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nutrient load target that needs to be achieved will be done in the first 10 years. <br /> There is no end date for the total reductions. <br /> In addition, local governments can receive credits for documented BMP's and storm water <br /> practices put in place after the base period of 2001. <br /> Impacts of the Jordan Lake rules on Orange County <br /> Under the Jordan Lake rules, Orange County would need to meet the 5% reduction <br /> goal for phosphorus loading. The nitrogen reduction target is 8% for streams that drain to the <br /> Haw River, including tributaries of Back Creek, Haw Creek, Cane Creek, Collins Creek, and <br /> Terrells Creek. The nitrogen reduction target is 35% for streams that drain to Jordan Lake, <br /> such as the upper reaches of New Hope and Morgan Creek in Orange County. There is much <br /> land in Orange County that is agricultural or forested and would not be part of the Existing <br /> Development rule, where the primary cost of implementation would occur for the rules. (There <br /> is a separate section of the rule that applies to agriculture, similar to the Best Management <br /> Practices for nutrient reductions long in place in the Neuse and Tar-Pamlico river basins. <br /> Forests are not covered, as they are a `background' or naturally occurring source of nutrients). <br /> Orange County, along with many other local governments in the watershed, already <br /> have riparian buffers in place more stringent than the state minimums proposed, and already <br /> enforced by the county. <br /> Nutrient Trading: <br /> We agree with David Stancil's opinion (Jordan Lake Nutrient Management Rules — <br /> Position Statement' March 30, 2009) that there are very promising possibilities for Orange <br /> County to engage in nutrient trading with urban jurisdictions that part of the Upper new hope <br /> arm of Jordan Lake, through conservation and wetland projects in the Rural Buffer. As he <br /> points out, these trades would only happen if the Existing Development rule remains part of <br /> the Jordan Lake rules. <br /> Wastewater treatment plants: <br /> OWASA will be required to meet the 35% reduction for nitrogen because the waste <br /> water treatment plan discharges to Morgan Creek, in the most impaired part of Jordan Lake. <br /> The costs associated with waste water treatment plant upgrades are often mistakenly cited as <br /> a result of these rules. These upgrades will be necessary even without the Jordan Lake rules <br /> as the result of a 1997 state law (the Clean Water Responsibility Act) that mandated upgrades <br /> by 2011. The Jordan Lake rules move the compliance date to 2014. <br /> The U. S. Clean Water Act - and the EPA TMDL for Jordan Lake: <br /> The model and monitoring methods for determining the impairment of Jordan Lake <br /> (excessive algae growth caused by nutrient loading from all land uses in the Haw River basin) <br /> was approved by the EPA. The EPA has also improved the Total Maximum Daily Load for the <br /> Jordan Lake nutrient reductions as required under the Clean Water Act. If any section of the <br /> current rules to reduce nutrients (such as the Existing Development rule) is not passed by the <br /> General Assembly, the state will have to find other ways to achieve those reductions. Would <br /> those reductions come from even greater removal of nutrients from waste water, or from more <br /> stringent new development rules, or from agriculture? <br /> Possible New Funding Sources: <br />