Orange County 2024 Priority Legislative Issues with Attachments

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10 areas including forests, land in forest succession, scrubland, non-pasture grassland, and isolated or connected wetlands. Nutrient loads from these areas should not be directly or indirectly assigned to other source categories. 7. The revised rules should promote land conservation and preservation of natural or unmanaged areas as an investment credit. 8. The revised rules should include a provision for a watershed organization to promote voluntary coordination of an investment-based,joint-compliance approach. 9. The revised rules should maintain the annual loading limits specified in the current new development rule,provide a more flexible evaluation-of-need for stormwater nutrient control for individual residential lots or for the subdivision of large family parcels for the purposes of passing land to heirs for building their homes, allow local governments to consider more innovative approaches to stormwater management, and include joint consultation among watershed organization members to assess and document consistent application of new development requirements. 10. Major and minor wastewater treatment plant owners should continue to optimize treatment performance using currently installed technologies. Review of plant performance should be included as a provision of the 25-year review. Plant and collection system owners should continue to track emerging technologies that may become technically and financially feasible in the future for further improvements to plant operations and biosolids handling; and identify and eliminate exfiltration from sewer lines and sanitary sewer overflows. 11. The revised rules should incorporate requirements for new wastewater treatment facility requests or expansion requests including provisions for technology upgrades,joint- compliance permits (e.g., the Lower Neuse Compliance Association's permit), nutrient offsets, and/or nutrient credit trading using practices on managed lands. 12. Investment credits should continue to be available for inspecting, identifying, and repairing or replacing malfunctioning onsite wastewater treatment systems and, as appropriate, for connecting onsite systems to sewer systems. 13. Separate, State-required nutrient management requirements should not be applied to managed lands in separate areas of the watershed(draining to an upstream watershed impoundment, arms of Falls Lake, etc.). However, water quality in all areas of the watershed should be tracked,particularly sub-watersheds with water-supply impoundments. The adaptive management provisions of the revised rules should address changing conditions in these waterbodies and allow for revisions to the program to address concerns as they arise. 14. The revised rules should expand the types of projects that qualify for investment credit, include the option of developing new credit types, and provide opportunity for other voluntary partners. The revised rules should promote local government participation in other watershed improvement actions. 15. The revised rules should encourage local governments to base implementation decisions on the principles of the fair and equitable treatment of members, and the residents of the watershed. The revised rules should promote opportunities for equitable stakeholder participation by encouraging input and participation from the public and interest groups. 16. The chlorophyll-a standard and water quality 303(d) assessment methodology for Falls Lake should be adjusted to better represent conditions in Falls Lake. The UNRBA supports an adjusted 303(d) assessment methodology and site-specific chlorophyll-a standard for Falls Lake and will continue to cooperate and collaborate with DEQ-DWR, Environmental Protection Agency(EPA), and other stakeholders on these revisions. The UNRBA does not recommend delaying rule revisions while these objectives continue to be developed and evaluated. Readoption of the Falls Lake Rules remains the priority so ongoing implementation efforts in the watershed can proceed.