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2. <br />�J <br />EXHIBIT A <br />RICE CREEK WATERSHED WATER RESOURCES MANAGEMENT PLAN <br />DRAFT CITY COMMENTS <br />ITEM <br />Management implementation strategy concerning water quantity <br />(Page V-15). <br />PROBLEM <br />The Management Plan states "The local water management plan <br />must demonstrate that for a 100-year return frequency <br />rainfall event, the rate of storm water runoff leaving the <br />municipality will not exceed the rate storm water runoff <br />leaves the municipality in its undeveloped condition." This <br />strategy creates a much higher goal than the current strategy <br />of required new development to have storm water runoff rates <br />equal to the existing condition. <br />Developed municipalities will have difficulty attaining this <br />goal in a cost effect and environmentally sound manner. <br />Municipalities will need to purchase additional land for <br />ponding. <br />Trying to reduce outflow rates from a municipality is a <br />laudable idea, but it is too idealistic. <br />CITY POSITION <br />The management implementation strategy concerning water <br />quantity should require cities to maintain the existing storm <br />water runoff rates as estabished per the TR-20 model results <br />referred to on Page III-26 of the Management Plan. New <br />developments and redevelopments shall have storm water runoff <br />rates equal to the existing condition. If opportunities are <br />available, redevelopments shall have storm water runoff rates <br />equal to undeveloped condition. <br />The problem statement in the plan should be more detailed and <br />stated more concisely. The plan shall then recommend a <br />solution to the identified problems. <br />ITEM <br />Water quality protection and pretreatment approach (Page <br />V-18). <br />PROBLEM <br />Water quality control and/or pretreatment objectives are too <br />stringent. It will be difficult to achieve from an effective <br />environmentally and fiscally sound approach. <br />PAGE 1 <br />