Orange County NC Website
4 <br />May 18, 2010 <br />Mr. Stephen T. Smith, Chair <br />Environmental Management Commission <br />1617 Mail Service Center <br />Raleigh, NC 27699 -1617 <br />RE: Comments on the draft Falls Lake Nutrient Management Strategy <br />15A NCAC 02B.0275-.0283 <br />Dear Mr. Smith: <br />Orange County is pleased to be able to provide comments on the draft Falls Lake <br />Nutrient Management Strategy, which is intended to reduce nutrient loading to <br />Falls of the Neuse Reservoir (Falls Lake). The County appreciates the work that <br />the Environmental Management Commission (EMC, the Commission) and the <br />North Carolina Division of Water Quality (DWQ) have undertaken to tackle the <br />issue of reducing the nutrient loading to this important public water body. At a <br />local level, this work is supported by the history of watershed protection that has <br />been a cornerstone of Orange County policies and regulations since the 1970's. <br />The nutrient reduction measures and regulations which the county has already <br />addressed were the first of their kind in North Carolina. These include the <br />implementation of an Erosion Control Ordinance in 1975 as well as the adoption <br />of a Land Use Plan and associated Zoning Ordinance and Subdivision <br />Regulations in 1981. Since then, Orange County has continued to enforce and <br />update regulations and procedures to ensure that the water supply watersheds in <br />the county are protected, including obtaining local delegated authority in 2001 to <br />enforce the Neuse River Basin rules. <br />It has long been the policy of the county to rely on land use measures and non- <br />structural methods of protecting water quality — to treat protection at the source <br />as much as possible. Stream buffer regulations in Orange County have long <br />exceeded the minimums established by the State. Other regulations which serve <br />to protect the quality of water in Orange County include extremely restrictive <br />flood damage prevention standards and impervious cover restrictions. For <br />example, the county's designated Upper Eno critical watershed area, which is <br />