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<br />- <br />~-'- <br />- - =~-- ~ ~ -~._----- <br />~ --,-.,.~~ -~ <br />- ._~ -- ---- <br />c-"> ~ __ -=r-~~ ~-...~~ <br />-.::;, <br /> <br />~~_;_;),!.. _~;' 1 L-' '~~:;>~' ,- 1: l _ ~;;lf <br /> <br />We will analyze several specific <br />program and policy mitigation <br />strategies, including dedication of <br />land to permanent open space. <br /> <br />TASK 2: ANALYSIS <br /> <br />With the loading assessment in hand, we will compare pollutant loading <br />and volume for the three points in time. We will then proceed to identify <br />BMPs that may be implemented to bring loadings to 1988 levels if such <br />mitigation is necessary (our estimate of hours assumes it will be and this <br />has been the trend with other loading assessments). We will focus on <br />reasonable and practical BMPs to be implemented by Elk River. We will <br />also provide discussion of which alternatives have been rejected and why. <br /> <br />The first source of possible BMPs is the City's current storm water pollution <br />prevention pmgram (SWPPP). Our analysis will begin with a review of the <br />BMPs already in the City's SWPPP and the extent to which they will <br />mitigate the water quality changes identified in the Loading Assessment. <br />After this step, we will consider other additional mitigation options. Any <br />additional mitigation options agreed upon by the City will be included in <br />the Nondegradation Report. <br /> <br />According to the MS4 permit, a high priority should be given to BMPs that <br />address impacts from future growth. Retrofits and mitigation for past <br />development must also be considered. Mitigation strategies could take the <br />form of programs or policies or retrofit projects. Our work plan describes <br />our assumed level of effort in regard to each of these. <br /> <br />We will analyze the following specific program and policy mitigation <br />strategies: <br /> <br />. Dedication of land to permanent open space <br /> <br />. Targeted infiltration and treatment standards wit~ redevelopment projects <br /> <br />. Targeted infiltration or treatment standards with street reconstruction <br />projects <br /> <br />. Increased volume and pollutant control from new development {increased <br />over current City standards} <br /> <br />. Maintaining currently landlocked areas as landlocked, or partially <br />landlocked, in the future development condition <br /> <br />. Cost/benefit of individual BMPs and their most appropriate use <br /> <br />. Other programs and policies such as increased street sweeping <br /> <br />We do not propose to develop site specific retrofit projects at this time. We <br />will identify drainage areas where retrofit BMP's provide more treatment <br />per dollar of investment. It would then be up to the City to weigh the <br />feasibility of one project location versus another. <br /> <br />TASK 3: RECOMMENDATIONS <br /> <br />The results of Tasks 1 and 2 will become the subject of the <br />Nondegradation Report, which combined with the Loading Assessment, <br />will be delivered to the MPCA by December 1, 2007. Our schedule calls for <br />delivery of a 95% Nondegradation Report to the City on September 1, <br />2007. <br /> <br />-# Bonestroo <br /> <br />8 <br />