Agenda - 03-26-2009 - 4a1 - Laserfiche WebLink

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4a-3 comments ~n ~~~ ~~~7 L~ra~ ~~s ~ ,~4r~~n ~~s~rvoir F~~~ ~ a~ 5 9~1712~~7 7~ g~cultu~re - The relatian~hip hetvvee~ the puxpoe in section .~~~ ~~~ and the standard Fs to ~~ innplemented ~ Section .~~~~ ' is unclear* "his is especially true ~ consideration, ~ ~ statement that, "in~piern~~.tinn may have occurred at any tune before during, or aver the baseline perEad." Yt Wu~ld seam that e prol~abilxty of reduoig nutrients from ag~oule suciently to achieve the nonpoint source nutrient targets under this ru.Ie is small. This under~es the nonpoint source nutrient reduction stt`ateg~ as a Whole. ,urthernnore, agricultural sources generate ni~roge~ credits h iruple~nenting and BAP iu addition to the fist provided . Section ~~~~ ~7~~a}. ~ providing a tbresh~id tc generate ni~ragen e~edits that ~e~rs na reiatianship to the nutrient reduct~.on targets, agrtcu.ltural sources mad be generating spurious cxedi~ a~u~her reducia~g the effectiveness ~~~ e nonpot source ~ut~e~at reductic~ strategy. ~ign`xeultural uses should have to meet cha~ag~s related to the ~~~~ baseline as is proposed far all other uses. ~theise, the moles should be nnodi~ed to allav~ any athex uses vcrhose actions prior to ~~ ~ can be shoes to have grater ~uali ~3~~~f1ts t~ ~'eCe~ve ~r~~lt for those ~.~t10n5. 8~ ~`iscal impacts ~-The estin~a~ted costs, ~.s hx~h as they are a~ready# still appear to grossl~r under~sti~nate the full cast of irnple~ne~ting the rule as mitten. a. direct casts which are not yet fully noted appear to include monitorg and enforcenr~ent activities both to the local gQvemeut and citizens, and prospective de~relopers. Zn and oftberr~selves, these casts are expected to sign~cantiy exceed the esthnates provided..dditianal costs are expected, but will got be la~rn until the'ro~vn prepares its pregram and deter~es what types of actions gill be needed tv achieve the requited nutrient reductions fronn e.isting development. h. direct cosh may be of a lamer naaguitude and .elude icst ~ reve~,ue, gross receipts and other funds associated with land taken out ofthe p~.vate supply to ~.stalx hest mar~agennent practices to~rards achieving the nutrient reductions for estg deveiopruer~t, aid ia~ develaprnent and b~.ilding that does riot occur because interested developers choose to locate ~isewhere where requirements are less stringent and lager densities encohrage mere vehicle miles travel. c. l~~vixo~ental casts associated Wig spravrling land use that is encouraged, par~icularl~ in less developed por~ioaas of the Jordan f,al~e watershed, Such cQSts rvil~ ~clude at ~. m~mumy water q~ali impacts frame riparzan. buffer and swr~`ace v~ater alteration and ren~o~ral and insuf ~cieut replacement, continued and expanded air quality i~~acts ~e,g. atmospheric ni~rogen~ £ram increased vehicle miles ~aveted, reductions in land available far ag~.culture, forests, open space, and wildlife. fracturing the forests far lav~~i~tensity land uses is Dawn to result in signi£~cant reductions in biological diversity ofpl~.nt and anirnalsF ... d. .~.inistrative casts associated v~i~ tracl~~g the compliance of local gove.~ane~.ts With the rule. '~,v will pay for thls data collectio.u, rnanitaring, tracl~n, plan review, et cetera The stated assumption that the ~'~ can a~hsorb these costs into aaa already' overbaal~ed and undersed ageucy seems eccedingl~r apti,~sc~ t a inimum~ caurdination ofthis effort ~rould seem to require dne ~stallation of 3~~ V1Jest ~~ir~ 5t~eet, Carrboro~ NC ~7~9~ AN E~IJAL OPP~R~'~Nf~Y E~[PL~Y~R