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�n=11 <br /> the Stage II requirements. Retrofitting existing development given site constraints with even <br /> one SCM is often not possible. <br /> Recognizing the uncertainty associated with model-based load reduction targets, Section 5(f) of the <br /> Falls Lake Rules included an adaptive management provision allowing for a re-examination of the <br /> Stage II requirements. The decade-long evaluation process by the UNRBA and the four-year study <br /> period funded by the NC Collaboratory have provided exceptional scientific information and <br /> knowledge about conditions in the lake and its watershed. Falls Lake is at risk of increasing <br /> eutrophication, but data and analyses indicate a relatively stable trophic condition. The lake <br /> currently meets its designated uses. Furthermore, nutrient reduction efforts in the watershed and <br /> changes in environmental conditions have resulted in significant reductions in nutrient loading to the <br /> lake since the baseline year of 2006. These conditions have not yet reflected significant and <br /> demonstrative reductions in chlorophyll-a in the lake. Due to the slow response of nutrient cycling in <br /> the lake and its sediments, the full implications of reduced loading over the last 17 years have not <br /> fully manifested. It is likely that these positive changes in the nutrient balance will be reflected over <br /> a much longer time given the large store of nutrients present in the lake sediments and the <br /> continued addition of nutrients from the watershed. <br /> Other watersheds in the country face similar challenges. The Chesapeake Bay Program Scientific <br /> and Technical Advisory Committee (STAC) released a Comprehensive Evaluation of System Response <br /> in May 2023. Similar to the Falls Lake watershed,the report concludes that "current efforts to <br /> reduce nutrient loads will not meet the TMDL targets" and that "estuary water quality has been slow <br /> to respond to realized nutrient and sediment reductions in many regions of the Bay." This report <br /> focuses on an estuary that drains a much larger watershed with more opportunities for <br /> implementation given the relative amount of agricultural land and urban land in the watershed. <br /> Even with additional opportunities for implementation in the Chesapeake Bay watershed, the report <br /> concludes that "additional nutrient reductions will improve water quality, but water quality criteria <br /> may be unattainable in some regions of the Bay under existing technologies" and that "the legal <br /> requirements of the Clean Water Act(the water quality goal) divert attention away from considering <br /> multiple means of improving living resources (support of aquatic life as the designated use)." <br /> As noted above, the current Falls Lake Nutrient Management Strategy is not technically,financially, <br /> or logistically feasible due to the unique characteristics of the watershed and the reservoir. A revised <br /> Nutrient Management Strategy for Falls Lake based on the science available and sound <br /> management principles is needed to protect this resource. While it is impossible to change the <br /> fundamental characteristics of this watershed and reservoir that make it eutrophic, a regulatory <br /> framework for nutrient management is essential for maintaining designated uses. The critical <br /> management objective for Falls Lake must be to mitigate impacts from existing activities in the <br /> watershed and to design and manage land use changes while continuing to maintain and improve <br /> water quality in Falls Lake. Without reasonable, balanced, and economically supportable actions, <br /> the risk of increased eutrophication, degradation of water quality, and adverse impacts to <br /> designated uses is a real possibility in the face of changing land use patterns and climatological <br /> conditions. <br /> Key Findings from Information Gathering, Monitoring, and Modeling Studies <br /> Before the comprehensive monitoring and modeling effort began, the UNRBA conducted an open <br /> and transparent planning process to ensure the requirements for a re-examination specified in the <br /> Falls Lake Rules were met. The state-approved monitoring and modeling quality assurance project <br /> plans (QAPPs) ensured the work of the UNRBA was conducted in a scientific and quality-assured <br /> manner. Since the monitoring effort started in 2014,the UNRBA has made considerable effort and <br /> investment to further the scientific understanding of the watershed and the lake. The UNRBA has <br /> ii <br />