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7 <br />c. There are also efficiency, cost and feasibility concerns regarding the splitting <br />of nitrogen reductions for non-point and point sources. Nutrient reductions <br />from non-point sources are more complicated and costly to obtain. <br />4. There is very little agriculture in the New Hope Creek basin. <br />a. While this portion of the County is rural, this will greatly limit the ability to <br />achieve percentage-based reductions for agriculture. <br />5. Existing development may have lower loading rates than new development. <br />a. The rules as proposed may- unintentionally require existing development to <br />have lower loading rates than new development. Under the proposed rules, <br />new development will have the option of paying aone-time offset fee in lieu of <br />reducing nutrient loading on-site. This. potentially means that new <br />development will have higher actual loading rates. <br />6. Burden of cost falls on local governments. <br />a. If the rules are implemented, local government will be asked to shoulder the <br />brunt of what may approach a $1 billion price tag for the nutrient strategy. <br />b. Since the water issues in Jordan Lake are not new in terms of real or <br />expected results, it would be critical to have State funding assistance to help <br />local govemments address these measures. <br />c. The cunent state of Jordan Lake water quality is markedly similar to <br />predictions made over 30 years ago by a variety of experts, and it is as much <br />a regional and statewide issue as a local issue. <br />7. Local govemments need added flexibility in meeting requirements. <br />a. More flexibility for local governments to participate in buy down opportunities <br />(with EEP) would help local govemments achieve the rules. <br />b. The proposed rules allow for a trading program. However, more time is <br />needed for the stakeholders to assess whether a trading program will be <br />feasible. While trading scenarios with partner jurisdictions appear to have <br />merit, the current targeted watershed study is not complete. <br />c. An emphasis on nutrient reduction trading, rather than in-lieu-of payments, <br />may be more effective. A trading ratio of 2:1 or greater may be needed to <br />ensure actual in-basin nutrient reduction. <br />