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~}~'aan~e~f 2 <br />4a-28 <br />~~~ <br />4 <br />•/~w ~~..Ijw~lir~ ~+,l~il"'L[~ ~i~1~~1.~~~y C~MM~~ ~\~/i ~D ~~ C~~~~F~~~r/N w~~.~ <br />~~F~~~ou~ c~uR Pt~ST C7F`~IC~ BMX 8 ~ ~ <br />AucFM. Got~voN boo ~C]U'~H C~~~4C~l~I~T'R~E"r <br />MI~NEr soN <br />~ir~~Ba~~~~H, No~~r C~oc~n~. ~7~78 <br />June 28, 2007 <br />ar. David H. Moreau, Chair <br />Environmental Management Commission <br />~ fi 7 Mail Service Center <br />Raleigh, NC ~7fi99- ~ ?' <br />~ 4 <br />\~J ~8t~~ <br />Re: Com" menu on the proposed Jora~ar~ Reservoir Water ~u~aply Nulrier~t Rules, June <br />~~j ~V~I <br />Dear Dr. Moreau: <br />Thank you for the opportunity to provide comments vn the proposed nutrient <br />management rules for Jordan Lake Reservoir. C?range County appreciates the work to <br />date by the Environmental Management Commission ~EMC~ and the North Carolina <br />Division of water t~uality ~NCDwQ~ staff to address the goal of reducing nutrients, and <br />is supportive of this goal. However, we do have some concerns about the proposed <br />implementation method of non~point source reductions, especially in the Upper New <br />Tape Arm of the lake. <br />As ,you know, grange County has a song history promoting proactive measures for <br />watershed protection: The County irnplemented~ watershed protection measures in its <br />~ 981 Land Use plan and associated honing ordinance and Subdivision Regulations, <br />and also implemented an Erosion Control drdinance in 1975. Both of these actions were <br />firsts for counties in forth Carolina at that time. In addition, the Erosion Control <br />ordinance mandates that and land disturbance in University take Uliatershed dater <br />extended to other watersheds require a building permit approved by the Erosion Control <br />Division. <br />For the last ~5 years, and beyond, County policy has consistently focused substantial <br />emphasis on ~ratershed protection, relying primarily on land use and non-structural <br />measures to protect water quality. Dn-site infiitrativn of the first one~inch of stormwater <br />runoff, extensive stream buffers that exceed state minimums measured from the edge <br />of the FEMA mapped flaodplain, if present, and not the stream bank, and protection of <br />riparian buffer lands and flaodplains~ are among some of the many watershed protection <br />techniques Grange County uses in this and other watersheds in our jurisdiction. The <br />reason for this long-standing policy is a fundamental belief that addressing water quality <br />pratectiar~ at the source by limiting nutrient loading at the outset is preferable tv relying <br />on structural controls after the fact. <br />WWiN.CD.DRANGE.N+C. U's <br />PRDTE'GTING AN,G PRk'SERYING P~"OPL,E~r RESDGRCES, QUALITY DJ= LIFE <br />DRANGS CDUNTYr .1~1DRTH CAROLINA ~- YDV ~DUNTI <br />(9k 19} ,~45-~" ~'3D ~ Fi4~ (.'9 !"9,~ ~i4~-D~^~'6 <br />