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Assessment of the Reasonableness of the Proposed Watershed District Rules The District initiated the rulemaking process January 5, 2005 and adopted a workplan and schedule that would conclude with rule adoption at the end of2005. (See Appendix G) The workplan had two phases, the first was to draft the Rules and the second was the formal adoption process dictated by MN Statutes 103D.341. The District's philosophy was to provide multiple opportunities for stakeholder input and to work closely with adjacent watershed districts to have as much consistency as possible with our rules. In April of 2005, the District, partnering with Ramsey Washington Metro Watershed District, completed Rulemaking Study Phase 1. (See Appendix H) The goal of the study was to evaluate how stormwater BMP's could be incorporated on densely developed sites to achieve the District's Development Review Criteria. The Rulemaking Study Phase I analyzed three previously approved sites that did not fully meet District Development Review Criteria. The three sites were evaluated in reference to District criteria for rate control, volume control, and water quality to determine if: A) Is it possible to achieve the current District criteria, and if so what would the stormwater BMP's be and how much would they cost; OR B) If it is determined that it is not possible to meet the current development review criteria, then alternative attainable criteria should be developed and the BMP's used and their associated costs should be detailed. The District retained four firms, which each independently completed the analysis. By having multiple firms complete the study it showed that multiple designs/approaches were available to achieve the District's criteria on densely developed sites. The Rulemaking Study obtained multiple objectives towards Rulemaking including: . Reevaluating the original Development Review Criteria . Exploring potential alternative Development Review Criteria . Providing examples of how previously noncompliant developments could be brought into compliance . Giving an indication of the costs of complying with various technical criteria . Providing a valuable tool to demonstrate the feasibility of implementing our new rules Based on the analysis completed during the Rulemaking Study Phase I, the District developed and adopted draft technical standards for Rules. (Appendix I) The draft technical standards for Rules were simpler and easier to interpret than the original Development Review Criteria and in some cases were less restrictive. Major changes were made to the volume control and water quality criteria. The integrated resource management criterion was not included in the draft technical standards for Rules. To further evaluate the draft technical criteria for Rules, the District completed the Rulemaking Study Phase II in June 2005. (Appendix J) The second phase of the Rulemaking Study evaluated the same three sites analyzed in the Phase I but utilized the draft technical standards for Rules. This second phase of the Rulemaking Study in particular illustrated that the technical criteria for Rules were practical, feasible from an engineering perspective and the costs were reasonable in reference to the total project cost. Table 2 summarizes the findings of the Phase II Rulemaking Study from June of 2005. CRWD - Statement of Need and Reasonableness (SONAR) for Watershed District Rules October 5, 2005 Page 3 of 5 "Our mission is to protect, manage, and improve the water resources of the Capitol Region Watershed District. "