Agenda - 06-01-2010 - 7a - Laserfiche WebLink

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information concerning the County's strong history of watershed protection. The letter includes the following highlights: • The reduction measures proposed are not performance- based, but are in fact a "one size fits all" set of regulations, and may not be equitable, with flexibility needed for more rural areas where local governments have previously instituted progressive watershed protection and minimized nutrient loading. • There is less agriculture in the watershed within County jurisdiction than the model may assume, and the agricultural operations that do remain have already made significant reductions in nutrient loading as a result of the earlier Neuse Basin Rules and changes to no -till agriculture - making any required further nutrient reductions difficult to achieve for the agricultural community. • The burden of cost for implementing these measures would fall in large part on local governments. Water quality issues in Falls Lake have been long- predicted and are regional in nature. State funding assistance would be appropriate in addressing this larger regional problem, especially for a jurisdiction with a proven history of watershed protection — voluntary protection which has also come at cost to the County. • Uncertainty exists regarding some of the input parameters used in the modeling. • Finally, the timing of the public comment period over the summer months is not conducive to stakeholder and public participation. As the County proposed for the similar Jordan Lake Rules public comment period in summer 2007, an extension to allow a fuller discussion and dialogue would be desirable. FINANCIAL IMPACT: There is no financial impact associated with the conveyance of these comments. However, promulgation and implementation of the Falls Lake rules that have been proposed will have significant financial impacts for local governments for an extended period of time. The cost of implementing reduction measures will not be known until the accounting tool is made available. Some jurisdictions (with more urbanized areas and expensive retrofit options) have estimated the cost of complying with the draft rules to be in excess of $500 million dollars. RECOMMENDATION(S): The Manager recommends that the Board consider and discuss the attached draft public comments letter and authorize the submittal of the letter to the EMC during the public hearing period, with such changes as deemed necessary.