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details be supported by and correlated with the goals and actions within section 6.3.9 <br />Evaluation and Accountability on page 137. <br />Page 149, Impact on Local Governments: adoption of local plans within two years may or may <br />not be consistent with the January 2014 date provided; we suggest revising within two years of <br />BWSR approval of this plan. Clarify the actual financial impact to the member communities by <br />year including direct contributions to the WMO as per the JPA as well as expectations as a <br />partner on projects. We understand the cities have each discussed initiating a stormwater <br />utility for WMO expenses; however, this is not currently in place and even when in place will still <br />be considered an impact. The WMO needs to have a clear understanding in the plan as to the <br />impact the proposed standards will have as well as a clear means of implementation of the <br />standards; this cannot be left to a future meeting. <br />Page 149 -150, Local Planning, first paragraph: the member cities must adopt within two years of <br />BWSR approval of the GLWMO plan. Additionally, the cities have 180 days from local plan <br />adoption to amend official controls, i.e. implement standards, and the WMO cannot require <br />implementation of standards prior to local plan adoption. <br />Page 150, Local Planning, third paragraph and page 152, top of the page: outline the procedures <br />the GLWMO will use to be notified of and review a project so that determination of need for an <br />appeal can be made. Additionally, define 'project' in this context. <br />Page 153, Grass Lake WMO Plan Revision and Amendments: the plan can remain in effect from <br />10 years of the date of approval by the BWSR, not 10 years from the year approved and <br />adopted. Additionally, this chapter or section must contain a list of anticipated amendments. <br />Joint Powers Agreement <br />The current JPA is not in compliance with MN Rule. The final plan must include a fully compliant and <br />executed JPA before the plan can be approved. <br />Thank you for the opportunity to review this plan and we look forward to working with you through the <br />rest of the plan approval process. BWSR staff could not recommend approval of the current draft plan. <br />If you have any questions, please contact me at 651- 297 -4735 or Melissa.K.Lewis @state.mn.us. <br />Sincerely, <br />ufi�- �� <br />Melissa Lewis <br />Board Conservationist <br />CC: State Review Agencies (via email <br />Page 6 of 6 <br />