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DRAFT <br />June 26, 2007 <br />Dr. David H. Moreau, Chair. <br />Environmental Management Commission <br />1617 Mail Service Center - <br />Raleigh, NC 27699-1617 <br />Re: Comments on the proposed Jordan Reservoir Water Supply <br />Nutrient Rules, June 15, 2007 <br />Dear Dr. Moreau: <br />Thank you for the opportunity to provide comments on the proposed <br />nutrient management rules for Jordan Lake Reservoir. Orange County <br />appreciates the work to date by the Environmental Management <br />Commission (EMC) and the North Carolina Division of Water Quality <br />(NCDWQ) staff to address the goal of reducing nutrients, and is <br />supportive of this goal. However, we do have some concerns about the <br />proposed implementation method of non-point source reductions, <br />especially in the Upper New Hope Arm of the lake. <br />As you know, Orange County has a long history promoting proactive <br />measures for watershed protection. The County implemented <br />watershed protection measures in its 1981 Land Use Plan and <br />associated Zoning Ordinance and Subdivision Regulations, and also <br />implemented an Erosion Control Ordinance in 1975. Both of these <br />actions were firsts for counties in North Carolina at that time. In <br />addition, the Erosion Control ordinance mandates that ~ land <br />disturbance in University Lake Watershed (later extended to other <br />watersheds) require a building permit approved by the Erosion Control <br />Division. <br />For the last 25 years, and beyond, County policy has consistently <br />focused substantial emphasis on watershed protection, relying <br />primarily on land use and non-structural measures to protect water <br />quality. On-site infiltration of the first one-inch of stormwater runoff, <br />extensive stream buffers that exceed state minimums (measured from <br />