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HomeMy WebLinkAboutEnviornmental Quality Committee Packet 11-14-2018 ENVIRONMENTAL QUALITY COMMITTEE AGENDA November 14, 2018 WHERE: Medicine Lake Room Plymouth City Hall 3400 Plymouth Boulevard Plymouth, MN 55447 CONSENT AGENDA All items listed on the consent agenda* are considered to be routine by the Environmental Quality Committee and will be enacted by one motion. There will be no separate discussion of these items unless a Committee member, or citizen so requests, in which event the item will be removed from the consent agenda and considered in normal sequence on the agenda. 1. 7:00 P.M. CALL TO ORDER 2. 7:00 P.M. PUBLIC FORUM – Individuals may address the Committee about any item not contained in the regular agenda. A maximum of 15 minutes is allotted for the Forum. 3. 7:20 P.M APPROVAL OF AGENDA - EQC members may add items to the agenda for discussion purposes or staff direction only. The EQC will not normally take official action on items added to the agenda. 4. 7:25 P.M. CONSENT AGENDA* A. Approve October 10, 2018 EQC Meeting Minutes 5. 7:30 P.M. GENERAL BUSINESS A. Surface Water Management Plan Update 6. REPORTS AND STAFF RECOMMENDATIONS A. Water Efficiency Grant Program Update 7. FUTURE MEETINGS: December 12, 2018 8. 8:00 P.M. ADJOURNMENT DRAFT Minutes Environmental Quality Committee (EQC) October 10, 2018 MEMBERS PRESENT: Committee Members Paul Senne, Marky Williamson, Andy Polzin, Kathy Osborne, Clark Gregor, Marita Prokop MEMBERS ABSENT: STAFF PRESENT: Public Works Director Michael Thompson, Senior Engineering Technician Ben Scharenbroich 1. Call to Order – 7:00 P.M. 2. Public Forum 3. Approval of Agenda Motion by Committee Member Polzin, seconded by Committee Member Williamson, recommending approval of the October 10, 2018 Environmental Quality Committee meeting agenda. With all members voting in favor, the motion carried. 4. Consent Agenda A. Approve September 12, 2018 EQC Meeting Minutes Motion by Committee Member Osborne seconded by Committee Member Williamson recommending approval of the Consent Agenda. With all members voting in favor, the motion carried. 5. General Business A. Accept Public Comment on the 2017 Storm Water Pollution Prevention Program Public Works Director Michal Thompson recapped that the purpose of tonight’s meeting was to accept public comments on the 2017 Storm Water Pollution Prevention Program (SWPP), and that this public meeting is one of the requirements of the annual MS4 reporting. He opened the discussion to the committee and any public member that were present to ask questions about or make comments on the plan. (One member from the general public was in attendance). Committee Member Polzin asked about the overlap between the SWPP and the city Surface Water Management Plan. Senior Engineering Scharenbroich explained that while there is a lot of overlap, the SWPP is reviewed annually, while the Surface Water Management Plan is a ten year plan. Senior Engineering Technician Scharenbroich indicated there were no big changes between the 2017 and 2018 programs other than changes to the city Street Sweeping program. He explained that the city has purchased a mechanical sweeper and the program will be conducted by public works maintenance staff instead of being outsourced, which allows the City to have better quality control of sweeping operations and better control of program costs. Committee Member Osborne asked if any lakes are showing significant improvement, or if any were significantly getting worse. Scharenbroich responded that Medicine Lake is showing Environmental Quality Committee Minutes October 10, 2018 Page 2 improvement. He said the Park District has an alum treatment scheduled for Medicine Lake in the next few years and hopes to continue improvements to get the lake de-listed. He furthered that Bass and Pomerleau lakes will also be getting alum treatments and working towards those two lakes being de-listed. 6. Reports and Staff Recommendations A. Water Efficiency Grant Program Update Senior Engineering Technician Scharenbroich reported that the city has installed soil moisture sensors and a smart controller at the Zachary Park playfields and is anticipated to save 780,000 gallons of water a year at the park. This will also save the staff from having to spend time overseeing the watering of the fields. 7. Future Meetings • Adopt a Street clean-up on Saturday, October 13th at noon. • November 14, 2018 – Annual Report and 2019 Work Plan 8. Adjournment Committee Chair Senne reminded the committee that the comment period for the Surface Water Management Plan was open until November 9th. Public Works Director Thompson announced that the Water Resources Manager position was posted and closes on October 29th. In addition to that position, another Technician will be hired in 2019. Environmental Quality Committee adjourned at 7:59 p.m. C:\Users\lstromberg\Desktop\Surface Water Management Plan Update - November.docx Agenda Number CITY OF PLYMOUTH ENVIRONMENTAL QUALITY COMMITTEE AGENDA REPORT DATE: November 9, 2018 for the EQC Meeting of November 14, 2018 TO: Environmental Quality Committee (EQC) FROM: Ben Scharenbroich, Senior Engineering Technician SUBJECT: SURFACE WATER MANAGEMENT PLAN ACTION REQUESTED: To receive update on Surface Water Management Plan update. BACKGROUND: Staff published the Draft 2019-2028 Surface Water Management Plan on September 10th, 2018 to comply with the rules and requirements of the 3rd Generation Plans (Minnesota Statute 103B.235) of each watershed management organization (WMO) within the City (Bassett, Elm, Minnehaha, Shingle), the Board of Soil and Water Resources (Minnesota Rule 8410) and the Metropolitan Council. Comments from the public have been received and are being reviewed; the public comment period ended on November 9th, 2018. BUDGET IMPACT: There is no direct budget impact to receive an update on the Surface Water Management Plan. RECOMMENDATIONS: I recommend the EQC receive an update on the Surface Water Management Plan and review the comments submitted to date. Attachment: Surface Water Management Plan Comments Received Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed9/13/2018 Julie OlsonBass Lake Improvement Assocation 17, 202, 225Email from Julie Olson 9-13-18: One item I will note is that I believe Bass Lake is 183 acres according to the latest DNR map that includes the lagoon which was dredged and connected to the lake in 1977 I believe. Some old maps have original 174 acres but we use the 183 acres map.*MN DNR has the lake listed at 182.47 acres *MPCA has the lake listed at 183.54 acres (impaired waters map) *Shingle Creek has the lake listed at 175 acresYes. MN DNR Acerage of 182.47 acres will be usedPg 42 (Map) Pg 225 Suggested 10/29/201810/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission EngineersUpdate the existing and proposed physical environment and land use. Information from previous plans that has not changed my be referenced and summarized byt does not have to be repeated. Local plans may adopt relevant sections of this Plan's Section 2.0 Inventory and Condition Assessment by reference unless the member city has more recent information, such as revised land use figures and data. The inventory and Plan should reference the Flood Insurance Program and where readers may obtain the most recent flood mappingChanges still neededRequired (Partially meets requiments currently)10/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission EngineersUpdate the existing and propose hydrology and provide subwatershed, storm drainage system, and installed BMP figures and shapefilesFigures depicting subwatershed, the drainage system, and installed BMPs are provided. "Drainage Calculations" are incorporated into the plan by reference, but it is not clear if this is H & H Modeling data or other data, and if it was performed using Atlas 14 or is planned to be updated."Drainage Calculations" relates to the tables that are included in the 2008 surface water management plan. Unsure how this data was derrived however we could plan to update this over the next 10 years.Yes, made change per commentpage 57 & 58Required (Partially meets requiments currently) 11/1/201810/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission EngineersExplain how the goals and policies, and rules and standards established in the WMP will be implemented at the local level. Appendix A provides an overview of conditions, problems, and implement actions for each of the 11 subwatersheds within Shingle CreekMeets requirements of the commission. No action is required NoNo action required 10/24/2018Surface Water Management Plan - Comments Received (as of 11/9/18) Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed10/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission EngineersExplain how the City will implement the City Review project review requirments of the revised Rules and StandardsThe plan does not acknowledge that development and redevelopment projects meeting certain thresholds must meet Commission rules and standards and are subject to commision review, and that projets meeting other standards must meet Commission requirements but may be reviewed at the local levelAdd table or wording to SWMP project review section outlining the review thresholds. Yes, made change per commentpage 51 & 260 Required 11/1/201810/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission EngineersUpdate existing or potential water resource related problems and identify nonstructual, programmatic, and structural solutions, including those program elements detailed in Minnesota Rules 8410.0160The plan presents problems and solutions and outlines them by watershedMeets requirements of the commission. No action is required NoNo action required 10/24/201810/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission EngineersSummarize the estimated cost of implementation and analyze the memer city's ability to finance the recommended actions.Costs of structural and nonstructural BMPs and operations and maintenance programming are present by yearMeets requirements of the commission. No action is required NoNo action required 10/24/201810/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission EngineersSet forth an implementation program including a description of adoption or amendment of offical controls and local policies necessary to implement the Rules and Standards; programs; policies; and a capital improvement plan.An implementation program is specified for each subwatershed. Note that the city-wide activities are shown leaves the impression that each table is the cost unique to that subwatershed when in fact it is the estimated cost city-wideNoted. Staff will look into adding wording for each subwatershed implementation table to better describe city-wide vs. subwatershed implementationYes, made change per comment Page 58 Suggested 11/1/201810/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission Engineers 41"All of the water bodies that are impaired in the State of Minnesota are listed on the 303(d) Impaired Waters List"All the waters that have been assessed as impaired are on the 303(d) list. There are likely many impaired waters that are not on the list because there is not adequate monitoring data or they havent been formally assessed yetNoted, the change will be madeYes Made the change as suggested pg 41 Required 10/31/201810/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission Engineers 42 - Table 4Add the Shingle Creek E. coli impairmentNoted, the change will be madeYes, made change per comment Pg 42 Required 11/1/2018 Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed10/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission Engineers50 - Figure 25The symbol colors for outlets and outfalls should be more distinguishableNotedThank you for the comment. To be consistant with city maps, the map will remain unchanged pg 50 Suggested 11/1/201810/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission Engineers53 Amendment procedureThis section should define the criteria distinguishing plan amendments that would be required to be reviewed and approved by the Commission, and those housekeeping-type amendments that would not require review and approval by the Commissionnoted, this addition will be included in the revised planChanges still needed Required10/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission Engineers213 - Schmidt Lake SubwatershedSuggest noting that this lake has been designated as an imapired water for excess nutrients, and a TMDL was completed. The lake was delistedi n 2014 due to improved water qualitynoted, this addition will be included in the revised planChanges still needed Suggested10/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission Engineers233 - Table 100 - Pike Lake Implementation ProgramWhat is the "Bass Lake Estates Stream Restoration" Project?Stream Restoration Project behind the homes on 61st Avenue N between Kirkwood Lane & Hemlock Lane. Project is planned for Design in 2022 and construction 2023. Budget = $500,000Changes still needed Suggested10/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission Engineers248 - Water Quality ControlsThe City's policy is to require rate control on any project that creates new or fully reconstructs more than one acre of impervious surface. The Commission's standard is based on project size, regardless of the area of new impervious surface (e.g., a 5 acre site with one-half acre of new impervious surface must meet rate control requirements.) The exception is linear projects where the threshold is one acre of net new impervious. noted, this addition will be included in the revised planChanges still needed Required Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed10/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission Engineersp. 249-250 - Water Quality ControlsPolicies regarding reducing E. coli and other bacterianoted, this addition will be included in the revised planChanges still needed Required10/5/2018Diane Spector & Ed MatthiesenShingle Creek Watershed Management Commission Engineersp. 253 - first bulletDo you mean Bass Creek instead of Shingle CreekYes, change will be included in the revised planChanges still needed Required10/19/2018Karen ChandlerBassett Creek Watershed Management Commission Page 9The City of Plymouth's strategy for improving water quality focuses on pollution prevention first and storm water treatment second. The plan goes beyond reacting to problems after they occur by implementing proactive programs and policies to protect surface waterThe Executive Summary focuses on the City's approach to addressing surface water quality issues. The Executive Summary does not discuss water quantity issues facing the City. Consider revising the Executive Summary to highlight a broader range of the existing and potential issues (also see comment regarding Page 41).The City will consider adding language into the Executive Summary that outlines water quantity issues facing the cityYes. Added language in the plan to outline water quantity and invasive species issues pg 9 Suggested 10/31/201810/19/2018Karen ChandlerBassett Creek Watershed Management Commission Page 11Partners with the City of Plymouth in improving water resources include the State of Minnesota, the Metropolitain Council, Hennepin County, Three Rivers Park District, the Bassett, Elm, Minnehaha and Shingle Creek WatershedsPlease revise the text to refer to the BCWMC and similar entities as "Watershed Management Organizations", or "WMOs" versus "Watersheds" to avoid confusion between the organization and the physical watershed. Yes, change will be included in the revised planYes. Changed WMO names as noted in comment pg 11 Suggested 10/31/201810/19/2018Karen ChandlerBassett Creek Watershed Management Commission Page 15The soil in Plymouth can be generally described as dense clay with occasional lenses of mixd sand and gravel (Figure 22). The three basic soil types are sandy clay till from the Des Moines ice lobe of the Wisconsin glaciation, natural silty sand and topsoil and organic silt deposits.Consider revising this section to describe the relationship between soil types, infiltration capacity, and runoff and referencing Figure 22 (Hydrologic Soil Group Information).The City will consider adding language into the Executive Summary that outlines water quantity issues facing the cityYes. Added language to discuss infiltration rates and runoff pg 15 Suggested 10/31/201810/19/2018Karen ChandlerBassett Creek Watershed Management Commission Page 16Additionally, each of these smaller watershed units is further broken down in the City of Plymouth into sub-watershed areas (Figure 4)The figure reference to Figure 4 is incorrect and should be revised to reference Figure 23 (Subwatershe Boundaries).Yes, change will be included in the revised planYes Made the change as suggested pg 16 Suggested 10/31/2018 Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed10/19/2018Karen ChandlerBassett Creek Watershed Management Commission Page 41Assessment of Existing or Potential Water Resource Related ProblemsThis section describes only surface water quality issues facing the City. Minnesota Rules 8410.0160 Subp. 3.D. states that local plans must contain the following: "An assessment of existing or potential water resource-related problems must be summarized. The problem assessment must be completed for only those areas within the corporate limits of the local government unit and similar to the process under part 8410.0045, subpart 7." Section 5.3.1.1 of the 2015 BCWMC Plan also requires local plans to address the problems idenfieded in the 2015 BCWMC Plan applicable to the City. The Plan must be revised to describe water resource issues within BCWMC's jurisdiction beyond those limited to water quality impairments. Issues relevant to the portion of the City within the BCWMC are described in Section 3 of the 2015 BCWMC Plan and include: water quantity and flooding, erosion and sedimentation, stream management, wetland, habitat, and shoreland management, groundwater, and stormwater system maintenace. These issues, to the degree they are relevant within areas subject to BCWMC jurisdiction, must be discussed in the City Plan. Yes, the city will review the BWCMC Plan Section 3 and changes will be included in the revised planYes, made change per comment pg 41/42 Required 11/2/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 48 - Table 7 Streams with approved TMDLsThis table must be revised to note that the fecal coliform impairment of Bassett Creek and the E. coli impairment of Plymouth Creek are addressed by the Upper Mississippi River Bacteria TMDL Study and Protection Plan completed in 2014. Yes, change will be included in the revised planYes Made the change as suggestedpg 48 & 258 Required 10/31/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 49 Figure 24Figure 24 - Minnesota DNR Protected Waters, Wetlands and CreeksConsider revising the title og Figure 24 to reflect the current MDNR Terminology of "Public Waters" versus "Protected Waters"Yes, change will be included in the revised planYes Made the change as suggested pg 49 Suggested 10/31/2018 Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed10/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPages 51-52 and Appendix BEntities currently having some level of administration responsibility within the City of Plymouth include the City of Plymouth, Bassett Creem WMO… the four watershed management organizations (Bassett, Elm, Minnehaha, Shingle) are responsible for: Water Quality, Lake, and stream Monitoring; local plan review and approval; projects of regional significance; education activiesThe SWMP generally notes that the BCWMC has some authority in the City and references City Official Controls. The text in Appendix B - Regulatory and Complaince Program further lists City Policies and Performance Standards. However, the SWMP does not describe the City's permit review process and cooperation with WMOs relating to permitting. The City Plan must outline the city's permitting process and must describe the City's collaborative role in the BCWMC review of development and improvement projects, as described in Section 5.1.1.1 and Section 5.3.1 of the 2015 BCWMC Plan.Yes, change will be included in the revised planYes Made the change as suggestedpg 51 & 259 Required 10/31/201810/19/2018Karen ChandlerBassett Creek Watershed Management Commission Appendix A Watershed AssessmentsThe SWMP is required to conform to Minnesota Statutes 103B.235. Minnesota Statues 103B.235 Subd. 2 include specific requirements for local plans, including: define drainage areas and the volumes, rates, and paths of storm water runoff existing and proposed physical environment. This information is incomplete in the SWMP, although much of this information may be incorporated by reference to the BCWMC watershed-wide XP-SWMM modeling results. The SWMP must be revised to reference this data.Yes, change will be included in the revised planYes The City is committed to updating the model in Elm, Shingle and Minnehaha Creek Watersheds as well as providing the BCWMC information to continually update their model. pg 58 Required 10/31/201810/19/2018Karen ChandlerBassett Creek Watershed Management Commission Appendix A Watershed AssessmentsBCWMC Priority Waterbody Classifications for lake and streams in the City are included on Page 59 of the City Plan. Consider including the BCWMC classification in the descriptions of each waterbody in the applicable subwatershed sections in Appendix AYes, change will be included in the revised planYes made change per suggestionPages: 64,72,88,92,100,120,125,129 Suggested 11/1/2018 Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed10/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 64 Appendix A Table 11Waters that do not meet their designated uses because of water quality standard violations are impaired (Table 11) and ultimately a Total Maximum Daily Load will be established at the maximum amount of a pollutant the water body can assimilate before becoming imapired. The City of Plymouth uses these assessments to develop nonstructrual, programmatic, and structural solutions to improving the water quality.Consider adding a footnote to Table 11 noting that the E. coil impairment of Plymouth Creek is addressed by the Upper Mississippi River Bacteria TMDL Study and Protection Plan completed in 2014. Yes, change will be included in the revised planyes made change per suggestion page 65 Suggested 11/1/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 66 Appendix AThe Upper Plymouth Creek Sub-watershed has one known impairment through the 2018 Impaired Waters list produced by the State of Minnesota. The TMDL Implementation Plan was approved by the Minnesota Pollution Control Agency in March, 2016 and will be implemented during the course of this 10-year Surface Water Management PlanThis section must be revised to note that there are two known impairments (in one waterbody) - the chloride impairment of Plymouth Creek and the E. Coli impairment of Plymouth Creek. The text must also be revised to clarify the TMDL(s) to which the text refers. If the reference to the approved 2016 TMDL refers to the Twin Cities Metro Area Chloride TMDL, the text must also note that the E. Coli impairment of Plymouth Creek is addressed by the Upper Mississippi River Bacteria TMDL Study and Protection Plan completed in 2014Yes, change will be included in the revised planYes, made change per comment page 67 Required 11/1/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 74 Appendix AThe Middle Plymouth Creek Sub-watershed has one known impairment through the 2018 Impaired Waters list produced by the State of Minnesota. The TMDL Implementation Plan was approved by the Minnesota Pollution Control Agency in March, 2016 and will be implemented during the course of this 10-year Surface Water Management Plan.This section must be revised to note that there are two known impairments (in one waterbody) - the chloride impairment of Plymouth Creek and the E. Coli impairment of Plymouth Creek. The text must also be revised to clarify the TMDL(s) to which the text refers. If the reference to the approved 2016 TMDL refers to the Twin Cities Metro Area Chloride TMDL, the text must also note that the E. Coli impairment of Plymouth Creek is addressed by the Upper Mississippi River Bacteria TMDL Study and Protection Plan completed in 2014Yes, change will be included in the revised planYes, made change per commentpages: 73 & 75 Required 11/1/2018 Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed10/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 90 Appendix AThe Parkers Lake Sub-watershed has two known impairments (Chloride & Mercury) through the 2018 impaired waters list produced by the State of Minnesota. Implementation of best management practices consisten with the TMDL Implementation Plan for Chloride will be implemented during the course of this plan.The text is inconsistent with Table 25 which lists mercury as the only impairment for Parkers Lake. Table 25 must be revised for consistency.Yes, change will be included in the revised planYes, made change per comment page 89 Required 11/1/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 102 Appendix AThe Lower Plymouth Creek Sub-watershed drains to three known impairments through the 2018 impaired waters list produced by the State of Minnesota. A TMDL plan has been approved for Medicine Lake and future TMDL plans will be developed for Plymouth Creek and Bassett CreekThis section must be revised to note that the E. Coli impairment for Plymouth Creek and the fecal coliform impairment of Bassett Creek (which is referenced as a downstream waterbody in this section) are addressed by the Upper Mississippi River Bacteria TMDL Study and Protection Plan completed in 2014.Yes, change will be included in the revised planYes, made change per comment page 103 Required 11/1/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 127 Appendix AThe Bassett Creek Sub-watershed drains to one known impairment through the 2018 Impaired Waters List produced by the State of Minnesota. A future TMDL plan will be developed for Bassett CreekThe Main Stem of Bassett Creek is subject to three impairments: chloride, fish bioassessments, and fecal coliform (see table 2-5 of the 2015 BCWMC Plan). This section must be revised to clarify the applicable impairments and reference the Upper Mississippi River Bacteria TMDL Study and Protection Plan completed in 2014. Yes, change will be included in the revised planYes, made change per comment page 128 Required 11/1/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 135 Appendix AThe North Branch Sub-watershed has no known impairments through the 2018 Impaired Waters List produced by the State of MinnesotaConsider revising this section to note that Northwood Lake, immediately downstream of the City, is listed as impaired due to nutrients. Yes, change will be included in the revised planYes, made change per comment page 138 Suggested 11/1/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 249 Appendix B Water Quality PoliciesPolicy 4.2.1-16 of the BCWMC Plan requires that member cities annually provide the BCWMC with plans for BMP construction within their City (to facilitate updates to the BCWMC watershed-wide water quality model). The SWMP must be revised to include this requirementNo Change necessary, already in plan Already in plan Page 250 Required 10/31/2018 Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed10/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 250 Appendix B Erosion Control PoliciesPolicy 4.3.4-54 of the BCWMC Plan requires, in part, that the member cities annually report to the BCWMC regarding complaince with BCWMC standards as part of annual MS4 reporting or as requested by the Commission. The SWMP must be revised to include this requirementYes, change will be included in the revised planYes Made the change as suggested Page 251 Required 10/31/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 251 Appendix B Wetland PoliciesPolicy 4.2.6-66 of the 2015 BCWMC Plan states: "For wetalnds classified as Preserve or Manage 1, member cities shall implement standards for bounce, inundation, and runoff control that are similar to BWSR guidance; member cities are encouraged to apply standards for other wetland classifications." The City's wetland ordinance does not include standards for bounce or inundation period for Preserve or Manage 1 wetlands (referred to as "exceptional" or "high" in the City wetland inventory and code). The SWMP must be revised to include bounce and inundation standards, or reference City Official COntrols including these standards. Yes, change will be included in the revised plan Change to City of Plymouth Zoning Ordinance - Wetlands District will be needed. This change is expected in early 2019page 252 Required 10/31/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 251 Appendix B Erosion Control Policies or wetland policiesPolicy 4.2.5-64 of the 2015 BCWMC Plan states: "Member cities shall maintain and enforce buffer requirements adjacent to priority streams… buffer widths adjacent to priority streams must be at least 10 feet or 25 percent of the distance between the ordinary high water level and the nearest existing structure, whichever is less." The SWMP must be revised to include this requirement or reference City Offical Controls that include this requirement. Yes, change will be included in the revised plan Change to City of Plymouth Zoning Ordinance will be needed. This change is expected in early 2019page 252 Required 10/31/201810/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 253 Appendix B Maintenance and inspection policiesPolicy 4.2.2-24 of the BCWMC Plan requires that member cities are responsible for routine maintenance and repair of BCWMC Flood Control Project structures located within each City. The SWMP must be revised to include this requirement Yes, change will be included in the revised planYes Made the change as suggested pg 253 Required 10/31/2018 Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed10/19/2018Karen ChandlerBassett Creek Watershed Management CommissionPage 258 Appendix C Table 11 Streams with approved TMDLsSee below comment regarding Page 48, Table 7 This table must be revised to note that the fecal coliform impairment of Bassett Creek and the E. coli impairment of Plymouth Creek are addressed by the Upper Mississippi River Bacteria TMDL Study and Protection Plan completed in 2014. Yes, change will be included in the revised planYes Made the change as suggested pg 258 Required 10/31/201811/7/2018 Jason SwensonElm Creek Watershed Management Commission GeneralNo discussion of floodplains was found in the Surface Water Management Plan. Discussion of the floodplains and maps showing the locations of mapped floodplains in the City should be included in the plan, either in the Watershed Assessments portion of the plan or in the Existing and Proposed Physical Environment Section. Indicate where interested parties can access the latest floodplain maps for the City. Yes, Section 21660 - Floodplain Overlay District of the Plymouth Zoning Ordinance discusses the floodplains and maps that show the locations within the City. Interested parties can access the latest floodplain maps in the Plymouth Engineering or Planning DepartmentsNo change required N/ANo action required 11/8/201811/7/2018 Jason SwensonElm Creek Watershed Management Commission GeneralThe plan does not make mention of what rainfall standards were used in the preparation of the Watershed Assessments Section. The plan should address what data was used in the preparation and include any discussion if updates are required to utilize Atlas 14 dataYes The City is committed to updating the model in Elm, Shingle and Minnehaha Creek Watersheds as well as providing the BCWMC information to continually update their model. Yes, made change per comment Page 60 Required 10/31/2018 Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed11/7/2018 Jason SwensonElm Creek Watershed Management Commission GeneralProvide clear indication of what roles the City and ECWMC play in development review. Specify what projects trigger review by the watershed and which projects can be reviewed internally by the CityYes, The city will add a document by reference that outlines the responsibility of the city & when projects should be reviewed by the ECWMCYes, made change per commentPage 8 , 53 , 263 Required 11/8/201811/7/2018 Jason SwensonElm Creek Watershed Management CommissionPage 262 Table 111 Streams with approved TMDLsTable 111 should be updated to reflect the current status of the approved Elm Creek TMDLYes, change will be included in the revised planYes, made change per comment Page 262 Required 11/8/201811/9/2018 Renae ClarkMinnehaha Creek Watershed District1.       An executive summary stating highlights of the local water plan.Meets requirements. Plan is organized according to MR 8410 and includes the general requirements. 11/9/2018 Renae ClarkMinnehaha Creek Watershed District2.       Identify MCWD data systems in the local plan and describe their application to LGU activity in order for the District to ensure that the LGU is aware of these systems and that they are being used for common intended purposes.Meets requirements. On Page 150 of 265 in Appendix A, the Plan contains a comprehensive write-up about MCWD, provides a history of MCWD, presents the goals of MCWD’s 2018 Management Plan, presents MCWD’s planned capital improvements in the City, and provides an assessment of the MCWD subwatersheds in the City along with a summary of subwatershed characteristics, assessment of problems, and an outline of implementation.11/9/2018 Renae ClarkMinnehaha Creek Watershed District3.       A summary of water resource management-related agreements, including joint powers agreements, into which the LGU has entered with watershed management organizations, adjoining LGUs, private parties or others.Meets requirements. Page 12 of 261 summarizes the organizations with which the City has joint powers agreements, including MCWD. 11/9/2018 Renae ClarkMinnehaha Creek Watershed District4.       Maps of current land use and land use at the LGU planning horizon.Meets requirements. Figures 19 and 20 depict existing land use and the 2040 land use plan, respectively. Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed11/9/2018 Renae ClarkMinnehaha Creek Watershed District5.       Maps of drainage areas under current and future planned land use with paths, rates and volumes of stormwater runoff.Meets requirements. Figures 19 and 20 depict existing land use and the 2040 land use plan, respectively. Figure 23 depicts subwatershed boundaries without flow directions. Figure 25 provides a storm sewer system map including flow direction. Figures 26-64 depicts the City’s subwatersheds with flow direction indicated on each figure. “Drainage Calculations” are incorporated into the plan by reference. Please clarify if this is H & H modeling data or other data, and if it was performed using Atlas 14 or is planned to be updated. Appendix B (Page 248-249) covers manners in which the City plans to address rates and volumes of stormwater runoff to reduce the potential for flooding and water quality. 11/9/2018 Renae ClarkMinnehaha Creek Watershed District6.       A stormwater conveyance map meeting standards of the current MS4 general permit and indicating an outfall or a connection at the LGU boundary.Meets requirements. Figure 25 provides a storm sewer system map including flow directions and water quality ponds. MS4 permit requires stormwater flow direction in the pipes, outfalls with unique ID numbers and geographic coordinates, structural stormwater BMPs and receiving waters. City’s MS4 Permit indicates the unique ID numbers and geographic coordinates have been assigned. 11/9/2018 Renae ClarkMinnehaha Creek Watershed District7.       An inventory of public and private stormwater management facilities including the location, facility type and party responsible for maintenance (e.g., landowner, homeowner’s association, LGU, other third party).Partially meets requirements. Appendix B on Page 250 states that the City will manage its properties in accordance with appropriate and innovative BMPs as an example for its citizens. Page 9 incorporates the City’s Pond Maintenance Policy by reference. The analysis of the subwatersheds (Pages 63- 247) located within the different WMOs (including MCWD) in the City provides good information on maintenance requirements for public ponds. Page 253 indicates the City shall require maintenance of privately owned water quality treatment ponds and water quality BMPs as outlined in maintenance agreements, and the City requires adequate access to these facilities for inspection and maintenance purposes. However, an actual inventory of public and private stormwater management facilities is not presented. Please address. Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed11/9/2018 Renae ClarkMinnehaha Creek Watershed District8.       A listing and summary of existing or potential water resource-related problems wholly or partly within LGU corporate limits. A problem assessment consistent with Minnesota Rules 8410.0045, subpart 7, is to be completed for each. This includes but is not limited to: - Areas of present or potential future local flooding. - Landlocked areas - Regional storage needsMeets requirements. Water resource-related problems are addressed starting on Page 41. Water quality and water quantity issues are addressed in the Citywide goals (Page 43). The subwatershed analyses provide information on specific areas with flooding issues. Appendix B (Page 248) identifies the regulatory measures the City has taken to address potential flooding issues. Within Appendix B, the City states that it encourages regional detention area whenever practical.11/9/2018 Renae ClarkMinnehaha Creek Watershed District9.       A statement of the process to amend the local plan, consistent with Minnesota Statutes §103B.235.Meets requirements. Amendment Procedures are covered in a section that begins on Page 53.11/9/2018 Renae ClarkMinnehaha Creek Watershed District10.       Inventory of real property owned by the LGU, including discussion of (i) water resource issues and opportunities associated with its properties, and (ii) potential opportunities to coordinate with the District or other partners.Partially meets requirements. The subwatershed analyses present discussions of water resource issues and opportunities associated with parks and other areas, and potential partnerships are also presented. Please provide an inventory of all real property (municipal buildings, lots, etc.) owned by the City. 11/9/2018 Renae ClarkMinnehaha Creek Watershed District11.       Incorporates the inventory and description of practices from its SWPPP regarding facilities that it owns or operates and municipal operations that may contribute pollutants to groundwater or surface waters.Does not meet requirements. City’s MS4 Permit states that the City will review and update its facility inventory to include city-owned facilities that contribute pollutants. While Appendix B (Page 250) states that a response plan to minimize the impact of hazardous spills in accordance with the MS4 Permit, an inventory is not provided in the Plan. You may provide a link to other plans and data located outside the LWMP.11/9/2018 Renae ClarkMinnehaha Creek Watershed District12.       Include map and inventory of stormwater management facilities, including responsible party and maintenance condition and schedule.See #7 above. Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed11/9/2018 Renae ClarkMinnehaha Creek Watershed District13.       A description of the LGU’s approach to maintenance of stormwater management practices constructed in conjunction with private development.Meets requirements. Appendix B (Page 253) contains a section that addresses maintenance and inspection of water resource facilities, including private facilities. 11/9/2018 Renae ClarkMinnehaha Creek Watershed District14.       Information related to the issue of deferred maintenance of public and private stormwater management practices, to inform a cooperative approach to addressing the issue (optional).Not addressed.11/9/2018 Renae ClarkMinnehaha Creek Watershed District15.       Identify those areas within or adjacent to the LGU that the LGU has designated in its CLUP for potential development or redevelopment within the CLUP planning horizon. This includes planned rezoning, land assembly, and infrastructure extension or expansion.Meets requirements. The subwatershed analyses (Pages 63- 247) address development/redevelopment within each subwatershed throughout the City. 11/9/2018 Renae ClarkMinnehaha Creek Watershed District16.       List and describe completed or programmed small area plans and similar planning activities to assess the LGU’s role with respect to defined-area redevelopment.Meets requirements. Potential redevelopment areas are identified in the subwatershed analyses (Pages 63-247). opportunity sites. Land use planning and rezoning are addressed in the 2040 Comp Plan Draft. Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed17.       Describe the procedures by which the LGU plans, programs and implements each of the following:  Transportation infrastructure  Sewer and water infrastructure  Park and recreation land acquisition and management  Conservation land acquisition and management  The description should include the date of the most recent approved capital implementation or land acquisition and management program, the frequency of program updating, the internal procedures to develop and approve the implementation program and to implement specific actions, and how programming and implementation is coordinated with other LGU activities.11/9/2018 Renae ClarkMinnehaha Creek Watershed DistrictPartially meets requirements. A Transportation Plan is included as Appendix 6A of the City’s 2040 Comp Plan Draft and procedures for parks planning are outlined in the same document. The LWMP outlines several completed and planned sewer infrastructure projects on a subwatershed basis with an implementation program outlined in Appendix C (Page 261). Appendix B (Page 250) states that the City shall acquire easements covering ponds, wetlands, flood plains, streams and ditches as part of land development proposals.The date of the most recently-approved CIP is not provided, and no hyperlink is provided, although information on MCWD’s CIP is provided in Table 60 (Page 153) as well as Bassett Creek, Elm Creek & Shingle Creek are also provided. Page 11 suggests that the City’s Surface Water Fee has provided and will continue to provide the majority of funding for LWMP implementation.Please provide a link to the most recently approved CIP and a brief description regarding City planning, prioritization and implementation processes for items listed in 17. Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed11/9/2018 Renae ClarkMinnehaha Creek Watershed District18.       Provide links to small area/redevelopment plans, capital implementation programs, and land acquisition and management plans listed pursuant to item 17.Partially meets requirements. MCWD, Shingle Creek, Bassett Creek and Elm Creek capital implementation plans are presented the LWMP – no hyperlinks provided. City’s Implementation Program provided at Appendix C on Page 261. The City’s approach to land acquisition for the purposes of environmental protection is described on Page 28 of the 2040 Comp Plan Draft. Please reference and provide links to any existing plans listed in No. 17 above.19.       Evaluation of LGU’s official controls with respect to the integration of water resource and conservation protection.·         Explain regulatory tools that create incentives to consolidate development footprint to protect resources (e.g., conservation development, clustering, density credit, transfer of development rights)·         Dedication or development fees applied to support acquisition or consolidation of public park, recreation or conservation land, particularly as directed toward acquiring or protecting priority water resource areas·         Setbacks and/or other vegetated buffer requirements with respect to wetland or other surface waters, reconciled with other terms of its development code that restrict development footprint ·         Tree preservation policy11/9/2018 Renae ClarkMinnehaha Creek Watershed DistrictPartially meets requirements. Page 43 addresses the role of official controls for surface water planning and management, the agencies/LGUs with administration responsibility are presented on Page 51, and the official controls are outlined in Table 8 on Page 52. Wetland buffer classifications are referred to on Page 251 and are described in the City Zoning Ordinance. Please describe how regulatory tools create incentives to consolidate development footprints to protect resources. Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed20.       Identify other regulatory mandates concerning water resources under which the LGU operates, including LGU’s role, responsibility, and compliance status. Include Procedures for enforcement. Specifically addressing the following:Meets requirements. Water resource management related agreements to which the City must adhere are presented on Page 12. ·         NPDES Ms4 stormwater program·         Page 41 lists the MS4 permit as one with which the City must comply. Page 250 outlines the City’s responsibilities regarding erosion control under the MS4 Permit and Page 253 outlines maintenance and inspection requirements. ·         TMDL program *Impaired waters referend and TMDL framework incorporated ·         Page 41 describes the TMDL process; Page 44 notes the City will continue to support comprehensive monitoring to identify progress toward meeting water quality goals. ·         State and Federal anti-degradation requirements·         Pages 194 and 195 refer to nondegradation goals of the Shingle Creek Watershed Management Commission (ECWMC), and on Page 195 the City indicates its commitment to assist in meeting the goals of SCWMC.·         Safe drinking water act/wellhead protection program·         Page 8 states that the Wellhead Protection Plan is incorporated into the SWMP by reference; the City indicates its commitment to assisting with meeting the goals of Elm Creek Watershed Management Organization and SCWMC on pages 138 & 195, respectively; Page 254 indicates the City will develop and ·         NFIP, State floodplain management law·         Table 8 on Page 52 lists the City’s Floodplain Overlay District as one of the City’s official controls. City’s commitment to assisting ECWMC and MCWD are outlined on pages 137 and 152, respectively – each organization’s role in floodplain management is addressed. ·         State Shoreland Management Law·         Table 8 on Page 52 lists the City’s Shoreland Management Overlay District as one of the City’s official controls. ·         WCA·         Appendix B (Page 251) indicates the City will administer wetland protection and mitigation in accordance with WCA and the City’s Zoning Ordinance – no changes to that structure proposed.11/9/2018 Renae ClarkMinnehaha Creek Watershed District21.       Identify District assistance or coordination that would benefit any of these programs.Meets requirements. Coordination with MCWD is stated and implied throughout LWMP.11/9/2018 Renae ClarkMinnehaha Creek Watershed District Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed22. Describe how regulatory activities are coordinated with the District.·         How are potential permit applicants made aware of District permitting requirements·         Provide department(s) and positional contact information for regulatory coordination and how this coordination will be initiated by LGU11/9/2018 Renae ClarkMinnehaha Creek Watershed District23. Contains an implementation program, consistent with MN Rules 8410.0160.Meets requirements. Page 43 provides an implementation plan; Appendix C (Page 261) provides an Implementation Program with anticipated capital costs. 24.       Sets forth a coordination plan that connects the LGU and District in ways that efficiently provide for timely coordination.·    Annual meeting to review SWMP implementation·    Transmittal of MS4 report·    Describes how the District can receive notice of and consult with the LGU on its land use planning, infrastructure, park and recreation, and CIP efforts11/9/2018 Renae ClarkMinnehaha Creek Watershed DistrictPartially meets requirements. The Implementation Program of the subwatershed analyses within the MCWD indicate that the District’s stormwater rules would apply; the manner in which these or other permit applicants are made aware of District permitting requirements is not clear. Several individuals involved in drafting the LWMP are listed on Page 2; contact information is provided on the website that users will open to access the LWMP. Please include this information within the coordination plan outlined in No. 24 below. ·    Describes when and how LGU will provide notice on small area plans and other focused development or redevelopment actions·    Regulatory coordination – describe how LGU will share information and coordinate on the following:                                                   i.      Pre-application and permit reviews                                                  ii.      Construction site inspection and compliance                                                iii.      WCA where LGU is WCA authority                                                iv.      Implementation of District Rules where LGU is rule authority for any of MCWD rulesDiscussion of coordination opportunities now, on the horizon and/or requested in the future11/9/2018 Renae ClarkMinnehaha Creek Watershed District25. For each element in 24 above, describe when and how the communication will occur and indicate the department and position for proposed communication plan.Partially meets requirements. Individuals involved in drafting the LWMP are listed on Page 2; contact information is provided on the website that users will open to access the LWMP. However, the LWMP does not cover when and how communication will occur regarding points in #24 above and does not indicate the department and position responsible for communication. 11/9/2018 Renae ClarkMinnehaha Creek Watershed DistrictPartially meets requirements. Coordination with MCWD is stated and implied throughout the LWMP. The subwatershed analyses (Pages 63- 247) refer to MCWD rules and present opportunities for coordination. However, a stand-alone coordination plan pursuant to the MCWD Plan, Appendix A, paragraph 5 is key elements of MCWD’s Water resources Plan and implementation approach. Please coordinate with MCWD staff to provide. • Coordination efforts with MCWD regarding potential projects are set forth in several of the subwatershed analyses throughout the LWMP. However, the LWMP does not provide details on how the District will receive notice regarding planning, infrastructure, park and rec, and CIP efforts. • The LWMP does not specifically address when and how notice will be provided on small area plans and other development/ redevelopment actions. • As stated in previous bullet, the LWMP either states or suggests that coordination for the listed elements will occur, but it does not cover how that coordination will look Date Received Received From AffiliationComment Page #Watershed Local Plan Requirement / SWMP TextCommentPlymouth Staff Comment ResponseAre changes needed & reflected in the plan?Reflected on Page(s)Suggested or Required?Date Addressed11/9/2018 Renae ClarkMinnehaha Creek Watershed District26. Discussion of coordination opportunities now, on the horizon and/or requested in the futureMeets requirements. The City’s official controls are presented on Page 51, with an additional summary presented in Appendix B (Page 258). Appendix B (Page 251) indicates the City will administer wetland protection and mitigation in accordance with WCA and the City’s Zoning Ordinance – no changes to that structure or to any MCWD authority proposed.11/9/2018 Renae ClarkMinnehaha Creek Watershed District27. State whether the LGU intends to assume the role of “local government unit" responsible to implement the Minnesota Wetlands Conservation Act (WCA) or whether it chooses for the District to assume that role.Meets requirements. Appendix B (Page 251) indicates the City will administer wetland protection and mitigation in accordance with WCA and the City’s Zoning Ordinance – no changes to that structure proposed.11/9/2018 Renae ClarkMinnehaha Creek Watershed District28. Metropolitan Council Recommendations - Comments dated October 12, 2018The plan is consistent with Council policies and the Council’s Water Resources Policy Plan and provides a good overall framework for the City to successfully manage its water resources.