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on-site, as the State rules guided mitigation to be on site. Since that time, the WCA rules have changed to favor purchase of banking credits. Therefore, this item has been revised. 18. Prior to providing outlets to landlocked areas, the City will evaluate the impact of these outlets on downstream areas in conformance with City policies. City policy states the following: "The City of Hugo may provide an outlet to landlocked basins, provided that the discharge rate from these basins not exceed the critical duration 100 -year storm, that it can be demonstrated that this discharge will not significantly impact the downstream flood profile, wetlands not be drained (unless exempt as per the Wetland Conservation Act), and dead water storage to retain runoff from back-to-back 100 -year, 24-hour rainfall events is provided." This activity has occurred and will continue to occur. 19. Outlets will be required to conform to the RCWD policies. This activity has occurred and will continue to occur. 20. Stormwater will be treated to RCWD and City standards, which includes NURP treatment. Rate control and treatment will be provided through the use of a regional system associated with the ditch in cooperation with on-site treatment to meet the RCWD and City standards. The developers will be required to implement the stormwater management plan outlined as part of Option C in this AUAR. This is ongoing, and portions of the system have been constructed as part of the approved developments. 21. The City will review TMDL studies when completed and revise City practices and/or the AUAR as needed. The Centerville and Peltier Lakes TMDL study has been completed. This study identifies phosphorus as the pollutant causing the impairment in the lakes and has resulted in the need to reduce the external phosphorus loading from Hardwood Creek or Clearwater Creek by between 46 and 62%. A number of possible projects to address this load reduction have been identified in the November 2011 report "Capital Improvement Plan for Stormwater Projects within the City of Hugo" (WSB). Four possible projects in this study are located within the Everton Avenue AUAR study area. The Upper Mississippi River Bacteria TMDL study has been completed. This study identifies E. coli as the pollutant causing impairment in the river and has resulted in the need to reduce the external E. coli loading to Rice Creek between 4.8 and 44%. The City of Hugo already has a number of existing ordinances related to pet waste and septic systems. The City has also applied for, and received, several inflow/infiltration grants to fund the costs Final Alternative Urban Areawide Review Update Page 6 Everton Avenue Neighborhood City of Hugo, MN WSB Project No. 10373 September 2017