Orange County NC Website
Browse       Search
27 <br />Comments on March 2007 Drag Rules - Jordaa Reservoir <br />9/I7/2007 <br />Page 3 of 5 <br />7. Agriculture -The relationship between the purpose in Section .0262 (1) and the <br />standard BMPs to be implemented in Section .0264 (7) is unclear. This is especially <br />true in consideration of the statement that, "implementation may have occurred at any <br />time before, during, or after the baseline period." It would seem that the probability <br />of reducing nutrients from agriculture sufficiently to achieve the nonpoint source <br />nutrient targets under this rule is small. This undermines the nonpoint source nutrient <br />reduction strategy as a whole. Furthermore, agricultural sources generate nitrogen <br />credits by implementing any BMP in addition to the list provided in Section .0264 <br />(7)(a). By providing a threshold to generate nitrogen credits that bears no relationship <br />to the nutrient reduction targets, agricultural sources may be generating spurious <br />credits, further reducing the effectiveness of the nonpoint source nutrient reduction <br />strategy. Agricultural uses should have to meet changes related to the 2001 baseline <br />as is proposed for all other uses. Otherwise, the rules should be modified to allow <br />any other uses whose actions prior to 2001 can be shown to have water quality <br />benefits to receive credit for those actions. <br />8. Fiscal Impacts -The estimated costs, as high as they are already, still appear to <br />grossly underestimate the full cost of implementing the rule as written. <br />a. Direct costs which are not yet fully noted appear to include monitoring <br />and enforcement activities both to the local government and citizens, and <br />prospective developers. In and of themselves, these costs are expected to <br />significantly exceed the estimates provided. Additional costs are <br />expected, but will not be known until the Town prepares its program and <br />determines what types of actions will be needed to achieve the required <br />nutrient reductions from existing development. <br />b. Indirect costs may be of a larger magnitude and include lost tax revenue, <br />gross receipts and other funds associated with land taken out of the private <br />supply to install best management practices towards achieving the nutrient <br />reductions for existing development, and land development and building <br />that does not occur because interested developers choose to locate <br />elsewhere where requirements are less stringent and lower densities <br />encourage more vehicle miles traveled. <br />c. Environmental costs associated with sprawling land use that is <br />encouraged, particularly in less developed portions of the Jordan Lake <br />watershed. Such costs will include at a minimum, water quality impacts <br />from riparian buffer and surface water alteration and removal and <br />insufficient replacement, continued and expanded air quality impacts (e.g. <br />atmospheric nitrogen) from increased vehicle miles traveled, reductions in <br />land available for agriculture, forests, open space, and wildlife. Fracturing <br />the forests for low-intensity Land uses is known to result in significant <br />reductions in biological diversity of plants and animals. <br />d. Administrative costs associated with tracking the compliance of local <br />governments with the rule. Who will pay for this data collection, <br />monitoring, tracking, plan review, etcetera? The stated assumption that <br />the DWQ can absorb these costs into an already overbooked and <br />understaffed agency seems exceedingly optimistic. At a minimum, <br />coordination of this effort would seem to require the installation of <br />301 West Main Street, Carrboro, NC 27510 <br />AN EQUAL OPPORTUNITY EMPLOYER <br />