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4a-9 <br />currently three at the "bottom" of the drainage area. Furthermore, the watershed model <br />which vuas used to model sources of nutrients in the three respecti~re watersheds was not <br />to be revised. currently, the ~ratershed model is of insufficient scale and precision for any <br />kind of targeted management practical, such as to allow local governments the ability to <br />trace and correct highly localised sources Qf nutrients or determine true land use nutrient <br />loading rates ~ratherthan using published sources, none of which era calibrated far our <br />soils and geology}. Devising the lake model alone would not contribute the kind of <br />information needed for adaptive management. <br />one possibility proposed by stakeholders prior to the first publication of the Rules in ~~~5 <br />was the removal of the Farrington Road ~~ ~ 40~} causeway that crosses the lake. The <br />.causeway turns the Upper New Hope Arm into a de facto stormwnter forebay for the Louver <br />New Hope Arr. The narrov~r opening of the causev~ay limits the flow of water out of the <br />Upper New Hope Arm, landing to a residence time of aver a year. This nearly stagnant <br />flow leads to increased sedimentation easily visible Pram the causeway but also attested <br />to by people canoeing up the tributaries}, increased tornperatures, and decreased <br />dissolved oxygen. These conditions are very favorable forthe proliferation of algae, <br />~. The need to revise the Inke model ~prirnarily, the cost to da so} wars one of two main <br />reasons given by ~v~{~ in early stakeholder meetings for not modeling lake processing for <br />the scenario where the Farrington Road causeway were to be removed and replaced with <br />a bridge. The other reason given was the supposition that allowing water from the Upper <br />New Hape Arm to r~ix vuith that of the Lower New Hape Arm would necessarily worsen the <br />water duality in the Lo~rer New Hope Arm. There are scientific reasons to believe, <br />however, that uwrere increased mining allowed the Upper Neva Hope Arne ono longer strongly <br />segr~ented from other areas} would experience in~praved nutrient processing without a <br />concomitant reduction in nutrient processing in the Lower New Hope Arm. The very <br />purpose of a revised lake model vuauld be to truly test the assumption that water quality <br />would worsen if the causeway were to be removed. <br />~ ~ NA O~By0~fi3: NUTRIENT I~ANAEMENT <br />1. The ten-acre threshold established in §.0263(3)(d) should be deleted. A!I contracted <br />nutrient applicators should be subject to these requirements. <br />2. Please provide a definition fflr "nutrient management consultants." (§.0263(3}(e)) <br />3. Nutrient management training or completing and implementing a nutrient managemen# <br />flan is insufficient to modify any behavior tending towards overapplication of fertilizers <br />{§.0263(4)). A statewide licensing and certification program is needed sa that persons <br />hiring an applicator can readily check that fihe applicator has been properly trained <br />~{§.0263(4){b)). <br />15A NCAC 02B.02fi4: AGRICULTURE <br />~. In ,g~64~7}, {`sufficient level of farm stewardship" appears to establish a standard far <br />compliance. Please provide a definition far this term. <br />15~ N~AC ~~8.0~~5: ~TORMwATER I~IANACEMENT FAR NEw DEVELOPMENT <br />Page ~ of 9 <br />