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- . , i <br /> -, <br /> . � <br /> � <br /> � <br /> ; <br /> We have reviawed the proposed capital projects and have the following comments: <br /> ■ P�oiects CIP C1 (Offerman Ditch�,CI�,' CS (Casco Point Swale) CIP-1 (Stubbs Bay Ravine I <br /> � <br /> Stabilizafiio�) and CII'-7�,I,ona Laka Ravine Stabilization� <br /> The Diract Volume method of cslculating load reduction by stream stabilization is.an accaptable : <br /> method,however,moro detail gliould be provided to justify the"volume vnided"and"yBars" <br /> variables.Actual face area measurements and just,if"zcation for recassion ratas shouId be pravided. <br /> The calculations in the appendix for the Stubbs.Bay project included only the vegetative <br /> stabilization portian of the project;no calculations are shown for the praposed t•epair of tl�e i <br /> catastrophic failure pnrtion of the pro,�ect. i <br /> � i <br /> ■ CIP-11 Contribution to South Katrina Marsh Project) . <br /> Esch subwatershed plan in the CWRMP includes load reductions from regulation,LGU assigned ' <br /> load retiuction,and District external and intarnal load projects.The South Katrina Marsh project � <br /> is part of the District's Jennings Bay external load reductian plan,thus it cannot be used to satisfy � <br /> tl�e LGU load reductions.To do so would"double count"the reduction.{Note:The City has ; <br /> proposed addltional BMPa sufficient to meet the required reduction for the P�inter C�•eak ; <br /> subwatei�shed.) i <br /> ■ Orc��t�anca Revisions <br /> The MCWD's Stormwater Management Rule is currentty undergoing revision and is scheduled to j <br /> be cornplated by the end of the year.The City and MCWD will nead to coordinafe to determitae i <br /> how much of a reduction the City can be credited with for their proposed orciit�snce. i <br /> 3. Ident�Key Canservation Areas(KCA)cnzd assess adequacy of local policres and controls to <br /> corrserve their hydrologic atul ecalogical valztes, A fig�ue showing the KCAs shauld be added to the . <br /> Plan,as well as additionat discussion describr.ng more speci�catly how the City intends to achiave j <br /> this znanagement goal. <br /> Minnesota ules 8410 R�viremants ' <br /> � <br /> 4. Purpvse. Statute requires eaoh plan to contain a section titled"Purpose,"which axplains the purposa <br /> of water management planning.This informa�ion is contained in section 1,1 of the Plan,which could � <br /> simply be ren�uned"Purpose"instead af"Background." ; <br /> 5. Financial considerations, The Plan states that the primary source of fimding for the Implementation i <br /> Plan(IP)activities is the City's starmwater utility,whioh aurrently generates about$135,OQ0 per <br /> year.lt is stated that the utility plus othar funds such as ga�ants should be sufficient to fund tha IP. <br /> However,the annual cost of IP activities varies$232,400-$331,400.The Plan should inctude a � <br /> discussion of how the City would prioritize aetivities if sufficient funds are not availabJe,or whether ' <br /> the City wauld consider raising its utility rates to generate more revenue. i <br /> 6. Amendment procedure. Section 10.3 should note tk�at the City n�ust complate any amendments to its <br /> Local Plan within two years after the adoption of CWRMP revisions ar the next CWRMP. <br /> Additional MCWD CWRMP Requirements � <br /> 7. Park and open space integration. Discussion should be added to the Plan describin�how water <br /> resourcas ptannuig will be incorporated with parks and opan space planning. <br /> � <br /> Page 2 of 3 ! <br /> j <br /> i <br /> I <br />