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<br />Letter to Ms, lennifer Olson <br />February 20, 2002 <br />Page 2 of3 <br /> <br />e <br /> <br />Plan and the City's experience indicate that storm water pond construction and associated <br />long-term maintenance costs are more cost effective that infiltration devices, <br /> <br />Notwithstanding, the Plan has been amended (Section 2, Utilities, paragraph four, page <br />21 and Section 3, Regional Storm water Treatment Locations, paragraph two, page 24) <br />recommending the use of alternative drainage systems and BMPs on a project by project <br />basis, <br /> <br />Section 3 - Hydraulic and Water Quality Analysis <br /> <br />Preparation of a figure depicting water quality treatment in the City's subwatersheds is <br />beyond the scope of the LSWMP preparation, We have amended Table 7 in the Plan <br />identifying the completion of a subwatershed evaluation study as detailed information is <br />lacking in the City (storm water routing, detention pond characteristics, etc.). <br /> <br />Section 4 - Objectives and Policies <br /> <br />The Wetland Conservation Act provision relating to storm water detention pond <br />phosphorus removal efficiency and wetland mitigation/replacement has been added under <br />the Ponds and Wetlands section of Objective F (page 33). <br /> <br />Section 5 - Implementation Program <br /> <br />e <br /> <br />The City will keep RCWD informed on the feasibility and implementation of the storm <br />water improvement projects identified in the LSWMP. <br /> <br />Cost/Benefit for Pollutant Removal <br /> <br />Table 9 did not include a column identifying pollutant removal capability for each <br />practice because the information was not included in the referenced USEPA document. <br />Similarly, the "Minnesota Urban Small Sites BMP Manual" does not include definitive <br />BMP removal efficiencies. We agree that both infiltration devices and storm water ponds <br />have demonstrated pollutant removal capabilities. However, the USEP A document (page <br />5-9) and the Center for Watershed Protection WEB sites (http://www,cwp,org/coJd- <br />climates.htm and http://www.stormwatercenter.net/Librarv/PracticeArticles.htm) <br />reference studies and cautionary statements on the long-term use and cost of infiltration <br />systems. <br /> <br />We have referenced the Minnesota BMP manual in the LSWMP (Section 3, Regional <br />Storm water Treatment Locations, page 24) along with including it as a reference in <br />Appendix M, <br /> <br />As discussed earlier, the Water Quality Task Force Report recommendations will be <br />implemented by the City where appropriate and in a cost-effective manner. The City will <br />continue to use storm water ponds as the BMP of choice with other alternatives <br /> <br />e <br />