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HomeMy WebLinkAboutAgenda 02-20-24; 6-b - Orange County’s Proposed 2024 Priority Legislative Issues 1 ORANGE COUNTY BOARD OF COMMISSIONERS ACTION AGENDA ITEM ABSTRACT Meeting Date: February 20, 2024 Action Agenda Item No. 6-b SUBJECT: Orange County's Proposed 2024 Priority Legislative Issues DEPARTMENT: County Commissioners ATTACHMENT(S): INFORMATION CONTACT: Commissioner Jean Hamilton, 245-2130 DRAFT Orange County 2024 Priority Commissioner Amy Fowler, 245-2130 Legislative Issues with Attachments John Roberts, County Attorney, 245- 2318 Bonnie Hammersley, County Manager, 245-2300 PURPOSE: To: 1) review and discuss the proposed Orange County 2024 Priority Legislative Issues and any other potential items for inclusion in Orange County's legislative agenda package for the 2024 North Carolina General Assembly Session; and 2) Consider approval of the Orange County 2024 Priority Legislative Issues document for submittal to Orange County's legislative delegation. BACKGROUND: Orange County's Legislative Breakfast with Orange County's legislative delegation, in conjunction with the 2024 North Carolina General Assembly session, is scheduled for March 21, 2024. The Board of Commissioners has historically approved a set of legislative issues each year for presentation to/discussion with the delegation. The Board historically alo has appointed two members to work with staff on a Legislative Issues Work Group (LIWG) to develop a proposed legislative package for the County. Based on the work of the LIWG, the BOCC then reviewed and approved packages of legislative items to present to Orange County's legislative delegation. Commissioners Amy Fowler and Jean Hamilton are serving on the 2024 LIWG and have worked with staff on the attached 2024 legislative package. As the LIWG considered its approach for this year, the Group (similar to last year) decided to identify a concise list of Legislative Priority Issues. The Group ultimately identified eight (8) Priority Issues, acknowledging that the full Board of Commissioners may consider modifying the list, exchanging one item for another item, other potential revisions, etc. The LIWG also acknowledged Board members' previous comments on potential discussion topics for the Breakfast and has referenced the desire to discuss: • the Upper Neuse River Basin Association's (UNRBA) Submittal of Recommendations for a Revised Falls Lake Nutrient Management Strategy and Revised Rules; and • the University of North Carolina's Co-generation Facility. The Board will need to discuss the materials as provided by the LIWG. 2 The work of the Legislative Issues Work Group to this point is based on the current information available for the 2024 General Assembly Session. The issues addressed by the Group may evolve and change over the session and require additional attention by the Group and Board of Commissioners. New issues may also arise necessitating additional review. FINANCIAL IMPACT: There is no financial impact associated with reviewing and approving Orange County's 2024 Priority Legislative Issues. SOCIAL JUSTICE IMPACT: There is no Orange County Social Justice Goal impact associated with reviewing and approving Orange County's 2024 Priority Legislative Issues. ENVIRONMENTAL IMPACT: There is no Orange County Environmental Responsibility Goal impact associated with this item. RECOMMENDATION(S): The Manager recommends the Board: 1) review and discuss Orange County's Proposed 2024 Priority Legislative Issues and any other potential items for the 2024 North Carolina General Assembly Session; and 2) Consider approval of Orange County's 2024 Priority Legislative Issues document for submittal to Orange County's legislative delegation. Pending action by the Board, staff will work with the Chair to draft a cover letter to be included with the attached document to be provided to Orange County's legislative delegation for the March 21, 2024 Legislative Breakfast. DRAFT#6 3 ORANGE COUNTY 2024 PRIORITY LEGISLATIVE ISSUES Mental Health, Behavioral Health, and Substance Use Issues — Seek legislation to develop and fund mental health and behavioral health facilities and services at the state and local level that: • Ensure adequate State-funded mental health, developmental disability and substance use disorder services and facilities are available, accessible and affordable to all residents; • Include dedicated resources for community para-medicine projects and enhanced mobile crisis response; • Support Medicaid reimbursement to EMS for behavioral health transport to crisis centers; • Reimburse behavioral health urgent care services at a sustainable rate; • Reduce the number of people with mental health issues in county detention centers; • Ensure that state resources fund service provision costs, inclusive of crisis intervention and treatment; • Provide assistance to NC residents, especially youth, who are dealing with the impacts of COVID; • Increase innovation waiver slots more aggressively to meet the Olmstead Act requirements; • Increase compensation for mental health providers, psychiatrists, nurses, social workers, and direct support staff funded by innovation waivers and other Medicaid sources; and • Support both House Bill 563 and related amendments that: • Provide additional regulation on hemp-derived products such as Cannabidiol (CBD), and prohibiting those designed to resemble well-known candy and other snack food products; • Raise the legal age to purchase and use hemp-derived products to 21; and • Incorporate a ban on the flavoring of vape products. School Capital Funding — Support a State bond referendum to address school capital needs to provide needed capital funding to support school infrastructure, renovations, and new construction; and support legislation to: • Allocate State surplus funds for statewide school capital needs; and • Ensure methods used to distribute school capital funding consider the needs of all counties. Racial Equity in Criminal Justice — Support continued consideration and implementation, where practicable, of the recommendations of the North Carolina Task Force for Racial Equity in Criminal Justice (TREC), including: • Legislation to legalize the possession and use of marijuana and permit licensed businesses to engage in retail sales to adults, as this decriminalization will in turn broaden the agricultural economy and jobs as well as enhance revenue for governments with taxes, licenses, and other associated revenues that can be utilized to address opioid and other drug-related problems and other needs; • Policing reforms to address use of force, community oversight and law enforcement training on crisis intervention; • Funding at the county level to expand access to diversion and restorative justice programs; • The reduction of fines, fees and costs in criminal court, noting that such fines, fees and costs disproportionately impact people of color and people of low income. 4 Concealed Weapons in Parks and Red Flag Law — Support legislation authorizing counties to regulate the carrying of concealed weapons on county-owned playgrounds and in county-owned parklands, and allowing courts to prevent access to firearms for individuals who show signs of being a danger to themselves or to others. Mental illness, escalating threats, substance abuse and domestic violence are among the circumstances in which a judge should have the authority to order weapon restrictions or surrender. Full Funding of the Leandro Remedial Action Plan — Support equity and racial justice by fully funding the Leandro Remedial Action Plan, which details additional comprehensive, targeted education funding over the next eight years, predominantly to low-wealth and minority communities, in order for the State to come into compliance with its constitutional obligation to provide every student a sound basic education. Priority School Issues — Support legislation to address the following issues related to schools: • Provide local school systems with calendar flexibility; • Provide full funding for State allotments including Average Daily Membership (ADM) growth and infrastructure/capital, and support legislation to provide for an overall increase in funding based on ADM outside of the current formula system; • Provide a periodic accounting process for State per pupil funds so that funds and pro-rated funds follow students to their respective schools, as opposed to the current process that only considers State funding allocations based on students' attendance location on a single day during the school year; • Increase salary compensation for teachers and staff at all years of service; • Impose class size reductions commensurate with State funding for staffing; • Provide increased funding for school safety initiatives; and • Reduce funding and limit eligibility for/availability of private school vouchers, as vouchers constrain available funding for public education statewide, encourage students to leave public education, and limit services and educational opportunities for all remaining public school students. Non-Partisan Redistricting Process for Elections — Support legislation to establish a process for an independent, non-partisan redistricting process after each United States Census for the election of representatives from North Carolina to the United States House of Representatives, the North Carolina House, and the North Carolina Senate. Bicycle and Pedestrian Transportation Funding — Support legislation to remove the restriction on State funding for stand-alone bicycle and pedestrian projects imposed by the North Carolina Strategic Transportation Investment Law. The restriction limits the development of infrastructure for bicyclists, pedestrians, and users of personal mobility devices. 5 OTHER DISCUSSION TOPICS 1) Upper Neuse River Basin Association Consensus Principles 11 for Falls Lake Rules • Attachment 1 — November 2, 2023 Orange County Resolution Endorsing Consensus Principles II for Revised Falls Lake Rules • Attachment 2 — November 22, 2023 UNRBA Cover Letter and Consensus Principles II to Environment Management Commission (EMC) 2) UNC Co-generation Plant RES-2023-0581 11-C 16103 Attachment 7. 6 ORANGE COUNTY BOARD OF COMMISSIONERS ORANGE COUNTY, NORTH CAROLINA RESOLUTION ENDORSING THE UPPER NEUSE RIVER BASIN ASSOCIATION ("UNRBA") CONSENSUS PRINCIPLES II FOR REVISED FALLS LAKE RULES WHEREAS, the North Carolina Environmental Management Commission ("EMG") adopted the Falls Lake Rules ("Rules"), and the N.C. Rules Review Commission approved the Rules at its December 16, 2010, meeting, with an effective date of January 15, 2011; and WHEREAS, the jurisdictions of the Falls Lake watershed developed an original set of consensus principles in February 2010 to guide the development of the current Rules; and WHEREAS, the Rules (15A NCAC 02B .0275 (5)(f)) allow for the reexamination of the existing Rules using a Division of Water Resources ("DWR")-approved evaluation process, and for the results of the reexamination to be presented to DWR and the EMC; and WHEREAS, the UNRBA has followed the Rules' reexamination process, secured required approvals of the process by DWR, and invested in a 10-year, $10 million study of Falls Lake and its watershed, to establish an updated and comprehensive scientific basis for revisions to the Rules; and WHEREAS, on September 20, 2023, the UNRBA Board of Directors approved revised consensus principles ("Consensus Principles II", see Attachment A) for the readoption of the Rules; and WHEREAS, the UNRBA member local government jurisdictions desire to endorse the Falls Lake Consensus Principles II for the readoption of the Rules; NOW, THEREFORE, BE IT RESOLVED, that the Board of Commissioners for Grange County, North Carolina endorses the Consensus Principles 11 as adopted by the UNRBA Board of Directors, and recommends that the North Carolina Department of Environmental Quality and the EMC use these consensus principles as guidelines in developing the revised rules for Falls Lake. Adopted by the Orange County Board of Commissioners this the 2nd day of November, 2023. By: ALaura Jam ett edford, air - sen �tifi uhf Orange County Board of Commissioners Clerk to the B and 5z 17 7 -' November 22, 2023, Submitted via email UPPER NEUSE RIVER BASIN ASSOCIATION Mr. John (JD) Solomon, Chair Arba NC Environmental Management Commission (EMC) 1 1611 Mail Service Center Raleigh,N.C. 27699 -1617 Forrest Westall e-mail: pamlicojd@gmail.com Executive Director forrest.westall@unrba.org Mr. Richard Rogers, Director PO Box 270 Division of Water Resources (DWR) Butner, NC 27509 1611 Mail Service Center Phone:919.339.3679 Raleigh,NC 27699-1611 e-mail: richard.rogers@ncdenr.gov On the Web: http://unrba.org Reference: UNRBA Submittal of Recommendations for a Revised Falls Lake Nutrient Management Strategy and Revised Rules Town of Butner Dear Mr. Solomon and Mr. Rogers: City of Creedmoor The UNRBA is extremely pleased to submit our recommendations for a revised City of Durham Falls Lake Nutrient Management Strategy and readoption of the Falls Lake Rules. In submitting these recommendations and a summary of our scientific findings from Durham County a ten-year evaluation/study of Falls Lake and its watershed, it is important to give reference to how we have arrived at this juncture. It has been a thirteen-year Franklin County process that reflects an investment of local government resources to develop a much more complete understanding of this aquatic system. Granville County In 2010, the Environmental Management Commission(EMC)passed the Falls Lake Nutrient Management Strategy(the "Strategy" or the "Rules"). The Strategy Town of Hillsborough dictates load reduction requirements for local governments and other entities. Because of the engagement of stakeholders in the rule development process, the Orange County first set of Consensus Principles developed by the local governments to support the initial adoption of the Falls Lake Rules represents a good model for the readoption Person County of these rules. The cooperation and work of DWR and the EMC to incorporate those principles into the rules in 2010 provided an effective process to assess the City of Raleigh uncertainty associated with the modeling used to develop the 2010 rules. This uncertainty about the required nutrient load reductions, particularly for Stage II, Wake County resulted in the extensive scientific work performed since the initial rules were put in place. The adaptive management provision that allowed the last 10 years of effort is Town of Wake Forest described in the Rules (15A NCAC 02B.0275 Section (5)(f)). The UNRBA took on the responsibility of performing a reexamination under this provision of the Falls South Granville Water Lake Rules. and Sewer Authority Soil and Water In addition to the reexamination, the UNRBA has and continues to support its Conservation Districts members in the implementation of Stage I of the management strategy. It should be Town of Stem noted that this implementation, and other nutrient loading improvements since 2006, has generated significant reductions in nutrient inputs for Falls lake. The 1 8 November 15, 2023 UNRBA Submittal of Recommendations for a Revised Falls Lake Nutrient Management Strategy member governments of the UNRBA have not only committed to evaluation of the rules, but they have also made important strides in reducing nutrients in the watershed and the lake. However, the UNRBA has taken very seriously the tremendous requirements placed on them by Stage II of the Falls Lake Rules. Due to the uncertainty cited and concerns about the reduction goals for Stage II, the UNRBA undertook, ahead of designing the reexamination effort, a preliminary evaluation of the requirements of Stage II. This evaluation determined the Stage II reductions are infeasible and beyond the limits of technology(Cardno ENTRIX 2013). Nevertheless, the UNRBA remained committed to completing a comprehensive scientific reevaluation of the lake and its watershed. We have always been focused on a revised set of Rules that are built on an improved and solid scientific foundation. The UNRBA began planning our reexamination in 2011, and in accordance with the procedures and requirements outlined in the Rules, carefully undertook the development of the detailed monitoring and modeling programs, including the quality assurance documentation,to be used during this effort. The final plans and evaluation procedures/process documentation were approved by DWR. By the end of this reexamination process, this year, the UNRBA membership completed a 13-year effort and invested approximately$10 million of local government funds. This is an unprecedented effort by a coalition of regulated communities in NC to provide study and research to DWR, EMC, and the General Assembly to support the development a revised management approach on a critically important water body. With reference to the UNRBA coordination and use of the studies conducted by researchers funded by the NC Collaboratory, it is important to reference this organization. The NC Collaboratory was formed by the NC legislature in 2016 to study nutrient management issues in Jordan Lake and Falls Lake. Since that time, the NC Collaboratory has been expanded significantly to look at a range of issues in our state. Following the creation of the Collaboratory, the UNRBA reached out to the NC Collaboratory and positioned itself to share data and coordinate. The NC Collaboratory looked first at Jordan Lake,but then moved to Falls Lake. Even before the research on Falls began, the UNRBA coordinated with the organization and provided summaries of the work already completed by the UNRBA. This allowed the UNRBA to provide input each year on the status of our work and identify what additional studies might enhance and better inform the development of the UNRBA's reexamination. The UNRBA has shared all its data, work, and preliminary results with the Collaboratory. The Collaboratory also provided subject matter expert and third-party review of the UNRBA modeling of the watershed and lake. This extremely valuable contribution occurred while the models were under development. This integrated approach allowed the reviewers to provide input and feedback as the models were developed and allowed the modeling team to incorporate adjustments before the models were finalized. Third-party reviews increase transparency and provide an extra layer of assurance that the models can be relied upon to support regulatory and policy decisions. The UNRBA and NC Collaboratory held joint symposium each of the last three years, sharing information with our member representatives, DEQ, other researchers, environmental advocacy and conservation organizations, and other stakeholders. This collaboration has provided essential scientific clarification of the work done by the UNRBA and the NC Collaboratory. The NC Collaboratory's report on Falls Lake is due this December. Many other organizations and researchers have also provided critical information to support the reexamination and our recommendations. The amount of data available and the number of researchers involved in this study is extraordinary. Nearly 40 distinct monitoring programs or 9 November 15, 2023 UNRBA Submittal of Recommendations for a Revised Falls Lake Nutrient Management Strategy research studies conducted on Falls Lake, or its watershed, were used to support development of a comprehensive monitoring report, watershed model and three lake models. These tools have been used to assess potential future management approaches and guide the development of recommendations based on science and realistic public policy. What the UNRBA is providing with this transmittal is a condensed summary of critical findings and a set of consensus principles that should be extremely helpful in crafting a revised Falls Lake Strategy. In short, the information developed during this evaluation process shows a reservoir that is eutrophic but meeting its designated uses (drinking water supply, recreation, and aquatic life support). It also shows a lake that is subject to elevated algal activity and ongoing development in the watershed. As reflected in Consensus Principles II, land conservation and continued implementation of the new development rule are essential components of a long-term strategy. Actions to improve watershed health and address current nutrient loading will provide protection of this important water resource. Thankfully, the water quality in the lake is stable and sufficient to support uses. The challenge for the future is to maintain the water quality and make improvements where reasonably possible. The lake continues to have chlorophyll-a levels above the standard some of the time, but the lake is meeting the uses required under the water quality requirements of NC. The UNRBA's set of recommendations for a revised nutrient management strategy are described and summarized in the attached document, Concepts and Principles for the UNRBA Recommendations for a Revised Falls Lake Nutrient Management Strategy. The UNRBA Board of Directors unanimously approved this document and a focused set of revised consensus principles, Consensus Principles II, on September 20, 2023. These important principles carry the description of"II" because the jurisdictions in the watershed submitted the previously referenced Consensus Principles to help guide the development of the current rules. The UNRBA is committed to continue to work collaboratively with DWR, DEQ and the EMC and provide assistance and support as DWR and the EMC establish and carry out a process to see that the revised Falls Lake rules are developed and adopted. We believe that this process should proceed with strong reference to the UNRBA's work and Consensus Principles II. These principles and the Concepts and Principles Document represent a condensed summary of our findings after 10 years of work. The UNRBA is also providing extensive technical documentation of the modeling tools used to support our recommendations. We believe the work conducted by the UNRBA, its members, and the researchers at the NC Collaboratory to expand the scientific understanding of the watershed and the lake will allow the development of a strategy and set of revised rules that will continue to move management of this watershed and lake forward into the future. The revised Rules should reflect the principles identified. The successful completion of the UNRBA modeling efforts and development of the guiding documents for the revised rules would not have been successful without direct input from the organizations and stakeholders operating in the watershed. DWR planning and modeling staff have been actively engaged throughout this process. The UNRBA sincerely thanks everyone who has participated in this project as a provider of data and information, reviewer of models and reporting, facilitator of external discussions, and active participant in discussing the challenges and path forward for this unique system. The next phase of work will be led by DWR as the State moves through its rules readoption process. The UNRBA will also assist and promote keeping this process open and collaborative, engaging a November 15, 2023 10 UNRBA Submittal of Recommendations for a Revised Falls Lake Nutrient Management Strategy broad range of stakeholders so potential issues and concerns can be addressed as rule language is drafted, put out for public notice, and adopted. On behalf of the Association and our members, please find attached to this letter our recommendations for a revised Falls Lake Nutrient Management Strategy and revised Falls Lake Rules. This package includes resolutions signed by the governing body of each UNRBA member supporting Consensus Principles II and its companion document, Concepts and Principles for the UNRBA Recommendations for a Revised Falls Lake Nutrient Management Strategy. If there are any ons about this package or the information provided,please contact our Executive Di r, Forrest Westall, using the contact information on this letterhead. Sinc r ig Hutchinson, Chair Board of Directors,UNRBA Copy: UNRBA Board Members Mr. Rich Gannon Mr. John Huisman Ms. Julie Grzyb Ms. Karen Higgins 11 UPPER NEUSE RIVER BASIN ASSOCIATION (UNRBA) CONSENSUS PRINCIPLES II TO GUIDE REVISIONS TO THE FALLS LAKE RULES Approval by the UNRBA Board of Directors September 20, 2023 These Consensus Principles are based on scientific conclusions resulting from a 10-year evaluation of Falls Lake and its watershed by the UNRBA,NC Collaboratory, and other organizations. The information now available cannot be fully described in this set of Consensus Principles but is described in more detail in a companion document titled"Concepts and Principles for the UNRBA Recommendations for a Revised Falls Lake Nutrient Management Strategy" available online at https://unrba.org/reexamination. The UNRBA is committed to a cooperative and collaborative process to reach agreement on revised Falls Lake Rules (also referred to as the revised Falls Lake Nutrient Management Strategy). The Association appreciates our positive relationship with the NC Department of Environmental Quality and its Division of Water Resources (DEQ-DWR). The UNRBA will work diligently to maintain this relationship through the development and the adoption of a revised set of Falls Lake Rules. We have had the opportunity to interact and report to the NC Environmental Management Commission (EMC) on initiatives of the UNRBA. We plan to continue this communication through the readoption and implementation of the Falls Lake Rules. These Consensus Principles, and supporting information, will be provided to DEQ-DWR, the EMC, and the NC General Assembly as required by State law. 1. Revised rules are needed to promote effective action and sustainable investment by local governments,utilities, and other partners to meet the goals of maintaining, protecting, and improving water quality in Falls Lake into the future. The UNRBA recognizes the importance of this lake as a water supply source, an ecological and recreational resource, and a flood control reservoir. 2. NC DEQ-DWR and the EMC should move forward promptly with the revisions to the Falls Lake rules, taking into consideration these Consensus Principles. 3. The revised rules should embrace a systems approach focusing on solutions that consider interactions among surface water, land surfaces, groundwater, soils, and atmospheric and climatological drivers. This watershed-health approach should consider environmental benefits, costs, and impacts to users of the water resource and those asked to pay the costs of the regulations. The revised rules should improve water quality throughout the watershed, and not prioritize activities solely based on the reduction of nutrients to Falls Lake. 4. The revised rules should include adaptive management. Implementation of the rules should be reviewed every 5 years, with a report to address new information, conditions, or concerns that have developed during the previous 5 years. The UNRBA proposes that the adaptive management provision also include a detailed reevaluation of the rules completed 25 years after the date the revised rules are enacted. A detailed reevaluation should incorporate additional monitoring data collected by DWR and other organizations, data analysis, modeling evaluations, and consideration of technological advancements for improving water quality. The 25-year review should include a reexamination of the rules, so that changes may be proposed and put forward for consideration. 5. The revised rules for managed lands should be an investment-based,joint-compliance approach. Managed lands include residential, commercial, institutional (schools, hospitals, other state and federal facilities, etc.), agricultural (cropland and pasture), road rights of way, recreational (parks), etc. 6. The revised rules should not require nutrient load reductions from natural or unmanaged 12 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.