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Sec 1675.08, Sub. 8 : This entire subdivision of specifications presents the risk of being in conflict with the NURP design standards of Rice Creek Watershed District. We recommend that the City Engineer review these standards and rectify them with Rice Creek Watershed standards. Sec 1675.08, Sub. 12 : Replace "previous'with "pervious". Sec 1675.08, Sub. 13 : Replace "interests.t allow'with 'interests to allow . , GENERAL 1. Scope: In general, current state (Minnesota Pollution Control Agency) and local (Rice Creek Watershed District) storm water management ordinances have disturbed acreage thresholds below which the regulations do not apply(10 acres and 3 acres, respectively). As currently written, any citizen wishing to obtain a building permit for almost any purpose must submit a surveyed site map (to two foot contours), a wetland delineation analysis, and a final site contour map, all of which would require the applicant to hire out for professional services. For a commercial or industrial development or redevelopment projects, these are appropriate requests; for a homeowner building a deck, the subcontracted professional services costs may exceed the cost of the deck. We also can foresee that Public Works staff could spend much of their time reviewing (likely inadequate) submittals by homeowners, and that sticking to the letter of the ordinance as proposed would create an adversarial relationship between the City and its citizens. As a solution, we propose that there be two classes of requirements, one (not yet written) that would apply to any permits issued to an individual homeowner in the City's R-1, R-1A, and R-2 zoning districts, and another(the current draft ordinance) for permits issued for all other(larger) . residential projects and in all.other zoning districts. We recognize that surface water.quality in the.City is everyone's responsibility(homeowner and business alike), but wish to recognize the difference in scale and potential water quality impacts between small residential repair/improvement projects and those of a larger construction project. The proposed residential housing storm water management requirements would be appropriate in scale and complexity, be able to be completed by the homeowner, be easily reviewable by City staff, and not pose significant financial barriers to homeowners who wish to maintain or improve the City's housing stock. We recommend that City staff contact the League of Minnesota Cities, and contact other city governments to see what other such ordinances currently exist to serve as a model residential storm water management ordinance. If none can be found, the Planning Commission or the City Engineer can be utilized to draft such an ordinance. 2. Section 1675.08. Sec. 9- Lawn Fertilizer Restrictions. While this restriction on phosphorus is desirable, as a practical matter it is virtually unenforceable. We recommend that the City. continue its efforts of educating.its citizens about this issue, and continue to cooperate with other local governments, conservation organizations, and concerned citizens. Should the Council have any questions or concerns regarding our comments, please let them be known to the Planning Commission and we will do whatever we can to support implementation of the new ordinances. We appreciate the opportunity to comment on these draft ordinances, and look forward to continue to work with the Council on this issue.