Orange County NC Website
Browse       Search
4a-30 <br />achieve the proposed 35°/~ reduction in total nitrogen in the Upper New Hope <br />Arm, it is conceivable that forested areas may have to be converted to some <br />sort of structural stormwater control, counter to the County's lan~~term policy. <br />With forestry outside of the realm of local government regulation, orange <br />County may not be able to enforce any provisions related to forestry. <br />c. A 35°ln reduction for rural watersheds with relatively low nutrient loadings will <br />not be as effective as a 35°/~ reduction applied to urban watersheds. <br />d. vtilhile stormwater reffofts nnay be a logical approach in urban areas where <br />loading rates are higher, it does not seem practical or equitable to hold rural <br />areas to the same percentage reduction goal, when protective measures are <br />already in place. <br />e. An in-stream~nutrient level goal for each sub~watershed of Jordan Lake, end <br />a corresponding nutrient delivery model to sustain the goal, may be a mare <br />effective method to equitably address reductions. <br />~. .oading rates by jurisdiction may not be equitable. <br />a. because of the location of the monitoring stations further downstream in both <br />the Morgan Creek and New Dope Creek sub-basins, it is impossible at this <br />time to accurately project loading rates by jurisdiction and validate what are <br />very different land use patterns and non-point source loading between <br />jurisdictions. <br />b. As such, it is difficult for each jurisdiction to determine whether the costs of <br />reduction are being equitably borne by the jurisdiction where loading is <br />occurring. if this type of reduction approach is pursued, further assessment of <br />the costs of implementing the rules - calibrated as best possible tv the <br />leading coming from each jurisdiction ~ v~ould be instructive to help ensure <br />that benefts and costs are equitably shared. A program that prdvided <br />reciprocal benefts to jurisdictions with low loading rates but high levels of <br />protection is essential to meeting equity concerns raised by heightened <br />regulation. The City of Raleigh's efforts to fund upstream watershed <br />protection in the Upper Neuse is reflective of a proactive realisation of such <br />an obligation. <br />3. Non-point source reductions were not calibrated to the Jordan Lake model. <br />a. It is our understanding that the non~point source reductions called for in the <br />rules were not calibrated to the specif c Jordan Lake model, as was the case <br />with the paint4source loading. The non-point source reduction rates were <br />instead estimated from other modeling and land use projections. <br />b. Therefore, it is not as clear whether the proposed rules for non-point sources <br />will achieve the stated goals, and it may be impossible to know if the <br />reduction targets will work until substantial tune, funding and other resources <br />are expended on feasibility studies and implementation. <br />fi <br />