HomeMy WebLinkAboutAgenda - 03-12-2013 - 2ORANGE COUNTY
BOARD OF COMMISSIONERS
ACTION AGENDA ITEM ABSTRACT
Meeting Date: March 12, 2013
Action Agenda
Item No. 2
SUBJECT: Upper Neuse River Basin Association /Falls Lake Watershed Rules
DEPARTMENT: Environment, Agriculture,
Parks and Recreation
(DEAPR)
ATTACHMENT(S):
A. Falls Lake Watershed Map
B. List of Recommended Future
Monitoring Studies
C. The Consensus Principles
D. UNRBA Funding Spreadsheets
PUBLIC HEARING: (Y /N) No
INFORMATION CONTACT:
David Stancil, 245 -2510
Tom Davis, 245 -2510
Gail Hughes, 245 -2753
1
PURPOSE: To inform the Board of current and planned activities of the Upper Neuse River
Basin Association ( UNRBA).
BACKGROUND: The Falls Lake Nutrient Management Strategy (Falls Lake Rules) became
effective in January 2011. These rules require significant reductions in the amounts of nitrogen
and phosphorus entering Falls Lake from sources in the watershed including agriculture,
wastewater treatment plants, State and Federal facilities, and existing and future development
(Attachment A).
Compliance with these rules is projected to be extremely expensive, with the majority of the
expense anticipated to be borne by local governments in the Falls Lake watershed, mainly to
comply with the regulations involving wastewater treatment plants and existing development
(urban stormwater). Considerable expenditures will be needed during Stage II of the nutrient
reduction process (2021 -2036) to meet the overall reduction goals established in the rules —
40% reduction in nitrogen and 77% reduction in phosphorus runoff.
The members of the UNRBA, including Orange County, remain committed to the protection of
the Falls Lake water supply for the City of Raleigh. However, the fiscal analysis prepared by the
North Carolina Division of Water Quality (DWQ) during the development of the Falls Lake Rules
estimated the total cost to comply with the rules as written would be approximately $1.5 billion
dollars.
In addition, many people consider the required nutrient reductions unattainable at nearly any
expense. The Falls Lake Rules include provisions for the Environmental Management
Commission (EMC) to consider additional information starting in 2020 for the re- examination of
Stage II of the rules. In 2011 the UNRBA hired a consultant "for the development of methods
by which the regulatory framework associated with the recently adopted Falls Lake Nutrient
Management Rules can be evaluated ". This consultant, CardnoEntrix, recently completed four
technical reports to begin the process of analyzing available means for altering Stage II of the
Falls Lake Rules. These reports, completed during the initial phase of what has been termed
"The Path Forward" process, are as follows:
1. Develop Framework for a Re- examination of Stage II of the Falls Nutrient Strategy
2. Review Existing Data and Reports for Falls Lake and the Watershed
3. Estimation of Nutrient Loading to Falls Lake
4. Review of Existing Models and Recommendations for Future Studies
These reports summarize existing water quality information for Falls Lake and the surrounding
watershed, evaluate the lake modeling that DWQ completed during the development of the
Falls Lake Rules, assess other available models for representing the lake and watershed,
investigate the regulatory "framework" that guides water quality issues in North Carolina, and
detail a "roadmap" for the UNRBA to pursue in order to modify Stage II of the Falls Lake Rules.
As a result of this process, CardnoEntrix has provided the UNRBA a draft list of studies that are
recommended for completion in order to gain necessary information for incorporation into the
re- examination process (Attachment B).
The ultimate goal of The Path Forward process is to lower the nutrient reduction requirements
of Stage II of the Falls Lake Nutrient Management Strategy, while preserving the water supply
of the City of Raleigh. In addition, the UNRBA is interested in increasing the number of Best
Management Practices (BMPs) that have nutrient reduction credits established by DWQ for
their use. The UNRBA is beginning to work on determining nutrient reduction credits for a large
number of BMPs that should prove to be very helpful for both the agricultural community as well
as more developed urban areas to use in meeting their required nutrient reductions. Without
this work, urban areas would have only a few BMPs available to use in meeting the nutrient
reduction targets. The agricultural community has even fewer BMPs approved for use at this
time. Developing additional BMPs could prove to be extremely beneficial to the agricultural
producers in the Falls Lake watershed.
Given the amount of data that should be collected in pursuit of altering Stage II of the rules, it is
likely that the UNRBA will need to complete multiple studies of Falls Lake and the surrounding
watershed in the next five to ten years.
At this time, the Path Forward Committee of the UNRBA recommends that the studies listed on
Attachment 2 under the objectives entitled "Lake Response Modeling, Support of Regulatory
Options and then Source /Jurisdictional Loading" be completed. The Falls Lake Rules specify
that a minimum of three years of data must be collected to even be considered by the EMC
during the re- examination process. This fact, coupled with the volume of information that is in
need of collection, as well as the 2020 deadline for submitting data, underline the need to
initiate water quality monitoring in the near future.
During the development of the Falls Lake Rules, the majority of local governments in the Falls
Lake watershed adopted a document entitled Consensus Principles to Guide Falls Lake
K
Nutrient Management Strategy (Attachment C). These principles anticipated that local
governments would share the costs of re- examining Stage II of the rules. Item 10 of the
Consensus Principles includes the following:
"The limited resources available to DWQ and DENR for the
implementation of the nutrient management strategy and the need
for a robust and active sampling and monitoring program, as well
as additional modeling, make it desirable for the affected local
governments to share resources and undertake these important
activities, and other activities associated with re- examination of the
Nutrient Management Strategy, collectively. The affected local
governments should share resources and assist with funding for
the examination of the Nutrient Management Strategy"
The Consensus Principles were adopted unanimously by the Board of County Commissioners
on March 16, 2010.
FINANCIAL IMPACT: During FY 2011 -2012, UNRBA dues were doubled for all members.
Orange County's share was increased to $27,546.81. UNRBA dues are apportioned according
to a three -part funding formula (Attachment D). Starting in FY 2013 -14, activities undertaken by
the UNRBA over the next five to ten years to alter Stage II of the Falls Lake Rules will require
substantial funding. As a result, Orange County is being asked to pay dues and special
assessment fees of $68,341.06 for FY 2013 -14. It is likely that even higher fees will be
necessary during FY 2014 -15 since 12 months of water quality monitoring is planned for that
time, while only a partial year of monitoring is anticipated for FY 2013 -14. Staff anticipates that
elevated fees and dues will continue to be requested from each member of the UNRBA over a
period of five to ten years.
While the County and the agricultural community will certainly have to undertake measures to
reduce runoff to Falls Lake, if the Stage II nutrient reduction targets are not reduced and instead
remain as they are currently written, both parties will undoubtedly face greater expenditures
than if changes in the nutrient reduction rules are made.
Similarly, increasing the number of Best Management Practices (BMPs) available to regulated
parties, including the agricultural community and urban areas, is also expected to ease
compliance with the Falls Lake Rules.
RECOMMENDATION(S): The Manager recommends that the Board consider and discuss the
information presented concerning UNRBA activities related to the Falls Lake Nutrient
Management Strategy.
ATTACHMENT A
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Jurisdictional monitoring
X
X
Areal loading rates
X
Internal Lake Loading
X
X
X
Nutrient Fate and Transport
X
X
Lake bathymetry and flow data
X
X
Tributary monitoring
X
X
Storm event sampling
X
In -lake processes
X
X
Lag time
X
X
BMP implementation tracking
X
X
Diurnal pH and DO monitoring with water quality sampling
X
X
Fish monitoring with water quality sampling
X
X
Terrestrial and avian species monitoring
X
X
Recreational data and water quality sampling
X
X
Event based water quality sampling
X
X
Estimation of loading from onsite wastewater treatment systems
X
X
Streambank erosion and nutrient loading
X
X
Tracking BMP inspections and repairs
X
X
ATTACHMENT C
CONSENSUS PRINCIPLES TO GUIDE
FALLS LAKE NUTRIENT MANAGEMENT STRATEGY
Falls Lake is currently classified by the North Carolina Environmental
Management Commission (EMC) as WS -IV, B: NSW, CA. Pursuant to this
classification, the designated uses of Falls Lake include aquatic life propagation
and biological integrity (including fishing and fish), wildlife, primary and
secondary recreation, agriculture, and water supply. Falls Lake serves as a water
supply for the City of Raleigh (Raleigh) and six other municipalities in Wake
County.
2. The EMC has established a water quality standard for chlorophyll -a of 40 ug/L to
protect the designated uses of all waters in the state, including Falls Lake.
3. Since the time it was constructed, portions of Falls Lake have experienced
nutrient conditions that have contributed to monitored exceedances of the
chlorophyll -a standard. In 2005, the General Assembly directed the EMC to
develop a nutrient management strategy for Falls Lake. The legislation was
amended so that the nutrient management strategy and implementing rules are to
be established no later than January 15, 2011.
4. In 2008, the Division of Water Quality (DWQ) found that the chlorophyll -a levels
at certain locations in Falls Lake exceeded the water quality standard. The EMC
found, in the 2009 Neuse Basin Plan, that new nutrient management measures
were needed to address nutrient - related problems in Falls Lake.
5. The level of nutrient loading reductions necessary to protect and improve water
quality in Falls Lake make it appropriate to establish a two -stage nutrient
management strategy — the first stage (Stage 1) designed to achieve the water
quality standard for chlorophyll -a in the lower lake below Highway 50 (Lower
Lake), where the water supply intake is located, and to improve water quality in
the upper lake above Highway 50 (Upper Lake), and the second stage (Stage 2)
designed to further address water quality in the Upper Lake.
6. The first stage of nutrient loading reductions and protection measures for Falls
Lake, as described below, are designed to achieve sufficient improvements in
water quality to result in the removal of the Lower Lake from the 303(d)' list of
impaired waters by 2021.
7. The Stage 1 management measures should include reductions in loading from all
major categories of sources including point sources, agriculture and other
fertilizer using activities, new development, and existing development.
a Under Section 303(d) of the U.S. Clean Water Act, waters of the state that have water quality violations
resulting in the failure to meet the designated and protected uses are designated as "impaired ".
7
Consensus Principles
February 9, 2010
Page 2 of 4
a. Point Sources: Large point sources as a group should be required to
achieve by 2016 a 20% reduction in 2006 nitrogen loads and a 40%
reduction in 2006 phosphorus loads. The allowable mass load for these
point sources should be allocated among them based on 110% of current
flows.Z Smaller point sources should be required to meet limits of
technology by 2016.
b. New Development: As soon as is reasonably feasible, and no later than
eighteen months after adoption of rules by the EMC, new development
throughout the Falls watershed should be required to meet a nitrogen
annual loading limit of 2.2 pounds per acre and a phosphorus annual
loading limit of 0.33 pounds per acre, a portion of which may be achieved
through offset payments.
c. Existing Development: No later than three years after adoption of the
rules by the EMC, all jurisdictions throughout the Falls watershed should
be required to begin and continuously implement a program to reduce
existing development nutrient loads to 2006 levels within ten years from
adoption of the rules by the EMC.
1. Where septic systems account for more than 20% of the nitrogen
loading in the portion of a subwatershed of Falls Lake within a
jurisdiction (according to DWQ's watershed model), that jurisdiction
should be required, as a part of its Stage 1 existing development
program, to begin and continuously implement a program to reduce
loading from septic systems, discharging into waters of the State
within that jurisdiction and subwatershed, which accounted any part
for nutrient loading for the jurisdiction.
2. A jurisdiction that includes any part of a subwatershed of Falls
Lake in which chlorophyll a levels have exceeded 40 ug/L in more
than 75% of the monitoring events in any calendar year should be
required, as a part of its Stage 1 existing development program, to
begin and continuously implement a program to reduce nutrient
loading into waters of the State within that jurisdiction and
subwatershed.
However, the total amount of nutrient loading reductions in Stage 1 is not
increased for local jurisdictions by the requirement to add specific
program components to address septic loading or high nutrient loading
levels.
d. State and Federal Agencies: State and federal agencies, including but not
limited to DOT, shall be required to reduce nitrogen and phosphorus
loading from new and existing development to a similar degree and within
a similar time schedule as local governments.
z The Consensus Principles rely on, and do not seek any change from, the apportionment of load allocations
as proposed by DWQ in the draft rules issued on January 14, 2010
Consensus Principles
February 9, 2010
Page 3 of 4
8. Stage 2 management measures should be designed to achieve water quality
standards in the Upper Lake and to maintain water quality in the Lower Lake.
The compliance date for achieving all additional reductions from point sources
and agriculture should be no earlier than 2036. Additional existing development
reductions, as determined pursuant to paragraph 9 should begin in 2021 and
should be continuously implemented according to timelines proposed by each
local government in plans periodically submitted to and approved by the EMC,
subject to the limitations on the EMC's authority regarding existing development
criteria contained in the Jordan Lake legislation.
9. The process by which the proposed regulatory scheme has been developed relied
on a limited data base which will be substantially enhanced by a more rigorous
program of sampling, monitoring and analysis. In addition, it may not be feasible
to attain all currently designated uses in the Upper Lake and attempting to do so
may result in substantial and widespread economic and social impact. The EMC
should therefore begin a re- examination of its nutrient management strategy for
Falls Lake by January 1, 2018. The re- examination should consider, among other
things, (i) the physical, chemical, and biological conditions of the Lake with a
focus on nutrient loading impacts and the potential for achieving the Stage 1 goal
by 2021 as well as the feasibility of both achieving the Stage 2 reduction goals
and meeting the water quality standard for chlorophyll -a in the Upper Lake, (ii)
the cost of achieving, or attempting to achieve, the Stage 2 reduction goals and the
water quality standard in the Upper Lake, (iii) the existing uses in the Upper Lake
and whether alternative water quality standards would be sufficient to protect
those existing uses, and (iv) the impact of the management of Falls Lake on water
quality in the Upper Lake. As the first step in the re- examination, a Scientific
Advisory Board should analyze and review the information identified above along
with the additional monitoring and modeling data compiled since the model was
approved and should present its recommendations for changes in the Nutrient
Management Strategy and its implementing rules to DWQ and the EMC by
' Session Law 2009 -216 (the Jordan Lake legislation), at Section 3(d)(2)(f), sets the following limitations
on the authority of the Environmental Management Commission for its review and approval of local
government programs to control nutrient loading from existing development: "The Commission shall
approve the program if it meets the requirements of this subdivision, unless the Commission finds that the
local government can, through the implementation of reasonable and cost - effective measures not included
in the proposed program, meet the reductions in nutrient loading established by the Department pursuant to
sub - subdivision b. of this subdivision by a date earlier than that proposed by the local government. ...In
determining whether additional or alternative load reduction measures are reasonable and cost effective, the
Commission shall consider factors including, but not limited to, the increase in the per capita cost of a local
government's stormwater management program that would be required to implement such measures and the
cost per pound of nitrogen and phosphorus removed by such measures. The Commission shall not require
additional or alternative measures that would require a local government to:
1. Install or require installation of a new stormwater collection system in an area of existing
development unless the area is being redeveloped.
2. Acquire developed private property.
3. Reduce or require the reduction of impervious surfaces within an area of existing development unless
the area is being redeveloped."
9
Consensus Principles
February 9, 2010
Page 4 of 4
January 1, 2019. In light of the report from the Science Advisory Board, the
EMC should direct the DWQ to prepare proposed rule revisions, if any, and an
updated fiscal note on Stage 2 by August 1, 2019. In its development of any
proposed rule revisions, DWQ shall consult with the local governments and other
interested parties. Except to the extent that management measures identified as a
part of Stage 2 are required to achieve the Stage 1 goal, local governments should
not be required to begin implementing Stage 2 management measures without a
determination by the EMC of whether alternative goals and/or standards should
be established for the Upper Lake.
10. Annual monitoring of chlorophyll -a in Falls Lake should be funded and
implemented through a collective effort by all jurisdictions partially or wholly
within the Falls Lake watershed. The limited resources available to DWQ and
DENR for the implementation of the nutrient management strategy and the need
for a robust and active sampling and monitoring program, as well as additional
modeling, make it desirable for the affected local governments to share resources
and undertake these important activities, and other activities associated with the
re- examination of the Nutrient Management Strategy, collectively. The affected
local governments should share resources and assist with funding for the
examination of the Nutrient Management Strategy. The affected local
governments created the Upper Neuse River Basin Association, among other
reasons, as a means to more effectively perform functions related to Falls Lake
and the Upper Neuse River Basin. The Association with an expanded mission
and authority, or some similar organization, should be considered for expanded
duties that the local governments may agree to assume consistent with this
paragraph and paragraph 11 of this document. The results of the additional
monitoring and modeling and other relevant information gathered by the
collective efforts of the local governments should be shared on a regular basis
with DWQ and made available to the Scientific Advisory Board and the EMC in
connection with the review described in Paragraph 9.
11 A robust and innovative trading program among all regulated sources is critical to
the success of the nutrient management strategy for Falls Lake. In addition, local
governments should be able to use any combination of point and nonpoint
control/reduction strategies, including land preservation, within their respective
jurisdictions to meet their overall obligations under the nutrient management
strategy.
Nothing in these principles is intended to imply that the EMC is precluded from
complying with the requirements of federal law.
ATTACHMENT D
UNRBA Revenue Summary FY 2013 -14
Date: 2/19/13
Member
Membership
Dues
FY 2013 -14
Monitoring
Assessment
FY 2013 -14
Total
Amount Due
FY 2013 -14
FY 2012 -13
Membership
Dues Paid
Town of Butner
$ 2,054.55
$ 7,158.72
$ 9,213.27
$ 3,838.00
City of Creedmoor
1,387.01
4,832.80
6,219.81
2,614.00
City of Durham
33,392.50
116,350.17
149,742.67
59,616.00
Durham County
12,776.99
44,519.12
57,296.11
23,091.00
Franklin County
1,641.66
5,720.07
7,361.73
3,096.00
Granville County
9,429.83
32,856.55
42,286.38
17,105.00
Town of Hillsborough
2,558.02
8,912.96
11,470.98
4,670.00
Orange County
15,240.00
53,101.06
68,341.06
27,578.00
Person County
10,496.73
36,573.97
47,070.70
18,996.00
City of Raleigh
39,976.49
139,290.92
179,267.41
72,550.00
SGWASA
4,068.28
14,175.18
18,243.46
7,811.00
Town of Stem
1,084.05
3,777.19
4,861.24
2,095.00
Wake County
8,278.44
28,844.74
37,123.18
14,170.00
Town of Wake Forest
1,115.44
3,886.57
5,002.01
2,151.00
Total
$ 143,499.99
$ 500,000.02
$ 643,500.01
$ 259,381.00
10
UNRBA Membership Dues Calculation for FY 2013 -14
$ 143,500.00 Projected Revenue
Date; 2119/13
Member
Base Rate (10 %)
2012 Raw Water Demands (50 %)
Jurisdiction's Land Area (40 %)
FY 2013 -14 Dues
$ 14,350.00
Member's Sub-
Share of Cost
2012 Average
Raw Water
Demand (MGD)
$ 71,750.00
(%)
Member's
Sub -Share
Cost
Jurisdiction's
Acres Within
Watershed
$ 57,400.00
(%)
Member's
Sub -Share
Cost
Total
Membership
Dues
Town of Butner
$ 1,025.00
NA
8,822
1.8
$ 1,029.55
$ 2,054.55
City of Creedmoor
1,025.00
NA
3,102
0.6
362.01
1,387.01
City of Durham
1,025.00
28.410
40.1
$ 28,781.45
30,728
6.2
3,586.05
33,392.50
Durham County
1,025.00
NA
100,700
20.5
11,751.99
12,776.99
Franklin County
1,025.00
NA
5,284
1.1
516.66
1,641.66
Granville County
1,025.00
NA
72,019
14.6
8,404.83
9,429.83
Town of Hillsborough
1,025.00
1.090
1.5
1,104.25
3,674
0.7
428.77
2,558.02
Orange County
1,025.00
NA
121,805
24.8
14,215.00
15,240.00
Person County
1,025.00
NA
81,161
16.5
9,471.73
10,496.73
City of Raleigh
1,025.00
38.320
54.1
38,821.02
1,118
0.2
130.47
39,976.49
SGWASA
1,025.00
3.004
4.2
3,043.28
NA
-
4,068.28
Town of Stem
1,025.00
NA
506
0.1
59.05
1,084.05
Wake County
1,025.00
NA
62,153
12.6
7,253.44
8,278.44
Town of Wake Forest
1,025.00
NA
775
0.2
90.44
1,115.44
Total
1 $ 14,350.00
70.824
1 99.9
$ 71,750.00
491,847
99.9
1 $ 57,399.99
$ 143,499.99
Notes;
* Cost Allocation = 10% by uniform participation; 50% by raw water demands; and 40% by jurisdictional land area in UNRB,
** 2012 annual daily average raw water demand reported by user systems.
* ** Jurisdictional areas obtained from members, January, 2013. Percentages are calculated based on total basin acres. The towns of Mebane and Franklin have a few acres but not enough to affect percentages. Municipal
acreages do NOT include ETJs (although some municipalities may have some planning jurisdiction in ETJs, they do not collect tax revenue from these properties). SGWASA- and OAWS -owned acreages are included in
their respective jurisdictional areas and are not calculated separately.
UNRBA Monitoring Assessment Calculation for FY 2013 -14
500,000.00 Projected Revenue
Date: 2/19113
Member
Base Rate (10 %)
2012 Raw Water Demands (50 %)
Jurisdiction's Land Area (40 %)
FY 2013 -14 Dues
$ 50,000.00
Member's Sub-
Share of Cost
2012 Average
Raw Water
Demand (MGD)
$ 250,000.00
(%)
Members
Sub -Share
Cost
Jurisdiction's
Acres Within
Watershed
$ 200,000.00
N
Member's
Sub -Share
Cost
Total
Membership
Dues
Town of Butner
$ 3,571.43
NA
8,822
1.8
$ 3,587.29
$ 7,158.72
City of Creedmoor
3,571.43
NA
3,102
0.6
1,261.37
4,832.80
City of Durham
3,571.43
28.410
40.1
$ 100,283.80
30,728
6.2
12,494.94
116,350.17
Durham County
3,571.43
NA
100,700
20.5
40,947.69
44,519.12
Franklin County
3,571.43
NA
5,284
1.1
2,148.64
5,720.07
Granville County
3,571.43
NA
72,019
14.6
29,285.12
32,856.55
Town of Hillsborough
3,571.43
1.090
1.5
3,847.57
3,674
0.7
1,493.96
8,912.96
Orange County
3,571.43
NA
121,805
24.8
49,529.63
53,101.06
Person County
3,571.43
NA
81,161
16.5
33,002.54
36,573.97
City of Raleigh
3,571.43
38.320
54.1
135,264.88
1,118
0.2
454.61
139,290.92
SGWASA
3,571.43
3.004
4.2
10,603.75
NA
-
14,175.18
Town of Stem
3,571.43
NA
506
0.1
205.76
3,777.19
Wake County
3,571.43
NA
62,153
12.6
25,273.31
28,844.74
Town of Wake Forest
3,571.43
NA
775
0.2
315.14
3,886.57
Total
$ 50,000.02
70.824
1 99.9
$ 250,000.00
1 491,847
99.9
$ 200,000.00
$ 500,000.02
Notes:
* Cost Allocation =10% by uniform participation; 50% by raw water demands; and 40% by jurisdictional land area in UNRB.
** 2012 annual daily average raw water demand reported by user systems.
* ** Jurisdictional areas obtained from members, January, 2013, Percentages are calculated based on total basin acres. The towns of Mebane and Franklin have a few acres but not enough to affect percentages. Municipal
acreages do NOT include ETJs (although some municipalities may have some planning jurisdiction in ETJs, they do not collect tax revenue from these properties). SGWASA- and OAWS -owned acreages are included in
their respective jurisdictional areas and are not calculated separately.
N