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13 <br />Orange County is -and has always been -very supportive of attempts <br />to reduce nutrient loading and protect water quality in Jordan Lake. <br />However, the method of the proposed implementation for the non- <br />point source rules in the Upper New Hope Arm may not be practical or <br />equitable for a rural jurisdiction, especially since significant protective <br />measures have been instituted for many years. <br />In particular, Orange County would like to offer the following points for <br />the Commission's consideration: <br />1. Reductions for existing development are not "performance" based. <br />a. The proposed reductions for nitrogen and phosphorus are <br />represented as percentage loading reductions. This "one size <br />fits all" approach does not acknowledge the very different <br />loading rates and land use patterns between urban and rural <br />portions of this area; nor does this approach take into <br />consideration the resultant difficulty in achieving a <br />percentage-based reduction by jurisdiction. <br />b. As described above, Orange County already employs <br />watershed protection measures that account for relatively low <br />nutrient loading rates. In order to achieve the proposed 35% <br />reduction in total nitrogen in the Upper New Hope Arm, it is <br />conceivable that forested areas may have to be converted to <br />some sort of structural stormwater control, counter to the <br />County's long-term policy. With forestry outside of the realm <br />of local government regulation, Orange County may not be <br />able to enforce any provisions related to forestry. <br />c. A 35% reduction for rural watersheds with relatively low <br />nutrient loadings will not be as effective as a 35% reduction <br />applied to urban watersheds. <br />d. While stormwater retrofits may be a logical approach in urban <br />areas where loading rates are higher, it does not seem <br />practical or equitable to hold rural areas to the same <br />percentage reduction goal, when protective measures are <br />already in place. <br />e. An in-stream nutrient level goal for each sub-watershed of <br />Jordan Lake, and a corresponding nutrient delivery model to <br />sustain the goal, may be a more effective method to equitably <br />address reductions. <br />