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4a3 9-1-07 Town Council comments to NCEMC <br />RCD determinations are performed by Town staff (al <br />subject to ordinance; USGS or Soil Survey maps are <br />Town's stream buffer protection provisions. <br />I State-certified); all parts of the stream are <br />not used to determine applicability of the <br />We expect that you will receive a comprehensive list of such provisions, in which adopting the <br />Jordan rules could give water bodies less protection than Chapel Hill now provides, from Town <br />staff. <br />These ordinances and their accompanying procedures were enacted after many hours of public <br />hearings, over a period of years, at both the Town Council and advisory board levels. Because of <br />Chapel Hill's long tradition of wanting full public participation in ordinance changes, we expect a <br />lengthy process will be needed to make the numerous changes which appear to be required by the <br />proposed rules. <br />We ask that DWQ staff, in evaluating what to bring to the EMC, include advice on how to allow <br />local governments whose requirements now exceed those in the rules to use their current tools to <br />achieve the commendable goals of the Nutrient Strategy. To do so, the proposed rules will have to <br />include a level of flexibility which they do not appear to contain as drafted. <br />Page 2 of 2 <br />http://townhall.townofchapelhill.org/agendas/2009/03/26/4/a/4a3-2007_sept_1 O~jordan_la... 3/25/2009 <br />