19970722 Ver 1_Staff Comments_19970707

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Comments on Randleman Lake Nutrient Management Strategy and Implementation
Plan
Concerns
This management strategy will not completely solve the problem - chlorophyll a
standard violation. Several proposed lake segments including Deep River 1, Deep
River 2 and Muddy Creek 1 will still experience chlorophyll a concentration exceed
over 40 ug/l for more than 5% of the growing season under the proposed management
strategy.
This management strategy leans heavily towards point source reduction. The solution
to reduce nonpoint source pollution was weak in the strategy even through the
strategy stated that problem segments (Deep River 1 and Muddy Creek 1) of the
proposed lake received substantial nonpoint source runoff from adjacent urbanized
areas.
This management strategy did not include any cost-effective analysis, although one of
objectives of this strategy was to identify the most cost effective ways of reducing
nutrient loading.
Questions
• What is the definition of open space in the land use category? What is the difference
between forestry and open space in the land use category?
Why are no best management practices considered for medium density residential
giving the condition that medium density residential will experience a significant
increase in the future land use?
• Why are regional detention ponds located in the exist water supply watersheds which
are far away from problem segments (Deep River 1 and Muddy Creek 1) of the
proposed lake?
Recommendation
• Strengthen nonpoint source portion of the management strategy: include more
stormwater best management practices for urban areas especially residential areas
(The strategy should remodel ordinances given tighten stormwater controls.);
• Consider nutrient management for most of land use categories since nutrient
management is considered one of the most cost effective best management practices;
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• Extend the riparian buffer requirement to intermittent streams, require 10 feet of
undisturbed buffer adjacent to surface waters and have a minimum setback at least 30
feet for new development and any land disturbing activities;
• Increase overall wetland acreage in the proposed water supply watershed, minimize
the gap between the estimated wetland needed and proposed restored wetland
acreage;
• Document potential phosphorus loading reductions through improvement of existing
onsite wastewater treatment systems;
• Document potential phosphorus loading reductions through illegal discharge removal
and repair of leaking sewer lines;
• Provide details on the proposed educational program;
• Consider requiring certified waste management plans for all animal operations
regardless of size;