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~~ <br />should be excluded. The provisions of such a rule should be consistent throughout the <br />entire area, and should vary only in that the nutrient targets to be achieved differ between <br />each of the two subwatersheds, Local governments would support the state in that effort. <br />3. We recommend that if the EMC includes a "buy-down" prograzn for new development, at <br />least 80% of the revenue generated by the program must be spent on projects within the <br />,jurisdiction in which the revenue was generated. <br />4. We reconunend that the state require the Department of Transportation to submit nutrient <br />management plans to the DWQ for their existing projects and for any new projects. <br />Jordan Lake Watershed Model: <br />1. The Jordan Lake Watershed Model used for nonpoint source nutrient allocations is <br />inadequate for implementing and monitoring the nonpoint source nutrient management <br />strategy, We recommend that the DWQ redevelop the model at a higher resolution and <br />update the model with more current land use and impervious surface information, <br />2. We recommend that the DWQ update the model periodically to incorporate changes in <br />land uses, impervious surfaces, and nutrient loading rates. The model will be important <br />for monitoring progress in nonpoint source nutrient management for the Tordan Lake <br />Watershed. <br />Feasibility Study: <br />1. We recommend that the DWQ conduct a feasibility study to deternline whether the <br />nonpoint source management strategy for existing development is feasible, We do not <br />even know whether it is theoretically possible to achieve the proposed nutrient limits <br />within jurisdictions that have urban lazed, The feasibility of the NPS strategy has <br />implications for the entire nutrient management strategy as a whole. What happens if the <br />EMC and EPA adopt the nutrient management strategy and TMDL, and we then discover <br />that the areal nutrient limits camrot possibly be achieved? <br />2. We recommend that the feasibility study begin immediately. <br />Allocation for Future Growth: <br />We oppose any explicit allocation for future growth. An explicit allocation for future growth <br />would be, in fact, an allocation to the state, The currently proposed allocations appropriately <br />leave growth management to the local govennnents, which are responsible for treating that <br />wastewater and stormwater. <br />