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10. Table 3-2 Existing District Facilities: Please add which city each facility is located in and any maintenance <br />agreements that exist with that specific City. <br />11. Section 3.2.4 Flooding: Please add a discussion on Atlas 14 rainfall values and changing rainfall patterns and <br />how that affects flooding within the District in the present and future. <br />12. Section 3.2.4.2. Impacts of land use changes: The City strongly encourages the District to delete this section. <br />We would encourage the district to share information about flood prone areas, volume constrained locations, <br />and other difficult drainage areas. The draft plan's emphasis on land use as the solution to these issues is <br />presumptuous. The City (as the land use authority) would welcome all comments on land uses that are <br />proposed with the City's comprehensive plan. Drainage issues are only one of a multitude of competing factors <br />that determine proper land uses for a parcel. Until there is extensive study and conversation with <br />municipalities about the District's desire to influence land use, we encourage,the District to eliminate any <br />language that might sound like a predetermination to deny drainage permits due to authorized land uses. <br />Clearly, the district can deny a drainage permit that doesn't meet district rules. This section appears pointless <br />in its current form. <br />13. Section 3.2.5 Water Quality Management: Chloride and other emerging contaminants (such as E. coli) should be <br />listed as an issue in this section. It seems these are going to become more of a concern in the future and the <br />District should discuss how they will start handling these. <br />14. Table 3-3 RCWD Excess Nutrient TMDLs: Please add what city each waterbody is located in. <br />15. Section 3.2.5.5 Surface Water Monitoring: Discuss in greater detail what the revisions to the chloride <br />management efforts will be in terms of monitoring and management. This could possibly be added to the <br />Implementation Table to mark as a higher priority for the District. <br />16. Section 3.2.5.6 Thank you for recognizing the benefits of stormwater re -use to the regional drainage network. <br />We appreciate the partnership with RCWD to build some of these systems. The City has multiple additional <br />stormwater re -use retrofit projects it would like to build. Increased funding for these projects from partners <br />such as RCWD will accelerate construction of these projects. <br />17. Section 3.2.6.2. Funding Distribution: The first factor listed for prioritizing funding is... location. The plan also <br />states that decisions need to be made by geographic needs. Some clarity is needed here to explain how <br />decisions are made to prioritize the needs of one location over another. We would encourage the District to <br />incorporate some form of geographic equity within the plan to ensure that all portions of the region benefit <br />from district projects in an equitable way. <br />18. Section 3.2.8.3. Permitting and Enforcement: The final policy listed in this section enables cities to assume <br />responsibility to administer district rules. This program as administered by the City of Hugo is efficient. It <br />streamlines the approval process, reduces redundancy, saves time, reduces development costs, promotes <br />business activity within the city, and should also result in significant cost savings to the RCWD. The District <br />should consider passing along a portion of these savings to the participating municipalities. <br />19. Section 3.2.9.2: Communication and outreach. The final "policy" in this section appears to be a statement. It is <br />not a policy, and is out context. It is also opposed to the general theme of this section which focuses on <br />sharing, openness, and transparency. <br />20. Table 4-1 Annual Budget: Suggest including funding to assist in City BMP maintenance projects. This could be <br />related to water quality implementation prioritization. <br />21. Section 4.2.2 Modeling and Planning Program: Comprehensive Stormwater Management Plans can also allow <br />for regional volume reduction projects (stormwater reuse) that generate volume reduction credits. If not in this <br />section, some discussion and policy language should be added to talk about this opportunity and any additional <br />