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1(0 <br />c. An emphasis on nutrient reduction trading, rather than in- <br />lieu-of payments, may be more effective. A trading ratio of <br />2:1 or greater may be needed to ensure actual in-basin <br />nutrient reduction. <br />8. The current planned public comment period is not feasible. <br />a. The current planned timetable for public comment over the <br />summer months (June 15-August 15) is not optimal to <br />receive public comment on a subject of this importance. <br />Many local government boards take a °summer" break. <br />Because of the potential cost and far reaching ramifications of <br />these rules, the public comment period should be sufficiently <br />long enough to allow appropriate response from impacted <br />local governments. <br />In summary, Orange County would ask the Commission to consider <br />modification of and alternatives to application of a single nutrient <br />reduction percentage to all jurisdictions in the Upper New Hope Arm. <br />Thank you for considering these comments; and we stand ready to <br />help work with the State and other local governments in an equitable <br />and efficient manner to reduce nutrient loading in Jordan Lake. Please <br />feel free to contact our staff in the Environment and Resource <br />Conservation and Planning departments if we may provide additional <br />information or clarification. <br />Sincerely, <br />Moses Carey, Jr. <br />Chair <br />Orange County Board of Commissioners <br />Copies <br />Board of Commissioners <br />Laura Blackmon, County Manager <br />Rich Gannon, NCDWQ Non-Point Source Planning Unit Supervisor <br />Sydney Miller, TJCOG Water Resources Program Manager <br />