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Regular City Council Meeting Monday,May 5,2014 Page 17 was created in 1984. Mr. Culver opined that the proposed program was more in line with current city storm water guidelines and watershed requirements regard- ing increases in impervious surfaces and general site disturbances. Staff Recommendations: Mr. Culver advised that staff recommends City Council approval of the new pro- gram as presented with credits calculated and applied in 2014. Mr. Culver noted that property owners who had previously registered their Best Management Prac- tices (BMP's) would receive notice of potential credits, and as part of their appli- cation for credit, would need to prove they met the requirements for credit. Mr. Culver noted that the program also required that every five years, any property re- ceiving credit would have to recertify the condition under which the credit was originally granted. For commercial properties, Mr. Culver noted that this would require some cost for them to hire a consulting firm to recertify their BMP. Councilmember Willmus noted that a number of properties throughout Roseville had natural rain gardens, and questioned if they would be eligible for this credit. Mr. Culver advised that, under the proposed policy, they would not be eligible, as the focus was intended for those properties implementing non-natural BMP's above and beyond natural site conditions, and require registration and verification that they were serving that purpose. Mr. Culver noted that overflow on properties and other natural areas were part of the overall storm water system,but the credits were intended for people going beyond those natural components. Councilmember Willmus questioned, in function, why their involvement should be prohibited, with Mr. Culver responding that some type of certification (e.g. soil boring or property analysis as to how much runoff was leaving a parcel) would need to be done. Mr. Culver opined that this would be going back to the current storm water system in giving credit for something the property owner didn't do to improve a situation and would be difficult to address. If a property held versus dumped runoff water, Councilmember Etten questioned how the City addressed natural versus intentional actions by property owners; opining that it would be costly to certify that and questioned if it would be pru- dent to attempt to do so. As a resident on Hamlin Avenue, on a County Road without curb and gutter, Councilmember Willmus questioned how much benefit he would receive with such a program compared to those with curb and gutter installed. Councilmember Willmus noted parcels along County Road B with significant inflow on their property coming from impervious surfaces elsewhere that stayed on their land, while they were charged a storm water fee but received no benefit.