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RCWD Alternative Compliance Sequencing Report City of St. Anthony Village PAGE 4 WSB Project No. 1626-53 I. INTRODUCTION AND PURPOSE This report has been prepared by the City of St. Anthony (City) in an effort to address the Rice Creek Watershed District (RCWD) stormwater volume reduction and water quality requirements for the City’s Street and Utility Reconstruction Plan. Figure 1 shows the boundary of the RCWD within the City. The City has a strong commitment to improving water quality and reducing the impact that municipal operations can have on our environment. The City of St. Anthony is a recognized leader in the implementation of Green Technologies in Municipal Operations. They have received a Step 2 Green Steps Award from the MPCA for their municipal operations. The City has also received recognition for their: 1. Stormwater and Backwash Water Reuse Facility 2. Salt and sanding reductions in roadway de-icing operations 3. Street sweeping and municipal maintenance to reduce pollutant contact with storm water runoff In addition to the above, the City is currently exploring several technologies, some of which are described in this report, to further improve water quality and to reduce our impact on the environment. The City desires to comply with, or exceed, the water quality and volume control rules of RCWD. Furthermore, the City’s existing and proposed water quality initiatives are able to exceed the RCWD’s water quality standards. However, RCWD’s Rules and standard permitting process do not provide a streamlined method to account for water quality initiatives outside of the linear project area. Due to constraints common on linear projects, it has been necessary for the City to request volume control debits from RCWD to maintain street and utility infrastructure. The City is deeply concerned about the runoff volume debit that has accumulated, and debits for Street and Utility Reconstruction Projects will continue to occur if the current RCWD Rules and standard permitting process is continued. RCWD Rules require that runoff volume debits be offset by volume control BMPs elsewhere in the City. However, soil conditions throughout the City eliminate feasible opportunities for volume reduction BMPs. Therefore, under the current framework of RCWD Rules, the City will perpetually run a volume reduction deficit with RCWD and compliance is unattainable. This places the City Council in precarious position of appearing to be out of compliance with environmental regulations, despite their progressive efforts to improve water quality. This report addresses the RCWD’s Alternative Compliance Sequencing Requirements allowed under RCWD Rule C.5.f.2, and provides a plan to comply with water quality standards of the RCWD. Alternative sequencing is necessary for the City of St. Anthony to continue its Street and Utility Reconstruction efforts and to comply with RCWD Rules.