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• <br />• <br />• <br />MIDS Project <br />Cities' Perspective & Concerns <br />October 2011 <br />MInn_sxc Grle_ <br />rmwai_r <br />-anion <br />1. There are many types of land areas for which volume reduction (VR) BMPs are <br />inappropriate and /or unnecessary. These may include: <br />• Karst geology <br />• Shallow bedrock <br />• Shallow groundwater <br />• Urban land <br />• Pollution hot spots <br />• Drinking water protection areas <br />• Areas where groundwater is sensitive to surface water influences (see county <br />groundwater atlases) <br />• Areas where the increase in SW runoff volume due to urbanization may not <br />result in substantive degradation to receiving waters, including: <br />• drainage areas to high -order streams <br />• drainage areas to large lakes or wetland systems (where the resulting <br />change in bounce may be trivial) <br />2. Volume is a useful surrogate for pollutant loading, in many circumstances, but there <br />are limits to its use as a surrogate. Over - reliance on volume reduction should be <br />avoided. <br />3. Non -VR BMPs should be accepted in situations where VR BMPs are physically <br />feasible. <br />4. Non -VR BMPs should be part of a "parallel" compliance path, not an "alternative" or <br />"secondary" compliance path <br />5. The implementation of non -VR BMPs should not depend on approval of the <br />reviewing entity for consideration. <br />6. There may be cases where non -VR BMPs will be significantly more cost effective <br />than VR BMPs. Flexibility, including cost as a factor, to use non -VR BMPs should be <br />included in the performance standard. <br />7. Stormwater ponds (existing and new) should be included in the mix of BMPs <br />considered in the context of the MIDS Project. <br />