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stormwater runoff rates. A city-required flood plan was also not included in the application documents. Unfortunately, they also told me there is no appeal process through RCWD directly. No Viable Replacement Plan The RCWD expects this basin system to last 20-30 years with good maintenance. So every couple of decades, the single homeowner of Lot 1 will required to replace the $40,000 system ( the timing of which is based on the homeowners own inspections - quite the conflict of interests) at the peril of our cities natural resources. There are no other arrangements like this in Arden Hills. Contrary to the incorrect statement by the applicant's engineer during the Feb 7 Planning commission meeting when he said "there is no infiltration, there is no filtration, those items are the high maintenance situations [and aren't applicable here]", the RCWD is specifically requiring filtration basins (RCWD Permit Number 17-121, Findings section #2). These are not cheaply created, not cheaply repaired, and not cheaply maintained. A cost study done for the MN Pollution Control Agency and US EPA by Barr Engineering shows the average cost (in 2010 dollars) of similar basins that cover commensurate watersheds in St. Paul is around 30k-50k[10]. The MN PCA's "Minnesota Stormwater Manual" basin cost estimate worksheet puts the cost of the proposed BMP solution smack in the middle of that range, $39,000, in fact.[12] 40 thousand dollars seems like an amount higher than we could expect a single homeowner to cover quickly in the event of a failure - and it would need to be remedied quickly to avoid prolonged and increasing damage to our city's wetlands. (and they would be required to self-report the failure - but could, without penalty, appear to simply wait until it was eventually discovered) The MNPCA/USEPA and Weiss study[13] on BMP costs effectively says that one can expect to pay 5-12%[10] of the construction costs per year when amortized to keep these effective (this matches reasonably well with the 20-30 year lifespan RCWD gave for these basins). It's further worth noting that the cost survey index, which includes both small and large basins, seems to show these basins are almost exclusively owned and run by cities/counties or large organizations like universities or apartment complexes. Easement vacation: Allowing the vacation of easement and other plans to go through as they stand will result in additional costs to the city for future maintenance and rebuilding of the lift-station. The easement and lift station have been there well before the current owner bought his property. It's size, location, and atypical "very deep" lift station structure combined with the rather extreme and unique topology of the site and myriad items being added in, on top of, and around the lift station make shrinking the easement a bad financial deal for the city. Past city engineers (current city engineer was appointed Feb 13, 2017) have have noted the easement cannot be shrunk this much and still be sufficient for reconstruction. The driveway location on Lot 1 (which is directly on top of the main city sewer line) effectively cuts an additional ~1500 square feet from the actual size of the easement - space needed for maintenance and rebuilding of the site. The 2007 attempt to place one additional house on 3685 New Brighton road would have resulted in the easement shrinking by less than what is currently being proposed. At that time, the city engineer said that the shrunken easement "may not be sufficient for reconstructing the lift station in the future".[5] Staff review recommended widening the easement by 10 feet on the other side. The City Engineer and Public Works Director at the time then noted that only "with the boundary adjustment, the city engineer [and public works director] determined that partially vacating the easement would not impact the function, maintenance, or reconstruction of the lift station."[6]. That 2007 City Engineer proved to be prophetic, as the lift station was rebuilt in 2012 (before the current city engineer was in the position) and photographs show the rebuild required space beyond the current western boundary of the easement and well beyond the boundaries of the proposed easement. This is not a theoretical estimate of the extent; this is exactly how much land an actual rebuild needed. Contacting the construction company that did the rebuild, I'm to understand the amount of space is needed due to the "very deep" nature of this lift station. Even the company that won the bid and actually built the lift station in 2012 says that a rebuild would be more expensive with the plans as-is; they further said they would be required to use a sheeting box in order to 'save' the driveway (if even possible), the retaining wall, upper catch basin, swale, and piping within 30 feet would need to be removed and replaced. ... presumably all at the cost of the city. To summarize: • previous city engineers saying it can't shrink that much (and requiring it be expanded on the other side if they really want to cut off that corner) • previous city engineers requiring there be nothing added in the ground within the easement (the one pipe in the previous plan, they required be moved... this plan has 5 underground pipes (plus nat gas), 6 trees, retaining wall, 2 driveways, and a catch basin) • historical photos showing the space actually needed goes beyond the current extent of the easement... and, by extension, goes beyond the proposed shrunken easement. • the actual company behind the 2012 rebuild saying that a rebuild, given the proposed plans, would be more expensive and also would require demolishing/rebuilding various items on the plan. This plan will cost the city additional money and make any future work in the area more complicated... forever. The easement was put there for a reason: specifically to avoid private development from increasing city infrastructure maintenance costs. Easement imagery I created the below images by using the 2012 photos[15] and the current plans[3]. Using location of the trees (which can be assumed to have not moved and are accurate on the survey) and other known sizes, then perspective shifting the plans we can pretty accurately lay out the proposed site on top of the area needed to construct the lift station in 2012. This sanity checked against the rebuild plans well.[16] I did not tweak my added lines for the rectilinear wide angle lens distortion but being mid-frame said distortion should be minimal. The below image shows where lot 1's driveway would go -- you'll notice it's clearly within the area needed for construction in 2012. In fact, the driveway is Page 2 of 12Reasons to Deny 3685 New Brighton Road Subdivision 3/9/2018http://joefederer.com/subdivision/Reasons.html