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03-12-18-R
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03-12-18-R
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additional sedimentation in the wetland" for lot 1 and added flow to the street. He further notes that <br />depending on the Lot 1 house design, water hitting that roof would flow unimpeded down into the <br />extreme slope[11] wetland or onto the driveway (which we just noted, does not direct water to the <br />basins). He notes the basins, particularly the southern one, are simply not located in the right <br />places and appear to be crammed into the available location rather than an effective location (this <br />statement further supported by the RCWD comments). <br />I contacted RCWD directly about the appeal process or if they took the 2012 steepening of the <br />grade into account but have not hear back. <br />Secondly, and equally (more?) concerning: stormwater basins require maintenance. The city has <br />stated multiple times they are not responsible for maintenance; the plan says the city is not <br />responsible for maintenance; the RCWD simply says "there must BE a plan" but does not indicate <br />what it is. What wording is being included to ensure they are maintained and <br />inspected properly and what penalty is there for not doing so? <br />The original proposed plan involves cutting the grass, removing sediment, removing debris, and <br />inspecting (now that it's a proposed filtration basin there should be additional maintenance steps <br />than on the original plan). There are other items like doing inspections themselves, logging said <br />inspections with RCWD, and reporting maintenance tasks to the RCWD. As Mr. Bachler read at <br />the Feb 7 meeting, some of the requirements are "submitting report annually listing inspections, <br />dates, conditions, actions taken, etc.". These read like municipality tasks, not individual <br />homeowner tasks (who would be responsible for their own inspections rather than a 3rd party). <br />Further, this is protecting a city resource affecting dozens of homes -- yet the city wouldn't be party <br />to the maintenance at all? <br />Who will be ensuring their they are maintained, safe, don't stagnate and turn into mosquito nests, <br />and remain effective? There are no comments in the plans about ensuring the swales, catchment <br />basin, and under-driveway piping is maintained by this homeowner or subsequent homeowners. <br />Who foots the bill when they fail? This is particularly concerning given the closeness to the <br />wetlands, the lack of space to do a true infiltration basin (which has a longer lifecycle), and <br />inadequate soil for the lower-maintenance infiltration style basins. <br />A cost study done for the MN PCA and US EPA by Barr Engineering shows the average cost (in <br />2010 dollars) of basins that covers a commensurate amount of land in St. Paul is around 30k-50k. <br />That seems like an amount higher than we could expect a single homeowner to cover quickly in the <br />event of a failure. These are not cheaply created, not cheaply repaired, and the PCA/USEPA and <br />Weiss study on costs effectively says that one can expect to pay 5-12%[10] of the construction <br />costs per year when amortized to keep these effective. It's further worth noting that the cost survey <br />index seems to show these basins are almost exclusively owned and run by cities/counties or large <br />organizations like universities. <br />Contrary to the incorrect statement by the applicant's engineer during the Feb 7 Planning <br />commission meeting when he said "there is no infiltration, there is no filtration, those items are the <br />high maintenance situations [and aren't applicable here]", the RCWD is specifically <br />requiring filtration basins (RCWD Permit Number 17-121, Findings section #2). <br />With the owner moving and the applicant not being from the city and having a poor history of follow <br />through in the area, as well as unknown future owners taking on the task (both physically and <br />financially) of protecting our shared wetlands, I'm concerned this won't be well done in the out <br />years and the city will be stuck with a bill and/or the wetland will be damaged. <br />Property Sizes:
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