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incorporate site design changes into the final city approval that would allow the development to meet the District's Development Review Criteria. The Development Review Criteria was developed in 2002 and adopted by the District on September 5, 2002. The intent of Development Review Criteria was to, in part, achieve the goals and policies of the WMP. The criteria required developments and redevelopments to address rate control, volume control, water quality treatment, flooding, wetland protection, erosion and sediment control, and integrated resource management on their sites. (See Appendix D) During 2003-2005, the District assumed an advisory role to the Cities with development and redevelopment proposals. The advisory role consisted of review and comment in reference to the District's Development Review Criteria. The Cities would consider the comments and attempt to incorporate suggested changes to the greatest extent possible into the final approval. During 2003- 2005, the District reviewed 71 developments or redevelopments (through 10/01/2005). (See Appendix E) The District tracked compliance with all of the development review criteria and found marginal compliance with the criteria. The volume control and water quality criteria had the poorest level of compliance. Additionally, there were problems associated with the CRWD being made aware of the developments very late in the process or not at all. The main problem with of late notification was that site plans were completely developed and very difficult and costly to change at that late stage of the process. Developers were usually unwilling to make changes after they had received municipal approval and the city staff was either unable or unwilling to compel the developer to make the changes as well. To assess the impact of non-compliance with the Development Review Criteria, the District completed the Development Impact Assessment in November 2004. (See Appendix F) This assessment analyzed the long-term impact that the current level of compliance would have on the water resources of the District. The study found that if development/redevelopment continued in the manner it had in the past, the peak rate and total volume of flow, as well as the amount of phosphorus being delivered to receiving water bodies would increase. The District's goal of improving conditions with the watershed by achieving a decrease in rate and volume of flow, as well as a 60% reduction in phosphorus loads was clearly not being met under the current development review process. Table I summarizes the findings of the Development Impact Assessment: Table 1- Develonment Im~act Assessment Summary Table, CRWD - November 2004 Criteria CRWD Goal/Standard Results from Study Rate Control 0% Increase 5 Yr Storm - 13.2% Increase 100 Yr Storm - 28.7 % Increase Volume Control 0% Increase based on existing 5 Yr Storm - 24.2% Increase runoff volumes or that of site 100 Yr Storm -13.7 % Increase with 25 % impervious surfaces Water Qualitv 60% Reduction 9% Increase Based on these results using the development review criteria and the significant long-term impacts that would result from non-compliance, the District concluded that the voluntary development review process has not and would not achieve the goals and policies of the District's WMP. On December 13, 2004 the District held a meeting with the member cities and indicated its intention to promulgate Rules. CRWD - Statement of Need and Reasonableness (SONAR) for Watershed District Rules June 7, 2006 Page 2 of 6 "Our mission is to protect, manage, and improve the water resources of the Capitol Region Watershed District. "