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14 <br />2. Loading rates by jurisdiction may not be equitable. <br />a. Because of the location of the monitoring stations further <br />downstream in both the Morgan Creek and New Hope Creek <br />sub-basins, it is impossible at this time to accurately project <br />loading rates by jurisdiction and validate what are very <br />different land use patterns and non-point source loading <br />between jurisdictions. <br />b. As such, it is difficult for each jurisdiction to determine <br />whether the costs of reduction are being equitably borne by <br />the jurisdiction where loading- is occurring. If this type of <br />reduction approach is pursued, further assessment of the <br />costs of implementing the rules -calibrated as best possible <br />to the loading coming from each jurisdiction -would be <br />instructive to help ensure that benefits and costs are <br />equitably shared. A program that provided reciprocal benefits <br />to jurisdictions with low loading rates but high levels of <br />protection is essential to meeting equity concerns raised by <br />heightened regulation. The City of Raleigh's efforts to fund <br />upstream watershed protection in the Upper Neuse is <br />reflective of a proactive realization of such an obligation. <br />3. Non-point source reductions were not calibrated to the Jordan Lake <br />model. <br />a. It is our understanding that the non-point source reductions <br />called for in the rules were not calibrated to the specific <br />Jordan Lake model, as was the case with the point-source <br />loading. The non-point source reduction rates were instead <br />estimated from other modeling and land use projections. <br />b. Therefore, it is not as clear whether the proposed rules for <br />non-point sources will achieve the stated goals, and it may be <br />impossible to know if the reduction targets will work until <br />substantial time, funding and other resources are expended <br />on feasibility studies and implementation. <br />c. There are also efficiency, cost and feasibility concerns <br />regarding the splitting of nitrogen reductions for non-point <br />and point sources. Nutrient reductions from non-point <br />sources are more complicated and costly to obtain. <br />