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<br />Item # 6.2. <br /> <br />March 7, 2005 <br /> <br />League of Minnesota Cities <br />145 University Ave. West <br />St. Paul, MN 55103 <br /> <br />RE: Implications of the Upcoming Nondegradation Requirements for Municipal <br />Separate Storm Sewer System (MS4) Cities <br /> <br />To Whom It May Concern: <br /> <br />The City of Elk River is in full support of restoring and maintaining the chemical, <br />physical and biological integrity of waters of the State through management and <br />treatment of urban storm water runoff; however, the City feels it necessary to request an <br />extension for the nondegradation requirements for MS4 Cities. The City is scheduled to <br />submit their plan for nondegradation of all waters and, if appropriate, modify the City's <br />Storm Water Pollution Prevention Program by October 6, 2006. <br /> <br />This time frame puts a huge financial burden on the City since money has not been <br />budgeted to complete the requirements. Even if the City had money for these <br />requirements, the city would be unable to complete them in the allowed time frame. We <br />are actually unsure of how costly these requirements might be, since no criteria has been <br />set for calculating flow volume and pollutant loadings back to 1988 levels. The City <br />would like to see the Minnesota Pollution Control Agency (MPCA) establish some <br />criteria for calculating flow volume and pollutant loadings as well as establish guidelines <br />for communities to use to sustain the levels through future developments. The city is <br />pleading for an extension on this time frame so accurate and complete information can be <br />obtained to meet the requirements. <br /> <br />Sincerely, <br /> <br />Stephanie Klinzing <br />Mayor of the City of Elk River <br />