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ATTACHMENT 2 <br />Upper Neuse River Basin Association n <br />January 17, 2006 <br />Mr. William Ross, Secretary <br />NC Department of Environment and Natural Resources <br />1601 Maii Service Center <br />Raleigh, NC 27699-1601 <br />Subject: Stakeholder Process for the Falls Lake Nutrient Management Strategy <br />Dear Secretary Ross: <br />We are writing you because we are concerned about the limited amount of stakeholder involvement in the <br />development of a nutrient management strategy for the Falls Lake Watershed. We understand that any <br />stakeholder involvement in this process may be limited to that which is required by law: a public hearing of <br />proposed rules prior to their adoption by the Environmental Management Commission. We understand that <br />the Division of Water Quality has limited staff to support such a process, but a practical, feasible nutrient <br />management strategy for Falls Lake would be achieved most effectively through an open, inclusive <br />stakeholder process on par with that which occurred for developing the Jordan Lake nutrient management <br />strategy. <br />As you well know, to have the full cooperation of the communities involved, the nutrient management <br />strategy must be sound, practical and achievable. This is in the interest of both NCDENR, which is <br />responsible for.overseeing water quality standards statewide, and the local governments in the basin that will <br />ultimately be responsible for implementing the nutrient management strategy. If our citizens do not <br />understand the strategy, were not a part of developing it, and wonder if implementing it will make a <br />difference, then the strategy will fail. The extent of the public's involvement in the DWQ's current work on <br />Falls Lake is a Technical Advisory Committee (a handful of technical experts from local governments) for <br />developing the nutrient response and watershed models, and a couple of meetings at which DWQ staff <br />imparted information. Once the models are completed, stakeholder participation would be limited to the <br />public hearing required by the rulemaking process. We are concerned that this would be a recipe for failure, <br />which would not be good for Falls Lake. <br />The UNRBA recognizes the challenge that you face in funding projects to meet water quality standards. The <br />local governments face similar funding challenges. We propose a state-local partnership to meet this <br />challenge. We ask you to commit to working with the UNRBA to fmd a source of funding for a robust and <br />comprehensive stakeholder process for the Falls Lake nutrient management strategy development. Sydney <br />Miller (Triangle J Council of Governments) and Chris Dreps (1-TNRBA Coordinator) are actively working to <br />fmd such sources. Unfortunately, fmding a source of funding is difficult because Falls Lake is in a "grey <br />area." The Lake is not listed as impaired, yet the DWQ has launched a process with the explicit purpose of <br />determining assimilative capacity and loading limits. Therefore, Falls Lake does not qualify for many <br />sources of federal funding. <br />The UNRBA is already working with the invaluable support of NCDENR to improve management of the <br />Falls Lake Basin. The Upper Neuse Watershed Management Plan recommends 19 watershed management <br />strategies for protecting water quality and aquatic habitat. Among the recommendations are strategies to <br />reduce nutrient loading from newly developed sites, detailed watershed restoration plans for the most <br />PO Box 12276 RTt', NC 27709 Ph (919) 558-2702 Fix (919) 549-9390 <br />