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8 <br /> November 15, 2023 <br /> UNRBA Submittal of Recommendations for a Revised <br /> Falls Lake Nutrient Management Strategy <br /> member governments of the UNRBA have not only committed to evaluation of the rules, but they <br /> have also made important strides in reducing nutrients in the watershed and the lake. <br /> However, the UNRBA has taken very seriously the tremendous requirements placed on them by <br /> Stage II of the Falls Lake Rules. Due to the uncertainty cited and concerns about the reduction goals <br /> for Stage II, the UNRBA undertook, ahead of designing the reexamination effort, a preliminary <br /> evaluation of the requirements of Stage II. This evaluation determined the Stage II reductions are <br /> infeasible and beyond the limits of technology(Cardno ENTRIX 2013). Nevertheless, the UNRBA <br /> remained committed to completing a comprehensive scientific reevaluation of the lake and its <br /> watershed. We have always been focused on a revised set of Rules that are built on an improved and <br /> solid scientific foundation. The UNRBA began planning our reexamination in 2011, and in <br /> accordance with the procedures and requirements outlined in the Rules, carefully undertook the <br /> development of the detailed monitoring and modeling programs, including the quality assurance <br /> documentation,to be used during this effort. The final plans and evaluation procedures/process <br /> documentation were approved by DWR. By the end of this reexamination process, this year, the <br /> UNRBA membership completed a 13-year effort and invested approximately$10 million of local <br /> government funds. This is an unprecedented effort by a coalition of regulated communities in NC to <br /> provide study and research to DWR, EMC, and the General Assembly to support the development a <br /> revised management approach on a critically important water body. <br /> With reference to the UNRBA coordination and use of the studies conducted by researchers funded <br /> by the NC Collaboratory, it is important to reference this organization. The NC Collaboratory was <br /> formed by the NC legislature in 2016 to study nutrient management issues in Jordan Lake and Falls <br /> Lake. Since that time, the NC Collaboratory has been expanded significantly to look at a range of <br /> issues in our state. Following the creation of the Collaboratory, the UNRBA reached out to the NC <br /> Collaboratory and positioned itself to share data and coordinate. The NC Collaboratory looked first <br /> at Jordan Lake,but then moved to Falls Lake. Even before the research on Falls began, the UNRBA <br /> coordinated with the organization and provided summaries of the work already completed by the <br /> UNRBA. This allowed the UNRBA to provide input each year on the status of our work and identify <br /> what additional studies might enhance and better inform the development of the UNRBA's <br /> reexamination. The UNRBA has shared all its data, work, and preliminary results with the <br /> Collaboratory. The Collaboratory also provided subject matter expert and third-party review of the <br /> UNRBA modeling of the watershed and lake. This extremely valuable contribution occurred while <br /> the models were under development. This integrated approach allowed the reviewers to provide input <br /> and feedback as the models were developed and allowed the modeling team to incorporate <br /> adjustments before the models were finalized. Third-party reviews increase transparency and provide <br /> an extra layer of assurance that the models can be relied upon to support regulatory and policy <br /> decisions. The UNRBA and NC Collaboratory held joint symposium each of the last three years, <br /> sharing information with our member representatives, DEQ, other researchers, environmental <br /> advocacy and conservation organizations, and other stakeholders. This collaboration has provided <br /> essential scientific clarification of the work done by the UNRBA and the NC Collaboratory. The NC <br /> Collaboratory's report on Falls Lake is due this December. <br /> Many other organizations and researchers have also provided critical information to support the <br /> reexamination and our recommendations. The amount of data available and the number of <br /> researchers involved in this study is extraordinary. Nearly 40 distinct monitoring programs or <br />