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. - ~ '. EXHIBIT A RICE CREEK WATERSHED WATER RESOURCES MANAGEMENT PLAN CITY COMMENTS 1. ITEM Management implementation strategy concerning water quantity (Page V-15). PROBLEM The Management Plan states "The local water management plan must demonstrate that for a 100-year return frequency rainfall event, the rate of storm water runoff leaving the municipality will not exceed the rate storm water runoff leaves the municipality in its undeveloped condition." This strategy creates a much higher goal than the current strategy of required new development to have storm water runoff rates equal to the existing condition. Developed municipalities will have difficulty attaining this goal in a cost effective and environmentally sound manner. Municipalities will need to purchase additional land for ponding. Trying to reduce outflow rates from a muncipality is a laudable idea, but it is too idealistic. CITY POSITION The management implementation strategy concerning water quantity should require cities to maintain the existing storm water runoff rates as established per the TR-20 model results referred to on Page 111-26 of the Management Plan. New developments and redevelopments shall have storm water runoff rates equal to the existing condition. If opportunities are available, redevelopments shall have storm water runoff rates equal to undeveloped condition. The problem statement in the plan should be more detailed and stated more concisely. The plan shall then recommend a solution to the identified problems . 2. ITEM Water Quality protection and pretreatment approach (Page V-18). PROBLEM Water quality control and/or pretreatment objectives are too stringent. It will be difficult to achieve from an effective environmentally and fiscally sound approach.