RES 1987-19 - 00004591027
' RES06UTMDN NO. 19 1987
RESOGUPIDN CONOMM RICE CREEK WATERS88a DISTRICT WATER
RESOURCES MAERGERM PLAN
WHEREAS, the Rice Creek Watershed District has prepared a water resources
management plan as required by Chapter 509 by the Laws of Minnesota of 1982;
and
WHEREAS, as part of said law such plans are to be sent to any city within the
district for comment as part of the overall review process; and
WHEREAS, such planning needs to be undertaken in a practical, cost effective,
and achievable manner; and
WHEREAS, the City of Fridley has reviewed this plan and finds it to be
generally acceptable in many aspects with the exception that there are areas
of potentially very serious impact on the City; and
WHEREAS, said areas of potentially very serious impact are set forth in
Exhibit A entitled RICE CREEK WATERSHED RESOURCES MANAGEMENT PLAN, CITY
COMMENTS.
' NOW, THEREFORE, BE IT RESOLVED that the City of Fridley hereby advises the
Rice Creek Watershed District that it finds the Water Resource Management Plan
to be generally acceptable with the exception of several areas of potentially
very serious impact as follows and more explicitedly detailed in Exhibit A:
1. Water quantity implementation.
2. Water quality protection.
3. Overall management of the Rice Creek trunk system.
4. Duplication of effort with other agencies.
5. High implementation cost.
6. Ditch modification restrictions.
7. Various city specific items.
BE IT FURTHER RESOLVED that the City Engineer of the City of Fridley is hereby
instructed to send this resolution expressing the City's serious concern to
the Rice Creek Watershed District before March 1, 1987.
PASSED AND ADOPTED BY THE CITY COUNCIL OF THE CITY OF FRIDLEY THIS 23RD DAY OF
FEBRUARY, 1987
WILLIAM J. NEE(tMAYOR
ATTEST:
SHIRLEY A. HAAPALA - ITY CLERK
i
028
' EXHIBIT A
RICE (REEK NATERSHD HATER RESiAiXffi NNUGMM PLAN
1. IT@I
Management implementation strategy concerning water quantity (Page V -15).
PROELIN
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 municipality is a laudable idea, but
it is too idealistic.
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 III -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. ITEn
Water quality protection and pretreatment approach (Page V -18).
PR{ELEi
Water quality control and/or pretreatment objectives are too stringent.
It will be difficult to achieve from an effective environmentally and
fiscally sound approach.
Quality control and /or pretreatment before all protected waters and gyp' ,
wetlands is impractical. Present RM rules permit use of public wetlands
as a method of pretreatment.
' CITY POSTPiON
The R(WD plan should identify and prioritize which of the water resources
are of greater public benefit. Sometimes it may be necessary to permit
trade -offs to provide protection of a greater public benefit. Use of an
existing wetland may be the most practical and cost effective method of
pretreatment to protect the more significant resource of a downstream
lake.
The plan must be flexible to recognize and permit quality control and /or
pretreatment methods which protect the most critical resource.
3. r1FM
4.
overall management strategy of the Rice Creek trunk storm sewer system
(Page V- 5) .
The plan as submitted does not identify existing district trunk problems
nor establish a program or commitment by the Rice Creek Watershed District
Governors to correct and manage the problems.
CITY PaSrl'I�i
a. The Rice Creek Watershed District Management Plan should use the M-20
computer run on the existing development and projected year 2,000
water quantity conditions. Any development or redevelopment within
the district would then be required to satisfy the existing condition
in water quantity design.
b. The plan should then specifically address the identified flooding,
erosion, and quantity problems providing the time frame for
identifying the most economical and cost effective solutions.
c. The Rice Creek Watershed Management Plan must then identify the trunk
system within the district (recommended outline attached). This trunk
system then becomes the specific responsibility of the Rice Creek
Watershed Board of Governors for correcting and managing in the plan.
Provisions should be incorporated that provide for the district
governors to coordinate and facilitate maintenance, repair, and
construction of improvements for non - mainline trunk projects involving
two or more municipalities, if requested.
Responsibilities of regulatory agencies and how these agencies will
interface with Rice Creek Watershed District (Page V -46).
1
Proposed Rice Creek Watershed Plan and proposed Plan Implementation Budget
' may reflect duplication of activities in areas relating to regulation,
planning, enforcement, and capital expenditures of current agency programs
including the following agencies and current programs.
a. DNR-- wetland management, shoreland protection, flood plain management,
ground water protection and fisheries management.
b. PCA— septic system regulation.
c. SWCD— sediment /erosion control
d. LCD (Lake Conservation District)- -water quality monitoring, lake
improvements.
e. MHD /water — potable water supply management authorities.
44 FO. 4W 57 ,I
RCWD Board should reevaluate and clearly define its role relating to water
quality /quantity matters to insure that RCWD programs and resultant
expenditures do not duplicate current activities of other agencies more
qualified to deal with specific water quantity or quality issues. Final
RCWD Plan should contain an Implementation Plan Budget and list of
Management Strategies that have been carefully reviewed by each agency to
insure current programs and expenditures are not duplicated. When local
' units of government must work directly with affected agencies to meet
statutory requirements or standards, RCWD need not be involved in review
capacity.
5. ITEM
High expenses to implement the plan (Page V -59 and VII -5).
The plan includes levels of expenditures for the period of 1986 through
1990 which are too high for the benefit received and do not adequately
take into account the impact these increased costs will have on the
property owners. The plan is not well focused to solve identified
critical problems and prioritize the available resources to address such
problems. City costs to complete the local plan by the January 1, 1990
deadline will be unnecessarily high due to the short time available.
The level of expenditures should be reduced. The schedule to achieve the
goals should be extended to better match the ability of the property
owners to pay for the work and to reflect a more realistic timetable for
accomplishment after the plan is finally approved. The expenditures
should give priority to and better focus on the serious problems of the
' watershed. The deadline for the local plan to be completed should be
changed to three years after the overall Water Resource Management Plan is
approved by the State Water Resources Board and copies given to the city.
Public ditches preserved as open channels (Page V -22).
Open channels are desirable from the standpoint of water storage,
groundwater recharge, and treatment. However, in some unchanged areas,
retaining ditches as open channels will be impractical and uneconomical
for development and detrimental to the health safety and welfare of the
community.
That the Rice Creek Watershed District plan provide for the replacement of
open channel ditches with enclosed drainage system where conditions
warrant.
7. 17EM
Locke Lake
031
Locke Lake DNR #2 -77p is a 23 acre lake located in the City of Fridley
immediately east of East River Road. Rice Creek flows through it. The
lake is only shown and identified once in the Rice Creek Watershed
District Plan.
CITY POSPIZON
Locke Lake should be included on MAPS 1,2, 3,4,5,6,7,8,9,10,11,12,13,15,16
and 17. In addition, Locke Lake should be listed on TABLE 12 page III - 4
as it is a DNR protected water.
Locke Lake should also be addressed within the Subwatershed 16 information
on page IV - 19.
The City supports the capital improvement project for sediment removal
from Locke Lake as noted in section VIII. Of particular concern is the
districts rational to special assess a portion of this improvement and
only upon a City petition while a similar project affecting Long Lake is
accomplished by the District with an ad - valorem tax levy. Locke Lake
should be dredged as a District maintenance action using District wide
f unds.
Recreational Parks
There are three parks located within the City of Fridley limits that are
' not correctly identified in the plan.
rl
MAHONOMEN PARK - An Anoka County Park is located on Rice Creek. This park
' should be identified on MAPS 5 and 7.
DUNES PARK - A City natural site located on the northwest end of the west
basin of Moore Lake. The park is shown on MAPS 5 and 7 but is too large
and disproportionate to the lake.
COMMUNITY PARK - A City multiuse park located west of Highway #47 and
adjacent to the Anoka County regional trail. The park is omitted from
MAPS 5 and 7.
9. ITM
Contamination Sites (II -39).
The plan addresses certain groundwater contamination sources within the
City of Fridley that are not properly noted.
CITY POSITION
MAP 10 identifies the Lyndale and 51st dump as item 29 located in Fridley.
This area is not within the City limits.
The Medtronics, National Pole and Wood, and ONAN sites (31,39,41) are
' listed as potential sources of groundwater contamination. The National
Pole and Wood site is composed of the current property awned by Medtronics
and Onan. With MPCA approval Onan has cleared its property and
constructed a buried vault while Medtronics has removed contamination soil
from their property. As a result of these actions, it may be more
accurate to use the term possible rather then potential as it relates to
these properties.
10. 17M
TR -20 Computer Model (III -12).
The plan outlines the TR-20 computer model capabilities and capacities
within section III but does not provide detail data on the Rice Creek
Trunk System.
CITY POSITION
Properties within the City experience flooding from Rice Creek. The TR-20
model is capable of computing peak discharge, times of occurrence and
water elevations at any desired cross section or structure. It is
therefore desirable to have the plan provide specific details on the
existing flood problem areas and future flooding problems so that they are
identified and appropriate corrective actions included in the capital
improvement portion of the plan.
C33
it is also desired to have the flows identified at the municipal
boundaries with time of concentration information so that design
parameters may be established which will reduce or eliminate additive
conditions and maintain acceptable flows through critical creek sections.
U. ITEM
District Storage Capacities (IV -10) .
The management goal is to reduce flooding but the objective to provide
additional storage capacity in TABLE 21 A -2 only identifies this policy
for five of the 24 subwatersheds.
The district should establish a policy and management goal to provide and
maintain sufficient retention and detention facilities within the Rice
Creek System to insure design rainfall events, snow melt and spring rains
will not exceed the individual critical section capacity, or contribute to
downstream flooding.
Major existing facilities should be returned to design volume and then
maintained at that capacity.
Detention within the major trunk system should be established to eliminate
cumulative runoff effects.
' Procedures should be established then operated by the District to insure
facility outlets are controlled to eliminate downstream flooding in
critical crossections of the trunk.
12. ITEM
Sub - Watershed 16 - Lower Rice Creek (IV -19).
The requirement to prevent localized flooding and additional storage
facilities (objective Al & A2) are not identified for the subwatershed nor
are, Moore Lake and the Locke Lake dam noted.
CITY POSITION
Objective Al and A2 should be listed as policies for subwatershed 16.
Major concerns within this subwatershed are elimination of recurring
flooding and bank erosion as well as maintaining the integrity of the Rice
Creek stream channel.
As the Rice Creek stream parallels the Anoka County Regional
Bikeway/Walkway and canoe system, the Watershed District should also
I coordinate with Anoka County to enhance the recreational opportunities
within the subwatershed as well as the City of Fridley in its management
of Moore Lake recreational facilities.
t
I
Objective C 13 A Minimize Public Expenditures to Control Runoff (V=3).
1 PF40ELEK
The Policies for objective A do not clearly define the District's
responsibilities or actions to control runoff at minimum cost.
An analysis of the existing retention and detention facilities in relation
to critical flooding and erosion areas is required. Then appropriate
action by the District Governors to obtain additional facilities and /or
maintaining existing facilities to prevent flooding from storm runoff
events is required to be defined.
Existing outlets from major system facilities should be controlled by the
District to insure rainfall events and water level conditions are properly
monitored and managed over the entire trunk.
IL
Waters of Regional Significance (V-12).
Moore Lake is one of the urban resources used for swimming and
' recreational purposes.
CITY POSTTION
Moore Lake should be listed as a water of Regional Significance. This
lake has been approved for Federal Clean Water funds. The state MPCA, DNR
and City have expended in excess of 1 million dollars in water quality
improvements.
15. ITEM
Water Quality Implementation Strategy (V =15).
The plan requires the municipalities to prepare computer models to def ine
100 year return frequency rainfall events and runoff rates to an
undeveloped condition.
034
435
CITY PosrrIax
The District has prepared a TR -20 model for the entire system. This
' information should be provided to each municipality to use in developing
their local water management plan rather then expending funds for a
duplicate process.
The undeveloped condition criteria is not realistic or economical. The
criteria that should be used is the existing condition as of the District
computer run and then allay any municipality to satisfy those existing
conditions or improve then if practical and possible.
16. IT821
Water Quality Monitoring - Streams (V-28).
PRAEK
Maintaining 22 stream stations 9 times per year is an expensive proposal
especially if the samples are not obtained during the first flush for each
rainfall event.
CITY PUSPFION
While stream quality data is beneficial, depending on the rainfall event,
time, location and area circumstances, the results will very considerably.
Periodic samples from various geographic or land use locations should
suffice to establish a base for comparison and quality reviews at a
' considerable cost saving.
1