Orange County NC Website
=52 <br /> The UNRBA recognizes the importance of supporting agriculture in this watershed to maintain its <br /> rural nature and support the local food economy. As the revised strategy is being developed, farm- <br /> supporting organizations like the NC Farm Bureau and NCDA&CS have helped the UNRBA interface <br /> with farmers and make sure we present our common interests in productive ways. The following <br /> concerns have been raised during these discussions which should be considered in the transition to <br /> rule making to ensure that the interests of all parties are protected and to provide long-term stability <br /> for planning and implementation. For some of these concerns, potential solutions were offered <br /> (shown in italics). All of these concerns will require additional discussion as rulemaking commences: <br /> • Potential risks to farmers who have received funding from non-agricultural organizations if the <br /> structure of the Rules or the accounting methods change in the future; the farmers would have <br /> lost reduction credits to other sectors. Regulatory certainty will need to be addressed with input <br /> from DWR;as stated in this document, agriculture would continue to track nutrient loss <br /> reductions regardless of the source of funding. <br /> • Different funding structures or fluctuating levels of funding could affect allocations to the local <br /> Soil and Water Conservation Districts. Funding the Agriculture Cost Share Program with <br /> consistent levels of funding is one way to address these allocation issues. <br /> • Local government funds used for investment credit should be in addition to current levels <br /> (2023), so the programs are expanded. The recommendations in this document have been <br /> modified to include a year on which increases will be based. <br /> There is a risk that the legislature may reduce funding for the Agriculture Cost Share Program <br /> since more funds would be provided by local governments. <br /> • Fluctuating contribution levels from year to year could lead to instabilities in program <br /> administration. Representatives suggest that a recurring minimum contribution level and/or <br /> multi-year planning periods with stated commitments (e.g., 5 years like the IAIA) would be <br /> helpful for planning and staffing purposes. <br /> Farmers want to continue to receive best management practice and technical assistance from <br /> existing, trusted organizations like local Soil and Water Conservation Districts. Funding the <br /> Agriculture Cost Share Program with consistent levels of funding would continue existing <br /> procedures for funding practices and for technical assistance. <br /> • Depending on the level of funding increase, additional administrative work may overwhelm staff <br /> at NCDA&CS. Allocating some percent of contributions to support staff would help this issue. <br /> • Farmers are concerned that their stormwater fees will continue to increase to fund this program. <br /> One farmer indicated he pays as much as $1,000 per year in stormwater fees. By including <br /> funding of the Agriculture Cost Share Program as an eligible investment by local governments, <br /> farmers are more likely to receive direct benefits under this framework. Alternatively, the fees <br /> may increase under the revised nutrient management strategy but would fund projects like <br /> stormwater control measures on developed areas, sewer improvement projects, or land <br /> conservation. <br /> • Farmers are used to the existing rule structure that has been in place since 2011 and wary of <br /> change that may impact operations and regulatory burdens. Future changes in staff at <br /> regulatory agencies or changes in membership of the Watershed Organization could risk stability <br /> of the partnership. Additional outreach is needed to build trust. Formal agreements are needed <br /> to protect all stakeholders. Inclusion of representatives of agriculture in the Watershed <br /> Organization and its bylaws and committees would solidify partnerships. <br /> It is always necessary in coordinating with agriculture and in working on all projects to respect the <br /> landowner's decision on participation. Since streambank erosion is a significant factor in <br /> phosphorus loading and streams normally intersect multiple landowners, farm agencies can help <br /> 33 <br />