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

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Falls Lake Draft Rules Comments 7 Page 4 These facts make the claim of these areas as significant sources of nitrogen from septic systems even more doubtful. 3. Significant reductions in nutrient loading from agricultural lands were already achieved in Orange County as a result of the existing Neuse Rules, as well as the advent of "no -till' agriculture in the recent decades. Further reductions in nutrient loading from the dwindling number of agricultural operations in the county may not be feasible. Additional reductions in croplands and pastures as a result of buffer and livestock exclusion requirements may force more agricultural operations out of business, likely having the detrimental affect of increasing urban -style development within rural areas, counter to the County's Comprehensive Plan. Any such increase in developed lands is likely to result in an increase in nutrient -laden runoff. 4. While there is little doubt that measures are required to reduce the nutrients entering Falls Lake, little information seems to be available as to what the proposed nutrient reductions described in the draft rules will actually accomplish to this end. Will the proposed reductions actually result in Falls Lake no longer being "impaired "? How long will it take for reductions in nutrient levels in the lake to be seen, based on reductions in nutrient loading in the watershed? Is it even feasible to continue to maintain all designated uses of Falls Lake? Are there alternative water quality standards which would be sufficient to protect the main uses of Falls Lake and which would not be so difficult to achieve? Unfortunately, answers to these important questions likely do not exist at this time. It may be worthwhile to have an independent organization examine these issues, and others, once Stage I of the Nutrient Reduction Strategy is underway - if for no other purpose than to give support to the further reductions that are called for under Stage II. Given the enormous nutrient load reductions called for in Stage II of the draft rules, and since the technology that several area wastewater treatment plants will depend upon to meet the reduction goals does not exist, a review of the progress to date seems like an excellent idea. 5. The Triangle Chairs and Mayors Group published a set of Consensus Principles earlier this year concerning the draft Nutrient Management Strategy. While these principles supported many of the draft rules, contained within the list of principles was a desire for the proposed rules to include a "re- examination" of the rules after they have been in effect for several years, prior to Stage II of the rules (which calls for even more drastic reductions in nutrient loading than mandated in Stage 1). The Consensus Principles state that the rules development process "relied on a limited data base which will be substantially enhanced by a more rigorous program of sampling, monitoring and analysis." This limited data base included lake samples collected during the extraordinarily dry year of 2007.