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~~'~ ~ '~ <br />C. ~r ~5 <br />4.~ ~,~ <br />_~. <br />World <br />Class <br />Region <br />Date: <br />To: <br />From: <br /> <br />TRIANG~,E J COl1NCIL OF GOVERNMENTS <br />MEMORANDUM <br />March 16, 2007 <br />Local governments in the Jordan Lake watershed <br />Sydney Miller, Water Resources Program Manager <br />4307 Emperor Boulevard, Suite 110 <br />Durham, NC 27703 <br />Mailing Address: PO Box 12276 <br />Research Triangle Park, NC 27709 <br />919.549.0551 FAX: 919.549.9390 <br />www.tjcog.dst.nc.us <br />Subject: Proposed Jordan Lake nutrient rules dated March 8, 2007 and fiscal analysis dated <br />March 2007 <br />I have read through the latest drafts of the proposed Jordan Reservoir Water Supply Nutrient <br />Rules and Fiscal Analysis: B. Everett Jordan Reservoir Water Supply Nutrient Strategy. Staff at <br />the NC Division of Water Quality has clearly made agood-faith effort to prepare the fiscal <br />analysis. <br />I have prepared some comments, generally from the perspective of local government. Do not <br />construe my comments to represent the opinions of any local governments or their staffs. The <br />opinions in this memorandum are my own. Furthermore, I am certain that I have missed <br />important points within both the rule and the fiscal analysis. Additional reviews would only <br />improve our consideration of the rule and the fiscal analysis. <br />My comments pertain to both the proposed rules and the fiscal analysis. I have included citations <br />within my comments in an abbreviated format. ".026X" refers to a rule within 15A NCAC 02B <br />.0262-.0272. "FA Chapter X" refers to a chapter of the fiscal analysis. <br />1. Watershed Nutrient Reduction Goals -The rule (.0262 (6)(a)) states that "rules .0265, .0266, <br />.0267, .0268, and .0269 shall apply to all incorporated municipalities within the Jordan <br />watershed as identified by the Office of the Secretary of State." However, the rule goes on to <br />state that "those municipalities shall include:" and provides a list of municipalities. The rule <br />should be clarified to indicate that the list is meant only as an example, and that the phrase <br />"shall apply to all municipalities within the Jordan watershed as identified by the Office of <br />the Secretary of State" controls. Newly incorporated municipalities within the Jordan Lake <br />watershed, and municipalities previously outside of the Jordan Lake watershed but that annex <br />property within the Jordan Lake watershed, should become subject to the rule. <br />MISSION STATEMENT <br />To serve as an intergovernmental organization for local elected officials <br />that works proactively an regional issues in order to sustain and improve the quality of life for our citizens. <br />