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Mr. Kyle Klatt <br />April 10, 2009 <br />Page 2 <br />Comments on Final AUAR <br />The following paragraphs list the VBWD's comments and the corresponding AUAR question number <br />and page number. <br />Executive Summary, Stormwater Volume Control, Page x <br />This section states, "The city will work with developers to provide runoff volume facilities adequate <br />to maintain existing runoff volume or the 100-year rainfall event...." As summarized in other <br />sections of the AUAR, the City needs to require that developers not increase the stormwater runoff <br />volumes for the 100-year rainfall event. <br />Question 17, Water Quality— Surface Water Runoff, Pages 67-79 <br />While the VBWD does not agree with all of the assumptions (including curve numbers for existing <br />conditions) of the various runoff volume analysis scenarios, the response to this question concludes on <br />page 78 that the runoff volume control facilities will be constructed to not increase runoff volumes from <br />existing conditions for the 100-year event, as calculated by the VBWD simple calculation for landlocked <br />basins. (This basically means that a volume equal to six inches times the new impervious surface must be <br />infiltrated.) Following the City's proposal, permit applicants will need to provide proof that <br />• the runoff volume difference between proposed and conditions (as calculated by the VBWD <br />simplified method) is captured, <br />• the proposed infiltration facility can infiltrate at the designed rate, and <br />• the runoff volume can be infiltrated within 48 hours. <br />The VBWD is currently updating its Rules and Regulations and may include this requirement for projects <br />within the Downs Lake watershed. <br />