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J4 ~QGhM¢r~ <br />4 <br />•~caR~: ~R. cFraR ~ ORANGE COUNTY BOARD OF COMMISSIONERS <br />~r.,-.acoe~ vicectwR POST OFFICE BOX 8181 <br />~LERiEP. FoUSIiEs <br />'~"' 200 SOUTH CAMERON STREET <br />hLKEN~N <br />HILLSBOROUGH, NORTH CAROLINA 27278 <br />June 28, 2007 <br />Dr. David H. Moreau, Chair <br />Environmental Management Commission <br />1617 Mail Service Center <br />Raleigh, NC 27699-1617 <br /><< <br />Re: Comments on the proposed Jordan Reservoir Wafer Supply Nutrient Rules, June <br />15, 2007 <br />Dear Dr. Moreau: <br />Thank you for the opportunity to provide comments on the proposed nutrient <br />management rules for Jordan Lake Reservoir. Orange County appreciates the work to <br />date by the Environmental Management Commission (EMC) and the North Carolina <br />Division of Water Quality (NCDWQ) staff to address the goal of reducing nutrients, and <br />is supportive of this goal. However, we do have some concerns about~the proposed <br />implementation method of non-point source reductions, especially in the Upper New <br />Hope Ann of the lake. <br />As you know, Orange County has a long history promoting proactive measures for <br />watershed protection. The County implemented watershed protection measures in its <br />1981 Land Use Plan and associated Zoning Ordinance and Subdivision Regulations, <br />and also implemented an Erosion Control Ordinance in 1975. Both of these actions were <br />firsts for counties in North Carolina at that time. In addition, the Erosion Control <br />ordinance mandates that an land disturbance in University Lake Watershed (later <br />extended to other watersheds) require a building permit approved by the Erosion Control <br />Division. <br />For the last 25 years, and beyond, County policy has consistently focused substantial <br />emphasis on watershed protection, retying primarily on land use and non-structural <br />measures to protect water quality. On-site infiltration of the first one-inch of stormwater <br />runoff, extensive stream buffers that exceed state minimums (measured from the edge <br />of fhe FEMA mapped floodplain, if present, and not the stream bank), and protection of <br />riparian buffer lands and floodplains are among some of the many watershed protection <br />techniques Orange County uses in this and other watersheds in our jurisdiction. The <br />reason for this long-standing policy is a fundamental belief that addressing water quality <br />protection at the source by limiting nutrient loading at the outset is preferable to relying <br />on structural controls after the fact. <br />www.co.oaANGE.NC.us <br />PROTECT/NG AND PRE56RV/NG -PEOPLE, R~SODRCES, QUALITY OF L/FE <br />ORANGE CO(/NTYj NORTH CAROL/NA -YOU CONNTI <br />(919) 245-2130 • FAX (9fe) 644-0246 <br />