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24 <br /> 1 As a result, the UNRBA jurisdictions collectively worked to encourage a re-examination of the <br /> 2 Rules, with an alternative method of addressing nutrient reductions for the Lake. Rather than <br /> 3 trying to implement jurisdictional load reductions on their own - at great cost and questionable <br /> 4 results - the UNRBA and its member local governments have spent the last few years working <br /> 5 with consultants and in coordination with the NC Division of Water Resources to find a preferred <br /> 6 and "doable" alternative approach to meeting the nutrient reduction goals. Note: Considerable <br /> 7 additional detail and information about the Falls Rules, UNRBA findings, types of reduction <br /> 8 measures, and the "Path Forward"to identifying an alternative approach, may be found on the <br /> 9 UNRBA website at www.UNRBA.orp. <br /> 10 <br /> 11 To this end, since 2018 the UNRBA has been developing an alternative option for achieving <br /> 12 compliance with Stage I existing development nutrient load reductions that would be required by <br /> 13 the Rules. This alternative approach would promote a commitment to additional actions directed <br /> 14 at reducing nutrient loading impacts from existing development, using both existing and new <br /> 15 and innovative measures, to improve the water conditions in the Lake. Titled the "Interim <br /> 16 Alternative Implementation Approach" or IAIA, this program is considered interim because it <br /> 17 would apply only during the period between the time this alternative approach is initiated and <br /> 18 when the Rules are readopted (expected to occur in 2025 or later). However, it is important to <br /> 19 note that it is anticipated that the experience and use of this approach may very well inform and <br /> 20 serve as a model for the future readopted Rules to be implemented beyond 2025. A summary of <br /> 21 this document (in draft form) may be found as Attachment 1. <br /> 22 <br /> 23 The IAIA is based on voluntary participation of UNRBA members in the Program, and will allow <br /> 24 participating jurisdictions to achieve compliance with the Stage I requirements. Choosing not to <br /> 25 participate in the IAIA would result in a jurisdiction having to comply on their own by developing <br /> 26 a Stage I local program consistent with the Rules and the Model Program as written. Phase 1 <br /> 27 compliance without the IAIA would require installation of nutrient-removing measures in direct <br /> 28 relation to Orange County's prior nutrient loading. In other words, the County would need to <br /> 29 install enough nutrient-reducing ponds or similar SCMs to compensate for the amount of <br /> 30 Nitrogen and Phosphorus added to Falls Lake from Orange County between 2006 and 2012. <br /> 31 <br /> 32 Participating in the IAIA will allow a jurisdiction, in the interim period, to achieve full Stage 1 <br /> 33 existing development compliance. The IAIA also allows for credit for land conservation. There is <br /> 34 currently no credit for land conservation, of which Orange County has achieved considerable <br /> 35 success, except through the IAIA (until such time as the rules may be revised to include this <br /> 36 measure). Under a local-only program outside of the IAIA, the nutrient reduction would need to <br /> 37 be accomplished with traditional Stormwater Control Measures (SCMs - ponds, permeable <br /> 38 pavement, green roofs, etc.) or other structural controls. <br /> 39 <br /> 40 As noted, the NC Division of Water Quality has been advising on the IAIA and has indicated <br /> 41 support for this alternative approach to date. <br /> 42 <br /> 43 At this time, the UNRBA has completed work on the IAIA and is asking all member jurisdictions <br /> 44 to tentatively commit to participating in this effort beginning in FY 2021-22, before authorizing <br /> 45 staff and consultants to complete the actions that would be needed to formally implement the <br /> 46 program. Staff from DEAPR, Planning and the County Attorney's office have been involved in <br /> 47 the development of the IAIA from the outset, and recommend participation in the program as a <br /> 48 more cost-effective, collaborative and technically-efficient way to address the nutrient loading <br /> 49 issues that will be needed for Falls Lake. <br /> 50 <br /> 51 Commissioner Greene serves as the County's member on the UNRBA Board of Directors, with <br />