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than 0.25 inches results in surface water ponding and surface water runoff within the ACD 55 <br />drainage area (Houston Engineering, 2013b). Without -an alternative outlet or increased capacity <br />development may be limited mitigation, the inevitable impacts from the proposed development will <br />be increased volume and increased peak flows of surface water runoff within the ACD 55 drainage <br />area. This would may exacerbate current flooding up stream in the ACD 55 system since ACD 55 <br />restricts downstream flows and can only accommodate a small amount of flow. Sediment loads, <br />and with it pollutants and contaminants, would also increase. Flow from the 215 -acre area within <br />the City of Hugo may be up to 62 CFS during the 100 -year 24-hour storm. Additionally, 54 CFS will <br />be generated from the 534 acre area within Lino Lakes that is currently served by ACD 55. The ACD <br />55 infrastructure currently reaches capacity at 1-2 CFS. As a result, the City of Lino Lakes is <br />contemplating a new conveyance system and outlet structure to Peltier Lake from the 1,400 acre <br />development area, which would be subject to review and approval by the RCWD via the CSMP. This <br />may require the development of alternative standards (stormwater rules) to demonstrate no <br />adverse impacts through the use of RCWD Comprehensive Stormwater Management Plan (CSMP) <br />provisions. <br />Emmons & Olivier Resources, Inc. - page 4 of 5 <br />