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-1- "7d STAFF RECOTA ENDATIONS TO THE METROPOLITAN COUNCILS PROPOSED SURFACE WATER MkIAGE!.ENT PLAN Overall General ATAI REcommendations: 1. In all cases for organization, planning, implementation and funding, the Surface Water Management Guide should be modified to conform and be consistant with the Surface Water Management Act, Minnesota Laws 1982 Chapter 509, Sections 12 through 26. In no case should this plan exceed the authority granted by Chapter 509. 2. The map and description of watershed boundries should be reviewed to ensure conformence with official maps developed by the DNR pursuant to Laws 1977, Chapter 455, Section 33, Subdivision 7(a), as required by Chapter 509. 3. The Guide should conform to Chapter 509 providing an orderly and achievable time frame for the organization of Plater Management Organizations, planning by the WM0 and planning by the local units within each WMO. 4. Metropolitan Council involvement in the review process of PIDIO plans should be limited to review and comment only with a clear distinction made between general advisory comments and those pertaining to affects upon the four systems, as referenced by the Comprehensive Planning Act of 1976. Council involvement for local plans should be limited to • the Comprehensive Plan Amendment Process established by law only if amendments to the local comprehensive plan is necessary. 5. Funding for planning, implementation, and maintenance should be at the IV140 or local level as appropriate except where state funds can be obtained to augment the costs of the Surface Water Management Act mandates. Metropolitan Regional funding should not be used. 6. This draft policy plan defines many management practices and guidelines to be included in WMO and local plans. Where these guidelines exceed those required by Chapter 509 they should not be required but be suggested or advisory in nature. All references to 'will' , 'should' or 'shall' in a mandatory way when inconsistant with Chapter 509 should be changed. 7. Policy 14 as written infers that treatment of surface water plans for A95 review purposes may be elevated to a status similar to 'policy 39' for Housing. This is totally without foundation and should be modified to indicate clearly that the local surface water plan will only generate A95 comments for surface water related projects. 8. The Metropolitan Council should continue its role as a provider of technical assistance information, and data gathering to help PR-AO's and l0:!?1 units prepare Surface Plater Management Plans. •