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HomeMy WebLinkAboutChowan-River-Basin-Public-Comments-ResponsesE1 Commenter Topic Response Southern Forests Conservation Coalition SFCC is taking this opportunity to request the plan include meaningful recommendations implemented to reduce negative impacts resulting from the industrial wood pellet industry currently expanding its operations within the Chowan River Basin; an industry annually clearcutting thousands of acres of Chowan River Basin bottomland hardwood forests to feed an unsustainable energy scheme. We would like more specific data concerning this increase in forested area – are these areas replants of areas that were clear cut? Comment Noted - A land cover map that changes with time has been incorporated into the StoryMap for investigating changes in forested areas. What contribution to the canopy coverage is being made by this relatively new acreage especially near waterways? Comment Noted - We plan to work with this commenter and the Natural Working Land Dataset to see if they have conducted an analysis like this. North Carolina Forest Service Updating forestry numbers Comment Noted - Text was updated Ulrich and Mary Alsentzer1 In circumstances where existing rules, in particular those related to logging operations, are known to be violated, those individuals and companies responsible will be aggressively targeted and fined in addition to being required to re-vegetate where transgressions have occurred 1 Chowan Edenton Environmental Group DEQ Secretary Michael Regan discuses the wood pellet industry By: Dave Hendrickson https://www.newsobserver.com/news/state/north-carolina/article238398033.html Basin Planning Branch: Comment Noted - Conversastion started with North Carolina Forest Service to discuss these comment and their concerns. Cypress Group of the NC Sierra Club2 Forestry and Biomass Areas Three huge wood pellet plants that are driving massive clear-cut logging of bottom-land hardwood forests2, Air Quality Permits issued by NCDEQ have not addressed the cumulative environmental impacts of clear-cut logging on water quality, flood control, biodiversity, and marine habitat, or fish population.2 Clearer guidelines from state officials in NC as to which trees or tracts of land can be harvested.2 Chowan River Basin Water Resources Plan - Public Comment Responses 1 2/18/2021 E2 Ulrich and Mary Alsentzer We support any future rule-making that would attempt to tackle some of the issues aptly described in the Executive Summary by putting real “teeth” into your recommendations.Comment Noted Full Circle Crab Company, INC. Conditions of our water have become degraded to the point where its sole purpose is to carry the waste of human abuse to where it can become diluted with sea water Comment Noted - Letter sent to Division of Marine Fisheries Full Circle Crab Company, INC. Blue Cat which now dominates the ecosystem. These fish, introduced into the James River, now make a mockery of the efforts to restore herring and other once prolific populations despite moratoriums and fishing restrictions that the public and commercial fisherman have been tasked with. Their dominance illustrates the general situation in addressing the management of this watershed. Not nimble and no hammer. Comment Noted - Letter sent to Division of Marine Fisheries North Carolina Coastal Federation Nutrient levels that are too high in the Chowan River have a direct impact on water quality and fisheries habitats both within the river and the downstream sound. This was recognized by DEQ's Nutrient Criteria Development Plan which links the Chowan and Albemarle Sound. This linkage between water quality in the river and to downstream impairments should be documented in the basin plan. Comment Noted - We are currently working on the Pasquotank River Basin Plan and the story map will be a linkage between the two plans. Chowan River Basin Citizens By all rights this plan should be a strategic plan. Such quantified goals with related timelines can and should be developed as arguably the most important part of this draft plan for the Chowan River Basin. We recommend that after such goals are added to this plan, that it be recirculated for further comments. We are confident that the interest in such a complete strategic plan will be huge, and that all stakeholders will feel a special obligation to do their parts to help insure that the goals are achieved. Comment Noted - The Chowan River Basin Plan is just the first step in developing a strategic plan and before we begin on strategic planning we will have to account for all the various sources in the area and determine which factors are contributing to the change in the ecosystem. Green AP I would like the plan you are making to ensure that these waters will sustain life and livelihoods for another 300 years. To do so effectively, the plan must have specific goals and timelines. I do not see that there is enough rigor as-is and I hope you will make the correction. Comment Noted - The Chowan River Basin Plan is just the first step in developing a strategic plan and before we begin on strategic planning we will have to account for all the various sources in the area and determine which factors are contributing to the change in the ecosystem. Chowan Edenton Environmental Group The Chowan River Basin Plan is a dynamic document that carries many excellent recommendations for action to protect the valuable water resources of this river and surrounding waterways, but does not include a plan for implementation. The Chowan Edenton Environmental Group is willing to work collaboratively with NCDEQ Division of Water Resources, our county, state and federal legislators, research institutions, local businesses and concerned citizens to assure this plan becomes a guiding document for immediate action. The Chowan River cannot afford to wait another 10 years for these recommended actions to become reality. We expect, from NCDEQ, an organized action plan as part of this 10-year basin plan with workable timeline and proposed budget for implementation of the many recommendations. Comment Noted - The Chowan River Basin Plan is just the first step in developing a strategic plan and before we begin on strategic planning we will have to account for all the various sources in the area and determine which factors are contributing to the change in the ecosystem. Southern Forests Conservation Coalition SFCC also requests the CRBP include a statement of purpose (the reason for which something is done or made) and statement of intent (something planned), to clearly and unequivocally acknowledge the CRBP has everything to do with protecting the health and wellbeing of people who benefit from ecosystem services provided by Chowan River Basin’s creeks, freshwater marshes, coastal swamp forests, and other habitats that clean our air and water while also protecting a community’s characteristic natural heritage. While a plan in name, the CRBP will be a more relevant tool for regulatory agencies if the plan includes meaningful goals and measureable objectives. Comment Noted - Basin Planning is explained with a general statue and session law links that acknowledges the reason and intent. Community Comments and Strategic Planning Chowan River Basin Water Resources Plan - Public Comment Responses 2 2/18/2021 E3 North Carolina Coastal Federation This basin plan should address the issue of declining aquatic grasses in the Chowan River and Albemarle Sound caused by downstream flows containing high nutrient levels from the Chowan River. The plan should recommend that this issue be addressed as part of DEQ's Triennial Review. Aquatic habitats such as submerged aquatic vegetation in Albemarle Sound are a protected "existing use" under federal and state Anti-degradation policies. This plan should recommend that the waters in the Chowan (as well as Albemarle Sound) be listed as legally impaired on the state's 303(d) list because of the loss of aquatic grasses which is a violation of the state's Ant-degradation Policy. In addition, action is needed to either revise the Chlorophyll-a standard and/or devise more effective management measures to reduce nutrients to prevent future blooms as well as to recover downstream aquatic grasses. Work should begin immediately to reduce nutrient inputs by any practical and cost-effective means possible. Comment Noted - We did the best we could to bring as many comments as possible into the plan. Many of the comments related to nutrients, chlorophyll a, etc. will likely be addressed as part of the NCDP process. Additionally, these comments are also addressed in the CHPP SAV issue paper, which similarly recommends the NCDP SAC consider these issues. The SAV issue paper is part of the CHPP Plan updates and will be before the commission for action in fall 2021. North Carolina Coastal Federation DEQ should use this existing authority to address this urgent water quality impairment by asking the N. C. Environmental Management Commission to direct it to develop a watershed management plan for the Chowan River hydrologic unit. This plan should determine the extent that hydrology has been modified since November 28, 1975 (the date that existing uses are protected pursuant to the Clean Water Act). Based upon these estimates of changes in the volume and rate of runoff, the plan should then identify cost-effective management measures that seek to restore or replicate natural hydrology to the maximum extent practicable. Comment Noted - Stakeholders can seek funding through 205j and/or other grant opportunities mentioned in Chapter 6 of this plan Chowan Edenton Environmental Group No mention has been made Chapter 4 about the invasive hydrilla that plagued the shorelines of the lower Chowan for better that 5 years (the hydrilla disappeared when the cyanobacteria blooms reappeared in 2015). As a monoculture, the growth and proliferation of hydrilla replaced any native aquatic vegetation growing in shallow shoreline waters. To date, most of old hydrilla beds have little or no growth of aquatic vegetation. Comment Noted - SAV and Hydrilla section added to the plan Gary Perlmutter Text edits Comment Noted - Text edits were added to the plan Chowan Edenton Environmental Group A date on Figure 7.1 would be a good addition.Comment Noted - Text edits were added to the plan Chowan Edenton Environmental Group Chapter 6 – Chowan River Basin Plan Funding and Initiatives Comment Noted - Text edits were added to the plan North Carolina Farm Bureau Federation, INC.Please revise the description of BMPs in the box in Chapter 1 to appropriately describe BMPs.Comment Noted - Text was changed in the plan North Carolina Farm Bureau Federation, INC.Explanatory paragraph for the Poultry and Hog sections in this Appendix are also confusing Comment Noted - Text was changed in the plan North Carolina Farm Bureau Federation, INC.Contains confusing language about the number of hog farms Comment Noted - Text was added to the plan North Carolina Farm Bureau Federation, INC.DEQ should add a column that shows the number of hog farms with DEQ permits in each county.Comment Noted - Text was not changed as it might cause confusion North Carolina Farm Bureau Federation, INC.Please correct this error and revise the text to correctly describe why agriculture is considered a nonpoint source.Comment Noted - Text was changed in the plan Full Circle Crab Company, INC. It is incumbent on us to ask for the truth, get good believable science, and demand of our elected officials the necessary financial and political will to prioritize the life of our waters.Comment Noted - Letter sent to Division of Marine Fisheries Chowan River Basin Citizens Rally your NC Department of Environmental Quality, our NC Legislature, local governments in the basin, environmental organizations and ordinary citizens to take actions to protect the Chowan and the Albemarle.Comment Noted Awareness for Financial and Protection Efforts by Elected Officials SAV and anti-degradation Community Text Edits Chowan River Basin Water Resources Plan - Public Comment Responses 3 2/18/2021 E4 Lloyd Webb buffers to protect the river Comment Noted - Kept the recommendation currently in the plan "Consider implementation of nonpoint source management strategies (e.g. buffer rules) analogous to those in other nutrient-impaired watersheds."  More robust water quality monitoring technology for the water in the Chowan and Albemarle sound.1 Comment Noted - We agree as resources are available Equal emphasis on fresh waters of the Albemarle Sound system versus the water quality and marine habitat in the saltwater sounds of NC.1 Comment Noted - We are developing the Pasquotank River Basin Plan in the near future. North Carolina Farm Bureau Federation, INC.2 Establishment of new ambient monitoring station, and an increased understanding of Virginia impacting water quality and water quantity should be a priority for DEQ prior to any new regulations or implementation of a nutrient management strategy.2 Comment Noted - We agree as resources are available Laura Smith3 The state should increase funding for monitoring so that they can pinpoint where problems are arising.3 Comment Noted - We agree as resources are available Lloyd Webb4 more funding for monitoring4 Comment Noted - We agree as resources are available Concerns of AMS/RAMS sampling and the amount of sampling.5 Comment Noted - We agree as resources are available It is a suggestion that there might be an intermediate designation to alert DWR of potential problematic areas within a watershed. Many of the waterways (large and small) experience a large variance in conditions, so that the once a month AMS sampling may not be capturing the true nature of the water quality at a sample location. Perhaps, an informal survey or assessment should be conducted to assure that these waters with potentially elevated fecal coliform counts are not being used for extended human contact in recreational activities.5 Comment Noted - The EMC develops the listing methodology. Fecal coliform assessments where there is greater than 20% excursion rate or the geometric mean is greater than 200 in monthly data over the 5-year period are placed in Category 3. It appears that turbidity in some locations may be need to be monitored more frequently to protect habitat for the aquatic plants and animals.5 Comment Noted - We agree as resources are available Chowan Edenton Environmental Group5 Would it be possible for local communities’ citizen scientists to aid in identifying areas for monitoring and restoration?5 Comment Noted - Yes, they can help to identify areas. This can be achieved through a local program which involves monitoring. Chapter 6 of the plan has information on ways to get involved. Chowan Edenton Environmental Group The state needs a more refined way of verifying citizen fish kill reports – some could be small incidents, but others could be significant. Who is checking? Comment Noted - Fish kill reports were have been drafted through 2019 which include Citizen Reports and DWR Fish Kill Reports and going forward DWR will be referring the public to a website dashboard which will be available soon. Buffers Chowan Edenton Environmental Group5 Laura Smith Comment Noted - Kept the recommendation currently in the plan "Consider implementation of nonpoint source management strategies (e.g. buffer rules) analogous to those in other nutrient-impaired watersheds."  Cypress Group of the NC Sierra Club North Carolina Farm Bureau Federation, INC. NCFB opposes mandatory buffers on land used for agriculture purposes. If necessary, installation of such mandatory buffers may be appropriate only when land use changes, for example from agriculture to development. Also, we oppose a requirement to maintain existing buffers on agricultural land. If a regulatory program were to require maintenance of existing buffers, landowners should be able to install equivalent controls if some part of the buffer is removed. Comment Noted - Kept the recommendation currently in the plan "Consider implementation of nonpoint source management strategies (e.g. buffer rules) analogous to those in other nutrient-impaired watersheds."  Fish Kills Cypress Group of the NC Sierra Club1 Ambient Monitoring Regulations that were developed some twenty years ago required a buffer zone of at least 50 feet. This requirement was systematically altered as part of legislative "regulatory reform" so that now trees of economic value can be cut down right up to the river’s edge. It is time for basin-wide riparian buffers of at least 50 feet. Comment Noted - Kept the recommendation currently in the plan "Consider implementation of nonpoint source management strategies (e.g. buffer rules) analogous to those in other nutrient-impaired watersheds."  Chowan River Basin Water Resources Plan - Public Comment Responses 4 2/18/2021 E5 Chowan Edenton Environmental Group The only Chowan Basin Story Map that we are ale to find on the web does not include permits, streams, etc.Comment Noted - StoryMap was created Chowan Edenton Environmental Group Consider sharing (perhaps with an interactive GIS) specific datasets on the story map for the Chowan Basin so that an interested citizen could not only understand changes but could track changes over time. Comment Noted - Attempted to incorporate an interactive dashboard into the StoryMap although hurdles were encountered and we are working hard to continue to move forward to create this interactive feature in the StoryMap. Chowan Edenton Environmental Group Ammonia is MW-08 near Avoca, what would be the potential source of that Ammonia? Would it be possible to include link to a map showing the position of these groundwater wells by Avoca?Comment Noted - Information added to the StoryMap Chowan Edenton Environmental Group Since most of public probably is not aware of conservation lands and natural heritage areas, a map or a web link reference to these lands could be included. Comment Noted - Information added to the StoryMap We question if sampling for coliform bacteria is being done once a month at the regular AMS stations; does any sampling for fecal coliform occur near the shoreline areas in this basin?1 Comment Noted - AMS/RAMS stations do sampling fecal coliform. The AMS/RAMS program does not explicitly sample fecal near the shorelines. In reviewing the DMF enterococci bacteria sampling there are no sites in the Chowan. DHHS does not have any permanent sampling locations. Local health departments might know or university researchers would be investigating this topic. Category 3 states there is insufficient available data and/or information to make a use support determination. Are we ignoring a potential problem with high coliform counts by indicating that there is insufficient data? As local citizens who use these waters for recreation activities we are concerned that this could be a public health problem.1 Comment Noted - Currently the EMC develops the listing methodology. Fecal coliform assessments where there is greater than 20% excursion rate or the geometric mean is greater than 200 in monthly data over the 5-year period are placed in Category 3. A comprehensive study of the number and quality of local septic systems that have the potential to contaminate groundwater or surface water needs to be conducted in the Chowan River basin particularly the lower basin where the older waterfront communities.1 Comment Noted - Conversastion started with Department of Health and Human Services to discuss these comment and their concerns. The 1990 census data is out-of-date. We are concerned that these numbers have changed. Is there a way to monitor what might type of pollutants might be moving through groundwater and directly into the local waterways?1 Comment Noted - Conversastion started with Department of Health and Human Services to discuss these comment and their concerns. Activity reports (i.e. new systems, repaired systems, etc.) are uploaded to the DHHS website from the counties, but Chowan Bertie, and Gates have not reported out on those. The activity reports also might be over-estimating. The best way to get this information is to contact the local health departments. As it relates to your questions researchers would be the ones working on that question. North Carolina Farm Bureau Federation, INC.2 If septic systems are failing, the answer should be incentives and adequate financial and technical assistance to address the problem – either through repair, management, or alternative systems, -- rather than through regulation.2 Comment Noted - Conversastion started with Department of Health and Human Services to discuss these comment and their concerns. Text was changed in the plan. Chowan Edenton Environmental Group1 Story Map Septic Systems Chowan River Basin Water Resources Plan - Public Comment Responses 5 2/18/2021 E6 Chowan Edenton Environmental Group Outcomes in testing private wells for chemical contaminants. How can the public access the data from well testing or is this data private between the land owner and DHHS? Comment Noted - Conversastion started with Department of Health and Human Services to discuss these comment and their concerns. The private well sample results are housed on the NC State Lab’s website (https://celr.ncpublichealth.com/environmental). They are working on tools to track data and trends, but they do not have a tool yet. Information added to the plan. Chowan Edenton Environmental Group Does the state monitor any well contaminants for movement through the groundwater to streams? Comment Noted - NCDEQ does monitor ambient surface water and groundwater, but do not monitor well contaminants for movement through groundwater to streams. Chowan Edenton Environmental Group Have the number of residential groundwater wells/basin population changed from the 2015 data that is used in the basin plan? Comment Noted - Per the estimated county populations available from OSBM, 4 of the 5 counties in the basin are showing a decrease in 2018 and 2019 estimated population. Gates is the only county showing a slight increase (3%) between 2015 and 2018. Chowan Edenton Environmental Group In our opinion, to continue to say (as from the 2018 IR reports) that the water quality in the Chowan River at stations D8356200 and D8950000 is Meeting Criteria is misleading and irresponsible.Comment Noted - Changes incorporated into the plan Chowan Edenton Environmental Group If the lower Chowan has seen a shift in average surface water temperatures from 1981 – 2015, it would be good to know what the temperature status is from 2015 to 2019. Is the same statistical trends holding? Comment Noted - Numbers were updated and changes were incorporated into the plan Chowan Edenton Environmental Group We need to understand more about how and why patterns of increased conductivity (from an encroaching salt wedge) change.Comment Noted - Vertical profiles of salinity were incorporated into the plan. Explanation about salt water movement included in the plan. Ulrich and Mary Alsentzer We would like to express our concern regarding the described ill effects of non-point source pollution in the basin which contribute directly to the impairment of the waterways and swamps in the watershed area.Comment Noted Michael O’Driscoll I was thinking that one aspect that may help for a future meeting would be to see how some of the important water quality variables like nutrients, turbidity and chla vary over time vs discharge (maybe at one of the lower sites on the Chowan). Comment Noted Lloyd Webb We want to see more enforcement of pollution violations Comment Noted Surface Water Drinking Water Wells Chowan River Basin Water Resources Plan - Public Comment Responses 6 2/18/2021 E7 Chowan Edenton Environmental Group It would be of interest to know what the current status of the base flow and recharge rate is in this system since so much of our local economy is dependent on a healthy water supply from the surface aquifers. Comment Noted - In order to better understand base flow and recharge rates, more gages are required as well as monitoring stations North Carolina Farm Bureau Federation, INC.NCFB opposes DWR mandating farmers to install on-farm monitoring of groundwater, either on crop field or at animal operations.Comment Noted - No edits/changes to the plan were made Chowan Edenton Environmental Group Without question, the ability to understand local and specific agricultural water withdrawal is essential to protecting our water resources. It seems that we have little understanding about how much water is being removed from the groundwater system, what the recharge rates may be, or the impact of any changes in water quality within these surface water supplies (no data is reported from Agricultural water use in Bertie and Chowan counties). Nor, do we have data on what types of chemicals or other dissolved particles such as algal toxins may be moving laterally within the groundwater supply ending up in the streams and rivers or vice versa. According to a recent local interview with Chowan County, dewatering has occurred in both county and town wells, yet there is little data reported about dewatering in this plan. Much more needs to be done regarding a better understanding of our finite water supply– the suggestions in this Basin Plan need to be taken seriously. Comment Noted North Carolina Farm Bureau Federation, INC.The plan calls for a mandatory water use permitting program Comment Noted - Text was changed in the plan North Carolina Farm Bureau Federation, INC.There exists a misunderstanding of agricultural water use in North Carolina Comment Noted - DWR will continue to work collaboratively with federal, state, and local agencies as well as stakeholders in the basin to identify information sharing opportunities to understand and protect water use for all users in the Chowan River basin. North Carolina Farm Bureau Federation, INC. Chapter 8, page 1…fails to include a collaborative program by DEQ and NC Department of Agriculture & Consumer Services to collect information on agricultural water use.Comment Noted - Added text to the plan Chowan Edenton Environmental Group Local Water Supply Plans may not include any seasonal water supply use from the summer beacon communities at Arrowhead and Chowan Beach and the number of residential groundwater wells compared to the basin population has probably changed since the 2015 data use for this draft plan. Comment Noted - The footnote at the bottom of table 8.3 that reads "Population reported as year-round. It does not include seasonal population reported for Murfreesboro." The 2018 LWSP has seasonal population of 1,520 with an increase of 30 noted for 2020 and a 50 person increase for each subsequent year (2030, 2040, 2060). The LWSP reports the amount of water used on an annual basis and determines if existing and current needs are being met. Available water supply in 2018 was reported as 2.19 MGD with a demand of 0.376 MGD. The 2018 LWSP indicates that they plan to bring another ground water well online in 2019. Future projections indicate there is enough supply to meet demand through 2060 even with the seasonal population. Chowan Edenton Environmental Group Drought conditions or excessive rainfall from 2008 – 2020. There should be an examination of any correlation between drought and/or rainfall events to the extent and severity of algal blooms in the lower Chowan Basin? Commented Noted - Recommendation notes this concern "Investigate possible temporal relationships between stream flow and chlorophyll a concentrations. Understanding the correlation between stream flow and chlorophyll a concentrations could assist local agencies with forecasting the intensity of algal bloom that may occur." Chowan Edenton Environmental Group The suggestion in this basin plan needs to be taken seriously about understanding how much water is being removed from the groundwater system, what the recharge rates may be, or the impact of any changes in water quality within these surface water supplies. Comment Noted - Comment sent to Water Supply Planning Branch. North Carolina Farm Bureau Federation, INC. Establishment of new ambient monitoring station, and an increased understanding of Virginia impacting water quality and water quantity should be a priority for DEQ prior to any new regulations or implementation of a nutrient management strategy.Comment Noted Water Quantity Water Use Groundwater Chowan River Basin Water Resources Plan - Public Comment Responses 7 2/18/2021 E8 Chowan Edenton Environmental Group The CHPP referenced in Chapter 6 should include specific strategies for outreach education including ways to reach K-12 students and teachers. Comment Noted - Conversastion started with Coastal Habitat Protection Team and DWR Education and Outreach to discuss these comments and their concerns. Chowan Edenton Environmental Group From Chapter 6, it is clear that the NCFS provides a good way to assure that timber harvest includes a positive environmental component. More publicity and awareness of the NCFS stewardship plan opportunities would likely increase participation in this program. Comment Noted A similar question comes from the reporting in Appendix v-III – do these poultry operations all count as one operation if they are contracting with a large industry such as Perdue?1 Comment Noted - Our understanding is that each operation is separate even if owned by the same operator or integrate. While dry-litter application from poultry operations does have specific regulations, there is no explanation of how these regulations may be monitored for compliance.1 Comment Noted - Revisions to the plan occurred and were discussed with Division of Water Resources leadership. Since the CEEG members live in Chowan County, we see more and more chicken farms being constructed (3-4 barns at a time) in Chowan County (not sure about the other counties in the basin), and it seems that no maps or tables are capturing these changes.1 Comment Noted - Revisions to the plan occurred and were discussed with Division of Water Resources leadership. Laura Smith2 We also need closer monitoring of chicken farms to make sure they are not over-applying waste and contributing to nutrient and bacteria pollution.2 Comment Noted - Revisions to the plan occurred and were discussed with Division of Water Resources leadership. Lloyd Webb3 closer tracking of chicken farms3 Comment Noted - Revisions to the plan occurred and were discussed with Division of Water Resources leadership. North Carolina Poultry Federation The Federation takes particular issue with the "Agricultural Best Management Practices (BMPs) and Waste Management Recommendations" as found on page 17 of the Executive Summary. Specifically, the recommendation that NCDEQ should evaluate existing regulatory requirements for poultry operations, particularly the recommendation regarding implementation of any kind of further registration program, is not necessary or advisable. Comment Noted - Revisions to the plan occurred and were discussed with Division of Water Resources leadership. North Carolina Farm Bureau Federation, INC. NCFB disagrees with the recommendation in the Executive Summary and elsewhere that increased regulation of poultry operations is needed. Comment Noted - Revisions to the plan occurred and were discussed with Division of Water Resources leadership. Chowan Edenton Environmental Group1 Education and Outreach Public Engagement Beth Roach - Alliance of Native Seedkeepers, North Carolina Commission on Indian Affairs, Woman's Earth Alliance and Sierra Club, VA Chapter of the Sierra Club, Nottoway Indian Tribe of VA Animal Operations Comment Noted - Started a conversation to discuss further actions and stakeholder engagement. I have been deeply interested in the Chowan River Basin as it relates to our tribal communities within it and with regards to how this watershed crosses state lines. Our tribe engages in annual river cleanups and paddles. We are very interested in learning how to be even better partners with river stewardship. I work with the Meherrin and Tuscarora folks in this watershed and would love to see us engage in dialogue around the health and history of the watershed. I would love to see how our stories can be interwoven with future plans for the watershed. In the spring, we will have a skills building workshop that will hopefully lead to a pilot project in the next phase. This initiative is studying coastal adaptation plans in tribal communities throughout the US. A great first step could be hosting a talk with interested tribal members to share what your office does and how we can become involved. The waters carry deep meaning for all of us and we would benefit from mutual dialogue and understanding. Please let me know how we can proceed forward together! Chowan River Basin Water Resources Plan - Public Comment Responses 8 2/18/2021 E9 Laura Smith There should be full watershed modeling to help figure out where the pollution is coming from and what scenarios will best address it. The modeling should include the Virginia portion of the watershed with close attention paid to older point sources/leaky sewer pipes and ag/forestry non-point sources. Comment Noted Melody White Concerns regarding permit no. NC0032719 and the discharge location.Comment Noted - The letter was sent to the NCDEQ Washington Regional Office Melody White Massive blooms plagued the river May 2019 - Sept 2019, May 2020 green color, July 2020 light blue color concentrated color to Cannon's Ferry and extending to Arrowhead Beach and beyond.Comment Noted Laura Smith Our time on the river is extremely limited due to frequent harmful algal blooms.Comment Noted Chowan Edenton Environmental Group This region has an economic dependence on water; farming and fishing are a way of life for many. The Chowan River is an ecotourism attraction for boaters and other recreational water activities. The severe cyanobacteria blooms over the past few years have challenged what was assumed to be relatively stable ecosystem. We are greatly concerned about the potential effects of long-term water quality degradation in the Chowan River on the economy and on our way of life. Comment Noted Lloyd Webb In the last 5-7 years, we have seen an increase in algae near the mouth of the Chowan River. The more algae, the less we can fish and swim with our children and grandchildren...The algae has appeared to caused death to turtles we found many shells on the shoreline. When it is at it’s peak of bloom the shoreline is often blue green and with a white foam these conditions cause a foul smell. Comment Noted Elizabeth City State University Please consider apply unmanned aircraft vehicle (UAV) to monitor the water quality of the Chowan River.Comment Noted Elizabeth City State University Please consider apply satellite remote sensing to monitor water quality of the Albemarle Sound.Comment Noted Chowan Edenton Environmental Group The agricultural cost-share program outlined in Chapter 6 is an excellent way to help farmers save money while, at the same time, reducing nutrients (N and P) applied to the land. Table 6-6 shows that from 2015 to 2020 considerably less acres in the Chowan and Meherrin HUC's were impacted by BMP's compared to the earlier 5 year period, and thus, a much reduced period showed almost 3 times as much waste nitrogen managed and 2.5 times waste Phosphorus managed. Where is this waste N and P coming from – an explanation would provide greater understanding of this issue. Comment Noted - Waste management BMPs are required to report the amount of waste N and P managed as part of the cost share contract. Waste management BMPs include animal waste storage structures, manure composting, odor control management, manure/litter transportation incentive, lagoon biosolids removal, etc. A list of waste management BMPs funded through the NC Agriculture Cost Share Program (ACSP) can be found here: https://www.ncagr.gov/SWC/costshareprograms/ACSP/documents/Waste_Mgmt_c onservation_effects.pdf North Carolina Farm Bureau Federation, INC. The plan should recommend: Provide sufficient funding for adequate technical assistance and for voluntary implementation of BMPs through the NC Ag Cost Share Program and other federal and state cost share or grant opportunities.Comment Noted - Added text to recommendations section North Carolina Farm Bureau Federation, INC. Additional funding for voluntary implementation of the BMPs themselves, either through cost-share or grants. This should be in addition to the call for additional DSWC staff and should include funding for local soil and water conservation district staff.Comment Noted - Added text to the plan Agriculture Algal Blooms Valhalla WTP Watershed Modeling Chowan River Basin Water Resources Plan - Public Comment Responses 9 2/18/2021 E10 North Carolina Farm Bureau Federation, INC. Identify how to best capture water quality data and BMP benefits to model nutrient load throughout the entire basin. (This recommendation seems to be misplaced and perhaps should be in the Interstate Cooperation recommendations. NCFB does support additional work to quantify the benefit of ag and forestry BMPs. Comment Noted - Recommendation moved North Carolina Farm Bureau Federation, INC. Identifying and expanding educational opportunities to work with private land owners, hiring additional Division of Soil and Water Conservation (DSWC) staff, promoting BMPs to reduce phosphorus loading, and encouraging the use of nutrients management plans. NCFB supports these activities as long as the implementation of the practices by farmers and forest landowners remains voluntary. Comment Noted North Carolina Farm Bureau Federation, INC. Regarding the implementation of the nonpoint source management strategies recommendations on page 25 of the Executive Summary, we oppose farmers in a watershed having to adopt a group of mandated farm BMPs, but would support a voluntary program. If it is found to be necessary to implement nonpoint source management strategies in the Chowan Basin, we would recommend continuing the successful program of farmers sharing compliance through local advisory committees when needed to meet water quality goals, such as is in place in the Neuse and Tar Pamlico basins. Comment Noted - No edits/changes made to the text; however, added DSWC as a participant for the recommendation. North Carolina Farm Bureau Federation, INC. Regarding the implementation of the nonpoint source management strategies recommendations on page 25 of the Executive Summary, we oppose farmers in a watershed having to adopt a group of mandated farm BMPs, but would support a voluntary program. Comment Noted - No edits/changes made to the text; however, I added DSWC as a participant for the recommendation. North Carolina Farm Bureau Federation, INC. There should be added to the draft Plan…a discussion of the important role of the NCDP Criteria Implementation Committee (CIC) to review and advise DWR and DEQ on practical aspects and the fiscal impact of implementation of any proposed nutrient criteria. Comment Noted - No edits/changes made to the text; The NCDP section focuses on the development of nutrient criteria. The CIC is involved in understanding issues around implementation of a new criteria. This topic would make the discussion more complicated than necessary. A link to the website is provided for more information on the whole process. North Carolina Farm Bureau Federation, INC. NCFB opposes DWR mandating farmers to install on-farm monitoring of groundwater, either on crop fields or at animal operations.Comment Noted North Carolina Farm Bureau Federation, INC. As funding permits, DEQ should work with these towns through the Division of Water Infrastructure to upgrade the water and wastewater infrastructure and reduce potential impacts to the Chowan basin. Comment Noted - Added to Non-Discharge Permitted Facilities BMP section of Chapter 7 and referred reader to chapter 6 for more information about DWI grants. North Carolina Farm Bureau Federation, INC. "Maximize implementation of filter strips on agricultural land." We oppose this recommendation as written, because it implies a mandatory requirement for installation of filter strips.Comment Noted - Text was changed in the plan Agriculture Chowan River Basin Water Resources Plan - Public Comment Responses 10 2/18/2021