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7 <br /> -' November 22, 2023, Submitted via email <br /> UPPER NEUSE RIVER <br /> BASIN ASSOCIATION <br /> Mr. John (JD) Solomon, Chair <br /> Arba <br /> NC Environmental Management Commission (EMC) <br /> 1 1611 Mail Service Center <br /> Raleigh,N.C. 27699 -1617 <br /> Forrest Westall e-mail: pamlicojd@gmail.com <br /> Executive Director <br /> forrest.westall@unrba.org Mr. Richard Rogers, Director <br /> PO Box 270 Division of Water Resources (DWR) <br /> Butner, NC 27509 1611 Mail Service Center <br /> Phone:919.339.3679 Raleigh,NC 27699-1611 <br /> e-mail: richard.rogers@ncdenr.gov <br /> On the Web: <br /> http://unrba.org Reference: UNRBA Submittal of Recommendations for a Revised Falls Lake <br /> Nutrient Management Strategy and Revised Rules <br /> Town of Butner <br /> Dear Mr. Solomon and Mr. Rogers: <br /> City of Creedmoor <br /> The UNRBA is extremely pleased to submit our recommendations for a revised <br /> City of Durham Falls Lake Nutrient Management Strategy and readoption of the Falls Lake Rules. <br /> In submitting these recommendations and a summary of our scientific findings from <br /> Durham County a ten-year evaluation/study of Falls Lake and its watershed, it is important to give <br /> reference to how we have arrived at this juncture. It has been a thirteen-year <br /> Franklin County process that reflects an investment of local government resources to develop a much <br /> more complete understanding of this aquatic system. <br /> Granville County In 2010, the Environmental Management Commission(EMC)passed the Falls Lake <br /> Nutrient Management Strategy(the "Strategy" or the "Rules"). The Strategy <br /> Town of Hillsborough dictates load reduction requirements for local governments and other entities. <br /> Because of the engagement of stakeholders in the rule development process, the <br /> Orange County first set of Consensus Principles developed by the local governments to support the <br /> initial adoption of the Falls Lake Rules represents a good model for the readoption <br /> Person County of these rules. The cooperation and work of DWR and the EMC to incorporate <br /> those principles into the rules in 2010 provided an effective process to assess the <br /> City of Raleigh uncertainty associated with the modeling used to develop the 2010 rules. This <br /> uncertainty about the required nutrient load reductions, particularly for Stage II, <br /> Wake County resulted in the extensive scientific work performed since the initial rules were put in <br /> place. The adaptive management provision that allowed the last 10 years of effort is <br /> Town of Wake Forest described in the Rules (15A NCAC 02B.0275 Section (5)(f)). The UNRBA took on <br /> the responsibility of performing a reexamination under this provision of the Falls <br /> South Granville Water Lake Rules. <br /> and Sewer Authority <br /> Soil and Water In addition to the reexamination, the UNRBA has and continues to support its <br /> Conservation Districts members in the implementation of Stage I of the management strategy. It should be <br /> Town of Stem noted that this implementation, and other nutrient loading improvements since <br /> 2006, has generated significant reductions in nutrient inputs for Falls lake. The <br /> 1 <br />