Orange County NC Website
4a-12 <br />light of any transport factors not explicitly stated in the rules. wCll a draft version of this tool <br />be available early enough far Iccal governr~erit to use in their calculations and studies? <br />5. According to Rule .g~G~~3}~a}iii} the feasibility study shall propose an implementation ra#e <br />and schedule for load reducing activities. Mule F~~~9 also allows a jurisdictian tv buy <br />nutrient credits to meet Cts land reduction requirements, However, there are no <br />benchmarks for progress or a suggested tir~eline far mee#ing land roductian requirements. <br />Hove are proposed implementation rates ar~d schedules judged to be adequate? If a <br />feasibility study indicates that load reducing activities and projects are insufficient to meet <br />reduction goals across the jurisdictian, i the jurisdiction then required to buy nutrient <br />credits to meet its goals? <br />~. vUhat exactly constitutes "retrofitting}, as referred to in ~,O~G~~3}~a~~iv}? Gne assumes it <br />includes installation of new B[UIPs in existing developments. According to DvU~ staff, <br />MPs existing during the baseline period cannot be counted towards nutrient land <br />roductian. However, could improvement o~ modification of existing BIUIP to treat nutrients <br />or increase treatment be considered far credit? Could repair of brakenlpoorly~functioning <br />BAP to restore nutrient treatment ca_pacit~ be considered far credit? Given the potent~a4 <br />far these activities to improve nutrient management can repairer improvement of these <br />existing BMPs be used for full ar even partial nutrient credit? <br />?. vllhen starmwater infrastructure is shared or crasser boundaries between local <br />jurisdictions, which entity bears the responsibility for nutrient roductian? Local <br />governments, such as fawns and counties, are encouraged to work with each other to <br />jointly meet loading targets in .0~~~~~~{a}~v~~, which Boas allow a method to address such <br />shared infrastructure, imilar4y, NCD~T-maintained roads and LNG properties are <br />scattered throughout Chapel Hi[['s jurisdictian such that the starmwater infrastructure of <br />these three entities is highly interconnected. However, there is no clear guidance in these <br />rules on responsibilities for nutrient reduction when starmwater infrastructure is shared <br />between local governments and state agencies. while it would probably be highly <br />beneficial and reduce inefficiency, it is similarly unclear whether NCDC~T or UIVC is allowed <br />to enter into joint nutrient management agreementswith local governments. <br />S. Aacarding to discussions with D1~11~ staff and based an similar calculations far the Neuse <br />and Tar-Pamlico, inta[lation of a new starmwater BLIP upstream of an existing BI~P being <br />used for nutrient reduction has the potential to lower the nutrient removal credit far the <br />downstream BI~P ~thraugh the "BIUIPs in series" calculations}. 1llfhat is the minir~um <br />separation distance between Blv[Ps in ord er to be considered separate? Or ere nutrient <br />treatrr~ent loads for BlU[Ps in series, even if separated, calculated only using the drainage <br />area flowing tather~ that doesn't already pass through a BMP? This is likely to bean <br />extraordinarily complex calcuiatian of BI~P nutrient removal. Haw is treatment capacity . <br />managed under this scenario? <br />~ 5A NC~IC ~~B.~~~~: PR~TE~TIGN ~F EITIN R[PARIAN BUFFER <br />~ . In ~a~G~l~9}, Table of Uses,llegetation Maintenance includes the removaC of understory <br />nuisance vegetation as defined in `Exotic Plant Guidelines," by Cherri L. smith, Dept. of <br />Environment and Natural Resources, Division of Parks and recreation. Raleigh, NC. This <br />reference does not provide a definition of "understary nuisance vegetation." Please <br />provide a definition or change to "invasive exotic species," which is defined in the cited <br />reference. <br />Page ~ of ~ <br />