainder of the lake. The Town <br />is interested in determining whether either of the following actions has been <br />considered as alternative measures to improve water quality in the lake. <br />a. Modeling removal of the causeway and its replacement with a structure <br />that would reduce the constriction on flow. While it is understood that the <br />enhanced flow that would occur under this option may not completely <br />restore chlorophyll A to desired levels, it is postulated that the levels <br />would be closer to state standards, therefore decreasing the required <br />nitrogen and phosphorous reductions to achievable levels. <br />b. Since it acts similarly to a forebay in a structural best management <br />practice, reclassification of the Upper New Hope Arm of the lake and <br />modification of its permitted uses, and/or revision of the applicable <br />chlorophyll A standard so that levels might not be as limiting. <br />5. General - In order for the application of the nutrient management requirements for <br />Jordan Lake to be fair and accurate, modeling of atmospheric nitrogen associated <br />with existing land uses and vehicle miles traveled, water quality degradation, and the <br />necessary nutrient management strategies must be part of the rule when it is adopted. <br />Funds need to be budgeted for these activities immediately, if this has not yet <br />occurred. The possibility of expending extensive resources -time and money - on <br />nutrient management that does not account for the atmospheric contribution of <br />nitrogen is wasteful and costly. <br />6. General -Are the nitrogen and phosphorous loading rate targets technically feasible <br />in association with dense development activities? Carrboro officials have expressed <br />grave concerns that loading rate targets may present such an insurmountable obstacle <br />so as to render areas of the Town's jurisdiction undevelopable. The Town's existing <br />stormwater regulations have been identified as discouraging development and <br />redevelopment. Additional regulations run the risk of further discouraging <br />redevelopment and any associated water quality improvements that would be <br />achieved through such redevelopment's compliance with existing Town regulations, <br />or future versions which go further toward addressing Jordan's nutrient issues. <br />301 West Main Street, Carrboro, NC 27510 <br />AN EQUAL OPPORTUNITY EMPLOYER <br />