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MS-4 Nondegradation: Approve Distribution of Plan CITY OF CHANHASSEN 7700 Market Boulevard PO Box 147 Chanhassen, MN 55317 Administration Phone: 952.227.1100 Fax: 952.227.1110 Building Inspections Phone: 952.227.1180 Fax: 952.227.1190 Engineering Phone: 952.227.1160 Fax: 952.227.1170 Finance Phone: 952.227.1140 Fax: 952.227.1110 Park & Recreation Phone: 952.227.1120 Fax: 952.227.1110 Recreation Center 2310 Coulter Boulevard Phone: 952.227.1400 Fax: 952.227.1404 Planning & Natural Resources Phone: 952.227.1130 Fax: 952.227.1110 Public Works 1591 Park Road Phone: 952.227.1300 Fax: 952.227.1310 Senior Center Phone: 952.227.1125 Fax: 952.227.1110 Web Site www.ci.chanhassen.mn.us 3 - MEMORANDUM ..,-?' 0 ' TO: Paul Oehme, Director of Public Works/City Engineer \. < FROM: Terrance Jeffery, Water Resources Coordinator ~r ~ February 11, 2008 DATE: SUBJ: MS-4 Nondegradation, SWMP-15B: Approve Distribution of Plan SUMMARY Staff is recommending that the Nondegradation Assessment be submitted to the Minnesota Pollution Control Agency in compliance with the NPDES Phase II permit as revised June 1,2006. A public hearing was held at the January 15,2008 Planning Commission. The City of Chanhassen was required to submit the non degradation Plan to the Minnesota Pollution Control Agency in compliance with the NPDES Phase II permit as revised June 1, 2006 by February 1,2008. Staff has communicated with the MPCA a request to extend the deadline to February 12, 2008. This extension was granted. ACTION REQUIRED A simple majority vote of City Council present. BACKGROUND In June of 2006, the Minnesota Pollution Control Agency(PCA)issuedPermit No. MNR040000 - General Permit Authorization to DischargeStormwater Associated with Municipal Separate Storm Sewer Systems (MS4). Among other items, this permit identified 30 select cities which are required to develop a Nondegradation Assessment and Implementation Plan within a certain time frame. These communities are referred to as "Selected MS4s". The selection of these communities was based upon population growth experienced or projected to be experienced for three time frames: 1990 to 2000; from 2000 to 2003 and from 2000 to 2020. The City of Chanhassen is required to submit theirnondegradation assessment plan within 20 months (February 1,2008) from the dateofissuance.of the above-referenced permit. The City h'as requested an extension of the submittal date to February 12, 2008 to allow for coordination with scheduled City meetings. Wenck Associates, Inc. was the Nondegradation Plan on October 31, 2006. A draft of the plan has been attached for your review. The The City of Chanhassen · A growingc9_f~~}IJljJm~ljgs~eft,Jl~8b~~\82~P6l!sAfpqgWlllV\l\a~OJ'l,~town, thriving businesses, winding trails, and beautiful parks. A great place to live, work, and play. Paul Oehme MS-4 Nondegradation: Approve Distribution of Plan February 11, 2008 Page 2 Nondegradation Plan was presented to the Planning Commission on January 15, 2008 and public comment was received at this time. Copies of the Nondegradation Plan have been sent to Riley-Purgatory-Bluff Creek Watershed District, Lower MN River Watershed District, Carver County Watershed Management Organization, Minnehaha Creek Watershed District and the Metropolitan Council Environmental Services on December 15, 2007. The Plan has also been made available on the City's website and printed copies are available at City Hall. Written comments have been received from the Metropolitan Council Environmental Services, the Lower MN River Watershed District and seven Chanhassen Residents. These comments have been included for your review and consideration. Staff and a representative from Wenck will be making a short presentation on the assessment findings and subsequent timeline of events. NONDEGRADA TION REQUIREMENTS The selected MS4s are required to assess changes in base loading of three parameters to their waters from 1988 loading levels. These three parameters are total stormwater volume, total suspended solids (TSS) and total phosphorus (TP). If new or expanded discharges are found to exist or to be likely to exist, the City of Chanhassen must develop a nondegradation plan which will need to be developed and submitted to the PCA identifying what reasonable and practical best management practices (BMPs) the City will implement to reduce these discharges to the 1988 levels. These BMPs will be incorporated as revisions to the existing Storm Water Pollution Prevention Plan (SWPPP) for the City of Chanhassen. SUMMARY OF NONDEGRADA TION FINDINGS The City of Chanhassen has already implemented a number of policies and practices which have aided in the reduction of pollutant loading to area waters. These include street sweeping, reforestation measures, tree preservation, planning tools such as density transfer and the Bluff Creek Overlay District, and others. As a result, the City is projected to meet nondegradation requirements for total phosphorus and total suspended solids for the City as a whole. However, there are individual watersheds which will not meet nondegradation requirements for TSS and TP. These areas include Lake Ann which has experienced minimal development to date but, based upon proposed land uses through 2020, will undergo land use changes which will affect the loading of Lake Ann. The Riley, Purgatory and Bluff Creek Watersheds will also not meet nondegradation requirements. This is not inconsistent with the fact that many of these waters are listed as impaired by the PCA. The PCA has yet to determine if the assessments will be applied on a citywide basis or on a per watershed basis. g:\eng\terry\npdes phase ii\nondeg\021108 app dist of plan.doc Paul Oehme MS-4 Nondegradation: Approve Distribution of Plan February 11, 2008 Page 3 The City will not meet the nondegradation requirements for total stormwater volume. As areas within Chanhassen are converted to an urbanized land use the amount of impervious surface increases and there is a net reduction in native vegetation. Vegetation acts to intercept rainfall before it reaches the ground and becomes runoff. This process is referred to as abstraction. Additional, construction activities compact the soils and this soil compaction decreases the ability of water to seep (or infiltrate) into the soil and increases the amount of stormwater that runs off the site. This overall increase in impervious surface and decrease in native vegetation results in an increase in total runoff volume. Impacts from this increase in runoff are evidenced by the accelerated erosion within Bluff Creek and the bouncing (fluctuation) of lake levels within Chanhassen Lakes. IMPLICA TIONS FOR CHANHASSEN The City is required to submit a Nondegradation Plan to the MPCA by February 1,2008 (extended to February 12, 2008 per subsequent agreement). Prior to submittal to the PCA, the City is required to publicly notice the proposed SWPPP revisions as related to the Nondegradation Report and Implementation Plan and the Nondegradation Report and Implementation Plan must be made available to the public and to local water authorities, including the Lower Minnesota River Watershed District, the Riley-Purgatory-Bluff Creek Watershed District, the Minnehaha Creek Watershed District, and the Carver County Watershed Management Organization. By permit directive, the City must "consider alternatives, explain which alternatives have been studied but rejected and why, and propose alternatives that are reasonable and practical. The report must give high priority to BMPs (best management practices) that address impacts of future growth such as ordinances for new development." This language recognizes the difficulties with retrofitting storm water management techniques into developed areas and that changes are better suited to new development where land use constraints aren't as pronounced. Upon approval of the Nondegradation Plan by the PCA, the City will need to begin revising their Stormwater Pollution Prevention Plan (SWPPP) to incorporate changes in practice, policy and education necessary to bring those areas which will not meet nondegradation requirements to a level consistent with 1988 loading. The staff will continue to work with local water authorities, City Council and Planning Commission to determine how to best achieve the desired outcomes. The proposed SWPPP revisions within the Nondegradation Plan direct the City to begin the due diligence necessary to determine which, if any, code changes are necessary; what existing practices can be incorporated into the SWPPP; what additions or revisions to educational programming are needed and what partnership opportunities are available; and what changes to street, pond and g:\eng\terry\npdes phase ii\nondeg\0211 08 app dist of plan.doc Paul Oehme MS-4 Nondegradation: Approve Distribution of Plan February 11, 2008 Page 4 structural BMP maintenance and operations are needed. The revised NPDES permit and SWPPP will then be provided to the agencies for their review. At this time, no specific changes are proposed to the SWPPP other than the City begins evaluating alternatives on their merits and incorporate those accepted changes at a later date. The City of Chanhassen already has a number of practices and planning tools in place which can be incorporated into the SWPPP with minimal revision. As an example, these tools include the City's Tree Preservation Plan, the Arbor Day Event, the Bluff Creek Overlay District, and density transfer. Staff has begun researching the changes to policy, practice and education incorporated by other Cities and Local Water Authorities and will apprise the Council of their findings at future meetings. RECOMMENDA TION Staff is recommending that the City Council authorizes the distribution of the Nondegradation Assessment Plan on February 12, 2008 to the Minnesota Pollution Control Agency per NPDES Phase II requirements. ATTACHMENTS 1. Chanhassen's Draft Nondegradation Assessment prepared by Wenck Associates dated December 2007. (text only) 2. Letter of comment from the Metropolitan Council dated December 26,2007. 3. Email from Shelley Strohmaier dated 1/14/08 4. Email from Dave Susla dated 1/14/08 5. Email from Joe Pfankuch dated 1/15/08 6. Email from Mary Borns dated 1/15/08 7. Email from Steve Donen dated 1/15/08 8. Email from Scott Maeyaert dated 1/15/08 9. Email from Greg Fletcher dated 1/15/08 10. Memorandum from Boonestroo on behalf of the Lower MN River Watershed District dated January 8, 2008 (received via email on February 1,2008) g:\eng\terry\npdes phase ii\nondeg\021108 app dist of plan. doc Chanhassen Nondegradation Assessment Review D R AFT Prepared for: City of Chanhassen, Minnesota December 2007 __ __ __ - I - - - - - - -- --- - - - I -- ---, Wenck File #1481-03 Prepared for: CITY OF CHANHASSEN, MINNESOTA Prepared by: WENCK ASSOCIATES, INC. 1800 Pioneer Creek Center P.O. Box 249 Maple Plain, Minnesota 55359-0249 (763) 479-4200 Chanhassen Nondegradation Assessment ReviewD RA F T December 2007 ~Wenck Table of Contents 1.0 INTRODUCTION .................................. .;................................................................... ....... 3 1.1 Introduction.......................................... .................................................................. ......... 3 2.0 LAND USE AND P8 MODELING ....................................................................................4 2.1 P8 Model Construction and Organization....................................................................... 4 2.2 Land Use Assessment ................................ ...................................................... ............... 5 2.3 Imperviousness Assessment................ ....... .................................................... ............... 10 2.4 Pervious Curve Numbers .............................................................................................. 12 2.5 Other P8 Inputs.......... ......................... ................................................................ .......... 13 2.6 Model Validation and Assumptions.... ............................................................... ........... 13 3.0 CURRENT WATER QUALITY TREATMENT CAPACITY ........................................ 15 3.1 Applicable Rules, Codes and Ordinances ..................................................................... 15 3.1.1 Chanhassen Codes and Ordinances ...................................................................... 15 3.1.2 Riley-Purgatory Creek-Bluff Creek Watershed District....................................... 15 3.1.3 Minnehaha Creek Watershed District ................................................................... 16 3.1.4 Lower Minnesota Watershed District ................................................................... 16 3.2 Treatment Device Quantification............ ...................................................................... 16 3 .3 Year Built For Developments............ ........................ ......................................... .......... 16 3.4 Application of Rules ..................................................................................................... 18 3.5 Street Sweeping...................................................................................................... ...... 19 4.0 MODEL RESULTS......... .................................................................................... ............. 20 4.1 Organization............................................................... .................................... ................ 20 4.2 Load Changes.......................................................... .............................................. ........ 20 4.3 Current BMP Treatment......................................... ...................................................... 22 4.3.1 Development Rules......................................... ...................................................... 22 4.3.2 Street Sweeping.................................................................................................... 23 4.3 .3 Volume......................................................................... ......................................... 24 4.3.4 TSS Loading............ ..... ....... ................................................................................. 24 4.3.5 TP Loading............... ........... ................................... ............................................... 25 4.4 Model Sensitivity............... ........................................................................................... 25 5.0 SUMMARY AND PROPOSED BMPS ........................................................................... 27 5.1 Total Suspended Solids..... ...... ......... ............................. ........................... ..................... 27 5.1.1 Regulatory Program ..................................,............ .................... ...... ...................... 27 5.1.2 Street Sweeping .................................................................................................... 28 5.1.3 Lake Ann Subwatershed ....... ............................... ................. ................................ 28 5.1.4 Other Activities........................................................................ ............................. 29 5.2 Total Phosphorus ............................................................................ .............................. 29 5.2.1 Regulatory Program................................................................ ..... ......................... 29 5.2.2 Street Sweeping.................................................................... ................................ 29 5.2.3 Lake Ann and Riley-Purgatory-Bluff Creek Subwatersheds................................ 30 5.2.4 Other Activities............................................................................ ......................... 30 5 .3 Volume........... ...... ............... ....... ................................... ................................................ 30 5.3.1 Regulatory Program ............. .............................................. ................................... 31 5.3.2 Education Program... ........... .................................................................................. 33 5.3.3 Structural Improvements..... ............................ ...................................................... 33 5.3.4 N on structural Improvements... ....................... ...................................................... 34 6.0 SWPPP MODIFICATIONS.......... ................................................................................... 36 6.1 Total Suspended Solids.............................................................................. ................... 36 6.1.1 Regulatory Program .............................................................................................. 36 6.1.2 Street Sweeping .................................................................................................... 36 6.1.3 Lake Ann Subwatershed ............. ................................ ................. ......................... 36 6.1.4 Other Activities.. ......................... ............................. ................. ..... ....................... 37 6.2 Total Phosphorus....... ............................ ........................ ................. .............................. 37 6.2.1 Regulatory Program.................................. ............ ...................... .......................... 37 6.2.2 Street Sweeping................................................................... ........................ ......... 37 6.2.3 Lake Ann and Riley Purgatory Creek Subwatersheds .......................................... 37 6.2.4 Other Activities................................................................... ................... ............... 38 6.3 Volume............................................................................................................. ............. 38 6.3.1 Regulatory Program. .............................................................................. ............... 38 6.3.2 Education Program... ......... .................................................................................... 38 6.3.3 Structural Improvements ...... ................................................................................. 39 6.3.4 N on structural Improvements .......................... ...................................................... 39 TABLES Table 2.1. Current status of UAA analyses in the City of Chanhassen. ........................................ 4 Table 2.2. Land use categories for the City of Chanhassen. .......................................................... 5 Table 2.3. Land use acreages in the City of Chanhassen for the three key time periods............... 5 Table 2.4. Impervious fractions by land use from the UAAs, LANDSAT analysis, and those fractions used in this study............ ....................... .................... ........................ ..... 10 Table 2.5. Digitized impervious and pervious acres for commercial and industrial areas in Eden Prairie. ................................................................................. ................... ............... 10 Table 2.6. Total change in upland imperviousness in the City of Chanhassen. .......................... 12 Table 2.7. Curve numbers by land use and soil type. .................................................................. 12 Table 2.8. Runoff and loading by curve number from a test watershed in P8............................. 13 Table 2.9. Monitored and predicted volume and water quality for Purgatory Creek. ................. 14 Table 3.1. Estimated areas that developed under watershed district rules by subwatershed....... 18 Table 3.2. Riley-Purgatory Bluff Watershed District rules. ........................................................ 18 Table 3.3. Minnehaha Creek Watershed District rules. ............................................................... 18 Table 3.4. Lower Minnesota River Watershed District rules. ..................................................... 19 Table 3.5. Measured mass of material removed from street sweeping in the City of Chanhassen. ........................... ........................... ......... ..................... .............. ............................. 19 Table 4.1 . Raw increases in imperviousness, volume, TSS, and TP for the City of Chanhassen from 1990 to 2020... ................................... .......... ........ .......... ................. .............. 21 Table 4.2. Predicted TSS and TP load increases between 1990 and 2020 and estimated removal due to development rules. ............................ ....................... .................... .............. 22 Table 4.3. Particle size breakdown by NURP particle size class for three samples taken from street sweepings in Eden Prairie. .......................................................................... 23 Table 4.4. TSS and TP removal as a result of street sweeping in the City of Chanhassen.......... 23 Table 4.5. Predicted volume increases in the City of Chanhassen between 1990 and 2020. ...... 24 Table 4.6. Predicted TSS load increases between 1990 and 2020 in comparison to BMP removals. ...... ......................................................................................................... 24 Table 4.7. Predicted TP load increases between 1990 and 2020 in comparison to BMP removals. ...............................................................................................................................25 Table 4.8. Rice Marsh subwatershed TSS loading and removals for the 50th and 90th percentiles of the NURP studies...................... ........ ............... ................................................. 26 Table 4.9. Rice Marsh subwatershed TP loading and removals for the 50th and 90th percentiles of the NURP studies.................... .............................. ............................................ 26 FIGURES Figure 2.1. Subwatershed Map ...................................................................... ..... ...................... ......6 Figure 2.2. 1990 Land Use....... ...................................................................... ........................... ...... 7 Figure 2.3. 2000 Land Use....... ...................................................................... .......................... .......8 Figure 2.4. 2020 Land use.............................................................................. ............................. ....9 Figure 2.5. MPCA 1998 Landsat Imagery (% Impervious)..........................................................11 Figure 3.1. Hennepin County Year Built by Rule Change ...........................................................17 Figure 5.1. Annual Stormwater Volume That Could Be Captured Through Abstraction/Infiltration ................... ........ ...... ... ....................... ................... .................... .... ........... .31 TECHNICAL APPENDICES A East Chaska Creek B Lake Ann C Lake Lucy D Lake Mitchell E Lake Riley F Lake Susan G Lotus Lake H Lower Minnesota River I Minnehaha Creek WD J Rice Marsh Lake K Riley Purgatory Bluff Creek WD L Silver Lake M Sweepings Analysis N Analytical Methods Detail Executive Summary This study is completed in response to the Nondegradation Assessment requirement of the Minnesota Pollution Control Agency as part of the City's National Pollutant Discharge Elimination System (NPDES) Phase II permit. The purpose of this study is to assess changes in storm water runoff volume, total suspended solids (TSS) and total phosphorus (TP) loading in the City of Chanhassen since 1988, and to predict how land change expected to occur between now and 2020 would impact those parameters. This analysis is to be used to identify Best Management Practices to be undertaken to return to 1988 or better conditions. A key component of this analysis is an assessment of the change in impervious surface due to land use change. The percent impervious area varies in the City, with most subwatersheds between 20 and 35 percent impervious. 1990 16% 2000 20% 2020 28% This analysis estimated the pollutant loads and stormwater volumes for three key years - 1990 (a proxy for 1988), 2000, and 2020. Much of the land use change in Chanhassen since 1988 occurred under regulation to protect water quality. Additionally, the City currently undertakes Best Management Practices (BMPs) to improve water quality. The pollutant load and volume reductions associated with those BMPs were estimated to determine the net impact to stormwater volume and TSSffP load since 1988 and predicted to occur between now and 2020. Removal bv BMP Net Total Total Total Develop- Removal (-) Parameter Load Load Increase Street or Net 1990 2020 1990-2020 ment Sweeping Increase Rules (+) Total 1,274,100 2,060,167 786,067 933,108 254,446 -401,488 Suspended lbs/yr Ibs/yr lbs/yr lbs/yr lbs/yr lbs/yr Solids Total 4,555 7,243 2,688 3,073 589 -974 Phosphorus lbs/vr Ibs/yr lbs/yr lbs/yr lbs/yr lbs/yr Runoff 5,488 8,324 2,836 None None +2,836 Volume acre-feet acre-feet acre-feet estimated estimated acre-feeU /year /year /year year For the period 1990-2020, this study estimates the City will remove about 400,000 more pounds ofTSS than created since 1988, and 1,880 pounds more TP than created. For these two parameters, the City meets the MPCA requirement of no net increase in TSS and TP over 1988 conditions. However, land use change will generate 2,836 acre-feet of new runoff volume. To address this increase in stormwater volume, the City has identified several new BMPs that will over time either reduce stormwater volume or minimize the adverse effects of additional City of Chanhassen Nondegradation Assessment 1 D R AFT December 07 stormwater volume. Managing stormwater volume has the additional benefit of reducing TSS and TP loading by reducing the amount of runoff picking up and transporting pollutants to downstream waters. These BMPs include: . A new requirement on development and redevelopment to abstract (remove from runoff by infiltration, evapotranspiration, capture and reuse, etc.) a portion of annual runoff volume; · Reducing additional stormwater runoff volume through evapotranspiration by developing and implementing a reforestation program; · Retrofitting volume management BMPs where opportunities arise, such as on City street reconstruction projects; and · Mitigating volume impacts by stream restoration, erosion control projects, and shoreline restoration. City of Chanhassen Nondegradation Assessment 2 DR AFT December 07 1.0 INTRODUCTION 1.1 Introduction This study is completed in response to the Nondegradation Assessment requirement of the Minnesota Pollution Control Agency as part of the City's National Pollutant Discharge Elimination System (NPDES) Phase II permit. The purpose of this study is to assess changes in stormwater runoff volume, total suspended solids (TSS) and total phosphorus (TP) loading in the City of Chanhassen since 1988, and to predict how land change expected to occur between now and 2020 would impact those parameters. This analysis is to be used to identify Best Management Practices (BMPs) to be undertaken to return to 1988 or better conditions. A nondegradation assessment consists of three key steps: 1. An assessment of change in land use and imperviousness in the city from 1988 to present and out to 2020 conditions. 2. An associated pollutant load change with the land use change for total phosphorus, total suspended solids, and water volume. 3. Identification of current of necessary BMPs to return to 1988 conditions or better. This study is organized as follows: 1. A description of the City, land use change since 1988, and change expected to occur between now and 2020. 2. A description of the method used to calculate imperviousness and the results. 3. A description of the various input parameters used to model pollutant loading and stormwater runoff volumes. 4. A review of the existing BMPs designed to reduce pollutant loading, including a history of watershed and city rules and ordinances regulating development and redevelopment; the maintenance of sump manholes that collect material washed into the storm sewer system from the landscape; and the street sweeping program. 5. A detailed presentation of the results of water quality and quantity modeling reported by subwatershed in the city. These results estimate the amount of new TSS and TP loading and stormwater runoff volumes resulting from land use change in the City. 6. An analysis of the amount of pollutant loading removed by the BMPs described above. 7. The net impact of those BMPs in reducing the increased TSS and TP load and new stormwater volume. 8. Identification of new BMPs the City could undertake to return to 1988 conditions or better, or mitigate the impacts of increases. 9. Proposed modifications to the City's Storm Water Pollution Prevention Plan to plan to implement those BMPs. City ofChanhassen Nondegradation Assessment 3 D R AFT December 07 2.0 LAND USE AND P8 MODELING 2.1 P8 Model Construction and Organization Modeling for much of the City has already been completed through the preparation of Use Attainability Assessments (UAAs) for many of the lake watersheds in Chanhassen by the Riley- Purgatory-Bluff Creek Watershed District (Table 2.1). The UAAs include both watershed load modeling and in-lake response modeling. The UAAs are used to identify potential improvement projects and estimate the costs to restore the waterbody to meet selected water quality goals. UAAs have not been completed for Lake Minnewashta nor Rice Lake. T bl 2 1 C fUAA . h C' fCh h a e . . urrent status 0 analyses m t e Ity 0 an assen. Watershed Water Body Status Riley-Purgatory-Bluff Creek Mitchell Lake Completed Rice Marsh Lake Completed Lake Riley Completed Lake Susan Completed Lotus Lake Completed Lake Lucy Completed Lake Ann Completed Silver Lake Completed Minnehaha Creek Lake Minnewashta Not Completed Lower Minnesota Rice Lake Not Completed The UAAs include a P8 model developed for each of the lake watersheds. P8 - Program for Predicting Polluting Particle Passage thru Pits, Puddles, & Ponds - is a public domain (http://wwwalker.net/p8/). industry standard model developed to assess pollutant loading in urban watersheds. P8 was developed using National Urban Runoff Program (NURP) data and provides loading estimates based on data collected as a part of the NURP program. P8 was designed to assess the effectiveness of BMP implementation in reducing runoff loads from impervious surfaces and provides a tool for evaluating other non structural practices such as street sweeping. These models represent the best tools available for predicting watershed loads under current conditions. The models provided by the watershed districts were the basis for the City's assessment. For the assessment, the P8 model subwatersheds were maintained as well as the device configurations. However, imperviousness and the pervious curve numbers were updated based on evaluations of land use, LANDSAT data, and aerial photo interpretation. Selection of these input variables is described later in this report. It is important to note the modeling is not focused on absolute values, rather the purpose is to assess relative change among the time periods. The modeling does need to be close to real world values to assess the impact of current activities on loading. The modeling was developed for this purpose and is not intended to be a calibrated loading model. City of Chanhassen Nondegradation Assessment 4 D R AFT December 07 The analysis was conducted according to the receiving water including ten lakes (Figure 2.1). Although the analysis focused on changes in loading to the lakes, the subwatershed detail was maintained in the model for future evaluation of projects on water quality. 2.2 Land Use Assessment Land use data was collected from the City of Chanhassen, which used the same land use categories to classify land use in 1990, 2000, and planned 2020. These data were combined into a representative group of categories (Table 2.2, Figures 2.2, 2.3 and 2.4). 1990 data was selected as a surrogate for 1988 because land use data was readily available for 1990 and not 1988. Little change occurred in the City between 1988 and 1990. The resultant coverages are the best estimate of land use for the three critical time periods including 1990,2000 (present) and 2020. These data were compiled for the City of Chanhassen (Table 2.3). The 2020 land use coverage assumes build-out conditions and that no agricultural or vacant land will remain in the City. A near doubling of the land area used as single-family residential is expected between 1990 and 2020, along with significant increases in industrial and office uses. Large-lot rural residential uses are also expected to be converted to other, more intense uses. T bI 2 3 L d . th Ct f Ch h ~thth kf 'd a e . . an use acrea esm e uyo an assen or e ree ey . lme perlO s. Land Use Categories 1990 Land use (acres) 2000 Land Use (acres) 2020 Land Use (acres) Agriculture 2,880 1,639 0 Commercial 246 246 310 Industrial 327 557 848 Maior Highway 443 447 794 Multi Family Residential 60 96 517 Office/Institutional 58 98 392 Open Water 1,636 1,636 1,636 Parks 1,461 1,762 1,967 Rural Residential 1,568 1,425 1,055 Railway 104 104 108 Single Family Residential 2,447 3,641 4,713 Vacant 1,112 691 2 Wetlands type 1,2,6,7,8 591 591 591 Wetlands type 3,4,5 1,647 1,647 1,647 TOTAL 14,581 14,581 14,581 City of Chanhassen Nondegradation Assessment 5 D R AFT December 07 Legend ~ Oly of Chanhassen BoundafY [;> Lakes Maj or Roads Subwatersheds c:3 East Chaska Creek c:s Lake Ann C3 Lake Lucy c::3 Lake Mitchell III LakeRiley III Lake Susan C3 Lotus Lake c:3 Lower MN River III Mn nehaha Creel< III Rice Ma-sh Lake c:3 Riley Purgatory Bluff Creek (East) III Ril~ Purgatory Bluff Creel< (West) III Silver Lake Subwatersheds (Source: CUyof Chanhassen) 0.5 o :<<.I: L:\1481 \1 ~81.03w.:<<l\finE'l Flgs1Flgure 2.1 Su~'elUled Wep.mxd as! Modi ~ed: 11912007 11 :27:50 Mol CITY OF CHANHASSEN Subwatershed Map 1 I Miles I ~Wenc WenCk Assoclares I I nc. 1800 Pioneer Creek Center Environmental Engineers Maple Plain, MN 55359-l)129 JUL 2007 Figure 2.1 City of Chanhassen Nondegradation Assessn1ent 6 D R AFT December 07 n01: . Legend ~ City of Chanhassen BoundaiY 1990 Land Use .". Agri cu Ilure Rural R esidenlial Single Family Residential ~ Multi Family Residential .". Com me ri cal .". Ind usl.ri al o fn cell nsti tu ti ona I ",. Parks Vacant Wetland Types 1,2,6,7,8 ",. Wetland Types 3.4 ,5 ",. Open Water ",. Major Highway ",. Rail 1990 Land Use (Source: City of Chanhassen) 0.5 o 1 I Miles N J ..r, 1\ M>tl: L:\1481 \1481-03w.xd\final Figs~lgu~ 2.21990 Land U~.lfl);d Leu Mocfi6ed: 11912007 11 :45:55 ~M CITY OF CHANHASSEN 199'0 Land Use I ~Wenc WenCk Assoclares, I nc. 1800 Pioneer Creek Center Environmental Engineers Maple Plain, MN 55359-l)129 JUL 2007 Figure .2.2 City of Chanhassen Nondegradation Assessn1ent 7 D R AFT December 07 Legend ~ City of Chanhassen Boundary 2000 Land Use ",. Agricul to re Rural Residential Single Family Residential ~ Multi Family Residential ",. Commerical .". Industrial Officell n stitut:io na I ",. Par'<s Vaca nt Wetland Types 1,2,6,7 ,8 ~ Wetland Types 3,4,5 ",. Open Water ~ Major Highway ",. Railro a d 0.5 o 2000 Land Use (Source: City of Chanhassen) M>tl: L:\1481 \1481-03w.xd\final Figs~lgu~ 2.3 2000 Land U~.lfl);d Leu Mocfi6ed: 11912007 11 :41:38 ~M 1 I Miles N J ..r, 1\ I ~Wenc WenCk Associates, I nc. 1800 Pioneer Creek Center Environmental Engineers Maple Plain, MN 55359-l)129 JUL 2007 Figure 2.3 CITY OF CHANHASSEN 2000 Land Use City of Chanhassen Nondegradation Assessn1ent 8 D R AFT December 07 Legend D Oly of Chanhassen Boundary 2020 Land Use ", Agriculture Rural Residenlial Single Famity Residential 11M Multi Family Residential ". Commerical ",. Industrial OfficeJl n stituti on al ". Parks Vacanl Wetland Types 1,2.6.7.8 ". Wet.land Types 3.4.5 ",. Open Water ~ Major Highways ~ Railroad ~01: 0.5 o 2020 Land Use (Source: City of Chanhassen) 1 I Miles N J ..r, 1\ Mxd: L:\1481 \1481.03Vn)XI'Final Figs'Flgure 2:.4 2020 land UreJfl >>:I last Modi~ed: 71912007 11 :49:29 Nt! I ~Wenc WenCk Assoclares, I nc. 1800 Pi oneer Creek Center Environmental Engineers Maple Plain. MN 55359-l)129 JUL 2007 Figure 2.4 CITY OF CHANHASSEN 2020 Land Use City of Chanhassen Nondegradation Assessn1ent 9 D R AFT December 07 2.3 Imperviousness Assessment To estimate the imperviousness in the City, assumed percent imperviousness by land use from the watershed district supplied models and LANDSAT imagery were assessed (Table 2.4; Figure 2.5). The LANDSAT impervious fraction is an area-weighted average of imperviousness for all pixels or partial pixels falling in each land use classification. The values were in relative agreement except for commercial and industrial areas. Aerial photos were analyzed to determine the imperviousness of these two land uses. The selected values for the modeling were chosen based on aerial photo interpretation or based on an evaluation of LANDSAT estimated imperviousness as well as knowledge of the area and to provide a conservative approach. Table 2.4. Impervious fractions by land use from the UAAs, LANDSAT analysis, and those fractions used in h' d t IS stu Iy. LANDSAT Impervious UAA Impervious Selected Impervious Land Use Fractions Fractions Fractions Agriculture 0.11 0.03 0.05 Commercial 0.58 0.85 0.67 Industriall 0.51 0.75 0.55 Multi-Family Residential 0.33 0.65 0.55 Parks and Recreation Areas 0.07 0.02 0.10 Office/Institutional 0.35 0.50 0.35 Railway 0.09 N/A 0.20 Roadway 0.36 0.50 0.50 Rural Residential 0.09 N/A 0.09 Single Family Residential 0.20 0.30 0.25 Vacant 0.11 0.03 0.05 h Verified through aerI31 photo analysIs. N/A = Not available An aerial photo assessment of impervious areas in the adjacent City of Eden Prairie evaluated a total of 376 commercial acres as well as 628 industrial acres (Table 2.5). Impervious and pervious areas were digitized to estimate the area of impervious surfaces in these land use categories. Although they represent a very small area, parking lot islands were considered impervious because of soil compaction in these areas. Commercial areas were determined to be approximately 67% impervious while industrial areas were determined to be 46% impervious. Commercial development in Chanhassen is very similar to Eden Prairie. However, the LANDSAT impervious fraction for industrial was 51 %, and 75% was used in the UAAs. This study used 55% as the impervious fraction for industrial uses based on the LANDSAT data. T bl 2 5 D'"f d' d ~ '1 d'd t'l . Ed Pr' 'e. a e . . l2IllZe ImpervIous an . pervIous acres or commercia an m us rI3 areas m en alrI Category Commercial Industrial Acres Percent Acres Percent Pervious 123 33% 341 54% Impervious 253 67% 287 46% TOTAL 376 100% 628 100% City of Chanhassen Nondegradation Assessment 10 DR AFT December 07 Legend It:J Qly of Cllan hassen Boun dary 2:) Lakes - Major Roads 1998 Landsat (l>/o Impervious) D0-10% D 11-20% D 21-30% . 31-40% .41-50% D 51-600/00 D 61- 700/00 .7'1-80% . 81-90% .91-1000/0 ~...... ~ :'I..,; fIIIII r rI ~~,.. "t;. ~.. ! -. ~ T .~...~~ ~~ i.i h\ -~ ~ I . of.", r:t. . I' ~t..... .J .' · L.r- ~~.'.' Landsat Imagery (Source: MPCA) 0.5 0 1 I Miles N J .or, 1\ M:<<J: L:\1481 \1 ~81.03~:<<I\finE'l FIgs1Flgure 2.s lMdS$' lmngery.rnxd lod. MocUe:d: 71912007 11 :51:06 AM CITY OF CHANHASSEN MPCA 1998 Landsat Imagery (0/0 Impervious) I ~Wenc WenCk Assoclares. I nc, 1800 Pioneer Creek Center Environmental Engineers Maple Plain, MN 55359-l)129 JUL 2007 Figure 2.5 City of Chanhassen Nondegradation Assessn1ent 11 D R AFT December 07 Upland areas (areas excluding lake and wetland surface areas) in the City went from 16% impervious in 1990 to a projected imperviousness of 28% in 2020 (Table 2.6). The Lake Mitchell and Rice Marsh lake watersheds demonstrated the greatest impervious fractions with 54% and 39% impervious areas respectively. T bl 2 6 T t I h I d' th C"t fCh h a e . . o a c an~e In uplan ImperVIOusness In e IlY 0 an assen. Watershed Watershed Percent Imperviousl ID Area (acres)! 1990 2000 2020 Lake Ann 130 7 9 15 Chaska Creek 177 18 23 31 Lotus Lake 998 24 24 24 Lower MN River 509 15 15 20 Lake Lucy 707 13 17 23 Minnehaha Creek WD 2,047 18 19 21 Lake Mitchell 129 31 55 54 Rice Marsh Lake 586 32 36 39 Lake Riley 683 11 15 25 Riley Purgatory Bluff Creek WD 3,532 10 15 30 Silver Lake 113 20 25 25 Lake Susan 1,082 22 29 36 TOTAL 10,694 16 20 28 II Does not Include wetland and lake surface areas. 2.4 Pervious Curve Numbers The second key piece of information for the P8 model is a curve number for the pervious areas in the model. The SCS curve number reflects an area-weighted-average of the pervious areas considering soil types, land use and hydrologic groups. Table 2.7 lists the values used in the P8 modeling as a function of land use, hydrologic condition, and soil group. T bl 2 7 C b bid d 'It a e .. urve num ers JY. an use an so. type. Hydrolo~ic Soil Grou Land Use A B C D AID BID B/C AIB AlC Unclassified Agricultural 2 49 69 79 84 66.5 76.5 74 59 64 70.25 Roadway 2 49 69 79 84 66.5 76.5 74 59 64 70.25 Single Family Residential 2 39 61 74 80 59.5 70.5 67.5 50 56.5 63.5 Park and Recreation 1 39 61 74 80 59.5 70.5 67.5 50 56.5 63.5 Commercial 2 49 69 79 84 66.5 76.5 74 59 64 70.25 Multi-Family Residential 1 39 61 74 80 59.5 70.5 67.5 50 56.5 63.5 Vacant 1 39 61 74 80 59.5 70.5 67.5 50 56.5 63.5 Industrial 3 68 79 86 89 78.5 84 82.5 73.5 77 80.5 Railway 3 68 79 86 89 78.5 84 82.5 73.5 77 80.5 OfficelInstitutional 1 39 61 74 80 59.5 70.5 67.5 50 56.5 63.5 I . . SIngle famIly reSidentIal, park and recreatIon, multIfannly reSidentIal, vacant, and office/InstItutIonal were considered to be in good condition. 2 Agricultural, commercial, and highways and roadways were considered to be in fair condition. 3 Industrial and rail were considered to be in poor condition. City of Chanhassen Nondegradation Assessment 12 D R AFT December 07 2.5 Other P8 Inputs Other model input is the particle, precipitation and temperature file. The particle file used was the P8 default NURP50 particle file. Both the precipitation and temperature files used were obtained from UAA models. All models were run for the same 10 year period (1992 to 2002) with 5 passes through the precipitation file. 2.6 Model Validation and Assumptions Modeling was conducted for all loading in the City, including loading from other NPDES Phase II permit holders. Other permit holders include MnlDOT, Carver County, and Hennepin County. These loadings were included in this assessment. The modeling approach presented here is a conservative approach to assess nondegradation. The P8 model was developed for urban watersheds. However, one of the critical aspects of this modeling is the change in loading that occurs as land is converted from open or agriculture to developed land. To test the P8 model's handling of open space, a test watershed (100 acres) was run for an average precipitation year (Table 2.8). Curve numbers in the model for open space and agriculture typically ranged from 60 to 70. Because of the low runoff (<1.4 inches), the loading rates for open land with these curve numbers is very low. This may be artificially lowering the runoff from these areas, especially if the current land use is agriculture. However, to maintain a conservative approach, these numbers were maintained in the model. T bl 2 8 R ff did' b b f h d' P8 a e . . uno an oa lOll: )y curve num er rom a test waters e In TSS load TP load eN Runoff (in) (IbsJaclvr) TSS (ppm) (IbsJaclyr) TP (ppm) 50 0.3 , 0.7 12 0.01 0.127 55 0.5 2 17 0.01 0.138 60 0.7 4 22 0.02 0.150 65 1.0 7 29 0.04 0.167 70 1.4 13 40 0.06 0.193 75 1.9 24 55 0.10 0.226 80 2.7 44 71 0.16 0.263 85 4.0 82 89 0.28 0.305 90 6.3 163 114 0.52 0.363 95 11.0 366 148 1.09 0.440 Impervious 26.1 649 110 2.09 0.354 (NURP 50) Impervious 26.1 1947 330 4.43 0.750 (NURP 90) To validate the model, model results were compared to stream data collected as a part of the Watershed Outlet Monitoring Program (WOMP; Table 2.9). For the WOMP data, a close to average year precipitation was selected to evaluate. Data are presented as flow weighted means or on a unit area basis. This makes the data comparable even though the model was only run for the City of Eden Prairie portion of the watersheds. The model typically over-predicted runoff and loading for the Purgatory Creek watershed in Eden Prairie. Although the model does not City of Chanhassen Nondegradation Assessment 13 DR AFT December 07 account for receiving water processes, it represents a conservative estimate of loading from the land. Table 2.9. Monitored and redicted volume and water uatit Creek. Runoff Flow TSS load Flow Watershed Year (in) Weighted (Ibs/aclyr) Weighted TP TSS (m ) ( ) Purgatory 2004 7 23 38 160 Creek TP load (Ibs/aclyr) 0.26 Modeled 10 93 217 314 Data calculated from WOMP station for entire watershed 2Data calculated for City of Eden Prairie portion of watershed using NURP50 file. 0.73 City of Chanhassen Nondegradation Assessment 14 D R AFT December 07 3.0 CURRENT WATER QUALITY TREATMENT CAPACITY Understanding the BMPs and water quality treatment devices in the watershed is vital in assessing load changes in the City between 1988 and present. Additionally, assessing whether the current practices are sufficient for protecting water quality into the future can help guide City activities to assure compliance with nondegradation. 3.1 Applicable Rules, Codes and Ordinances Applicable watershed district rules and City codes and ordinances that address water quality were reviewed to determine the current treatment capacity in the City resulting from regulation. 3.1.1 Chanhassen Codes and Ordinances Wetlands. Provides for management of wetlands and wetland impacts by management classification as determined by a functions and values assessment. Ordinance specifies allowable hydrologic change in wetlands, and buffer and setback standards by classification. Shore land Management. Establishes structure, septic system, and drain field setbacks, and minimum lot sizes; regulates grading and filling activities and alteration of natural vegetation in the shoreland management area; and regulates onsite sewerage systems in the shoreland area. Also, specifies maximum impervious coverage by land use type and regulates placement and design of roads, driveways and parking areas. Bluff Creek Overlay District. Contains a number of regulations to protect the Bluff Creek Corridor, wetlands, bluffs, trees, and general environmental quality in the Overlay District. This ordinance encourages minimization of new impervious surface, cluster development, and other Low Impact Design elements, and requires a Natural Habitat Restoration Plan mitigating impacts to natural habitat areas in the Overlay District. Surface Water Management. Sets forth water quantity and quality requirements. Rate control and NURP-Ievel treatment is required on new developments. Additional treatment requirements are established for developments that discharge to higher waterbodies. Where developments discharge to Riley or Purgatory Creek, new runoff is prohibited from increasing the flow rate in the creek. 3.1.2 Riley-Purgatory Creek-Bluff Creek Watershed District The District's regulatory program was formally established in 1996. Projects to alter or disturb land surfaces in excess of one acre, fill within the 100-year floodplain, or fill within a wetland are required to meet NURP design requirements and include skimming of floatable materials. City of Chanhassen Nondegradation Assessment 15 DR AFT December 07 No specific rate or volume control is required. According to Bob Obermeyer, former engineer for the District, standards have been in place since 1977 for projects altering more than one acre. The early emphasis was simply on erosion control, but in the early 80s started looking for sedimentation control and treatment. The design criteria used was to provide sufficient surface settling area to remove a 0.1 mm particle based on a 10-year, 1.65" in 30 minutes storm event (Obermeyer, pers. corresp. 6/8/06, 7/12/06). 3.1.3 Minnehaha Creek Watershed District The District's regulatory program was formally established in 1974 and has been periodically revised since that time. The standards in place since 1988 apply to all land alterations except for residential developments ofless than two acres. Wet detention basins meeting NURP design requirements are required, except that developments less than 40 acres can choose to purchase regional storm water storage credits. The District's current regulatory program requires all projects to incorporate Best Management Practices, including site design, structural, and non- structural practices. Water quality requirements depend on the land use and size of project. Generally, NURP-Ievel treatment is required for developments of 8 acres or more. 3.1.4 Lower Minnesota Watershed District The District's regulatory program was formally established in 1999. A Runoff Management Plan (RMP) is required for residential projects in excess of 5 acres or nonresidential projects in excess of one acre, or projects meeting other criteria. Runoff from the site after development must not exceed the peak runoff from the site predevelopment for the 20-percent chance (5-year) and I-percent chance (lOO-year) storm event. The one LMWD lake in Chanhassen, Rice Lake, is a Level IV lake, requiring runoff treatment prior to discharge to NURP standards except that dead storage must be provided for a 2-inch event rather than a 2.5-inch event. 3.2 Treatment Device Quantification The City of Chanhassen's pond and wetland database was reviewed to assess the ability to quantify the treatment capacity in the City. The most important data includes pond dead storage or bottom and surface areas. Flood pool storage is also useful but not critical. Pond surface areas are available, but it is not known if all ponds are included. For the Riley-Purgatory-Bluff Creek Watershed, the data are available in the P8 model supplied by the District. Consequently, the treatment capacity was estimated based on the year the lot was developed and the District or City rules in place at the time. 3.3 Year Built For Developments The first step in identifying the rules under which development occurred, is to determine the date when a lot was developed. Hennepin and Carver Counties maintain a GIS layer that includes the development year for a particular tax lot (Figure 3.1). The City was then broken into areas based on the period in which different watershed rules were in place. Realizing that some development can still occur without review (less than 5 acres), each subwatershed was evaluated City of Chanhassen Nondegradation Assessment 16 DR AFT December 07 Legend n::Jl Oly of Chan hassen Boun dary .0 Lakes - Major Roads Year Bunt D No Data D Pre '1988 D 1988-1992 . 1993-Present Year Built (Source: Char1hassen) 0.5 0 M>XI: L:\1481 \1481.03lm:<<l\9nal FlgstFlgure 3.1 Year BUlll.mxd L~~ Modl6ed~ 71912007 12;57:02 PM 1 I Miles N J ..r, 1\ I ~Wenc WenCk Assoclares I I nc. 1800 Pioneer Creek Center Environmental Engineers Maple Plain, MN 55359-l)129 JUL 2007 Figure 3.1 CITY OF CHANHASSEN Hennepin County Year Built by Rule Change City of Chanhassen Nondegradation Assessn1ent 17 D R AFT December 07 to estimate the area of development that occurred under the watershed district rules (Table 3.1). This was accomplished by evaluating the dates the lots were built in relation to neighboring lots. If several lots were built together, the area was assumed to develop under the rules. T bl 3 1 Eft d th t d d d h d d. t . t I b b t h d a e . . sIma e areas a eve ope un er wa ers e IS rlc ru es )y su wa ers e . Watershed Estimated Number Estimated Number Fraction Built ID Of New Lots Built Under Rules Under Rules Notes Lake Ann 2 2 1.00 Chaska Creek 20 20 1.00 Lotus Lake 0.65 Estimated Lower MN River 16 10 0.63 Lake Lucy 267 251 0.94 Minnehaha Creek WD 0.70 Estimated Lake Mitchell 13 13 1.00 Rice Marsh Lake 295 282 0.96 Lake Riley 314 290 0.92 Riley Purgatory Bluff Creek WD 0.80 Estimated Silver Lake 73 66 0.90 Lake Susan 0.90 Estimated 3.4 Application of Rules Watershed rules were in place in the early 1980s, however the key rules are those in place after 1988. Since the early 1990s the pond design was the National Urban Runoff Program (NURP) standard and is assumed to provide a 50 to 60% total phosphorus reduction and a 70 to 80% total suspended solids reduction. T bl 3 2 Ril Po BI ff W h dD. a e . . ey- r atory. u aters e Istnct ru es. TP% TSS % Volume % Year Built Reduction Reduction Reduction Notes Pre 1988 0 0 0 Some WQ reduction starting in early to mid 80s 1988-1992 50-60% (1) 70-80% (I) 0 Provide dead storage for the lO-year 30 min event (1.65 inches) 1993-2007 50-60% (2) 70-80% (2) 0 Rules - NURP. Provide dead storage for the 2.5 inch, 24-hr event 1. Assumed based on the rule 2 Assumed based on NURP standards Table 3.3. Minnehaha Creek Watershed District rules. TP% TSS% Volume % Year Built Reduction Reduction Reduction Notes Pre 1988 50-60% (IJ 70-80% (IJ 0 1988-1992 50-60% (I) 70-80% (I) 0 1993-2007 50-60% (2) 70-80% (2) 0 Requirement depends on type of land use and development size 1. Assumed based on the rule 2 Assumed based on NURP standards City of Chanhassen Nondegradation Assessment 18 D R AFT December 07 Table 3.4. Lower Minnesota River Watershed District rules. TP% TSS% Volume % Year Built Reduction Reduction Reduction Notes Pre 1988 0 0 0 Some WQ reduction starting in early to mid 80s 1988-1992 50-60% (1) 70-80% (I) 0 Provide dead storage for the lO-year 30 min event (1.65 inches) 1993-2007 50-60% (2) 70-80% (2) 0 Rules - NURP. Provide dead storage for the 2.5 inch, 24-hr event 1, Assumed based on the rule 2 Assumed based on NURP standards 3.5 Street Sweeping The City of Chanhassen has a street sweeping program and maintains detailed records of material removed from streets. The City removed between 1 and 6 million pounds of raw material annually between 2004 and 2006 with an average removal of 3.3 million pounds (Table 3.5). Table 3.5. Measured mass of material removed from street sweeping in the City of Chanhassen. Tons Pounds Material Swept (Dry Removed Year Weil!:ht) 2003 2004 1,472 2,944,400 2005 506 1,011,500 2006 2,975 5,950,000 Average 1,651 3,301,967 City ofChanhassen Nondegradation Assessment 19 DR AFT December 07 4.0 MODEL RESULTS 4.1 Organization Model results were organized on a receiving water basis with the City's ten lakes as the focus (Figure 2.1). Model results are presented in for these subwatersheds. Those subwatersheds that drain out of the City or drain to creeks that ultimately drain out of the City without entering a lake were grouped together. The details of the P8 models supplied by the watershed districts were maintained and are provided in the Technical Appendices. 4.2 Load Changes Changes to impervious area, volume, TSS, and TP for the City of Chanhassen between 1990 and 2020 are presented in Table 4.1. Between 1990 and 2020 the City is expected to add about 1,250 impervious acres resulting in an increased discharge of over 2,800 acre-feet of water. The increased discharge was predicted to include an additional 786,000 pounds of TSS and 2,690 pounds of total phosphorus. City of Chanhassen Nondegradation Assessment 20 DR AFT December 07 (lbs per year) 2020 49 2000 31 TP 1990 27 1990 to 2020. 2020 13,803 TSS (lbs per year) 2000 8,635 Raw increases in imperviousness, volume, TSS, and TP for the City of Chanhassen from 1990 7,363 2020 64 (ac~er year) 2000 41 Flow 1990 36 2020 19 Impervious Area (acres) 2000 11 1990 9 Area (acres) Watershed In 4.1 e Tabl 130 Lake Ann Chaska Creek 131 568 98 567 79 555 38,448 166,271 28,622 166,222 22,905 162,366 155 682 118 682 99 668 54 240 41 241 31 236 177 998 246 395 193 292 191 235 71,558 117,550 55,417 85,955 54,705 68,607 299 460 242 347 239 285 103 165 76 117 75 91 509 707 1,020 937 901 297,523 272,234 172 261 1,237 1.146 1.106 429 386 368 2,047 241 532 572 2,508 65 916 7,243 1,378 65 765 5t458 1,038 54 588 4,555 739,018 19,092 271,391 2,060,167 394,652 19,095 225,324 1,521,111 290,670 15,771 171,498 1,274,100 2,977 78 1,074 8,324 1,731 78 908 6,370 1,364 66 713 5,488 1,076 28 392 2,979 528 28 319 2,127 358 23 236 1,732 3,532 113 1,082 10t694 Lotus Lake Lower MN River Lake Lucy Minnehaha Creek WD Lake Mitchell Rice Marsh Lake Lake Riley Riley Purgatory Bluff Creek WD Silver Lake Lake Susan TOTAL 241 532 359 ~n o -. ::1'2 ~~ "" ;:J 9 l}!'i 5' ir ::I ~ :x:.", '" ::I '" '" '" 3 '" ::;, 142 437 307 49,487 157,846 118,182 49,546 142,930 72,480 28,824 129,130 61,091 193 622 483 193 567 318 116 517 279 70 231 171 70 209 99 40 187 78 129 586 683 to.> .... ~ ~ ~ ~ ~ ~ (l) ::s <::- (l) ., ~ '1 4.3 Current BMP Treatment The primary BMPs in the City are load reductions through the application of development rules and street sweeping. These BMPs were evaluated to estimate the pollutant removal and volume reduction each were currently providing and could be expected to provide in the future. The reductions were summed to estimate the total amount of pollutant removal and applied to the load increase resulting from land use change to determine the net change in pollutant load and stormwater volume between 1990 and 2020. 4.3.1 Development Rules To evaluate the impact of application of development rules, each parcel in the city was assigned a treatment level depending on when it was built and the treatment rules that were in place at that time. For each subwatershed, raw and treated TSS and TP loads were calculated for each subwatershed based on land use in 1990,2000, and 2020. The reduction attributed to development rules was calculated as follows. Say a parcel that was vacant in 1990 generated a 30 pound per year TSS load. After development, it generated a raw load of 100 pounds per year TSS. Treatment rules were applied to the raw post-development load: 100 pounds * 80 percent removal = 80 pounds removed per year. This parcel generated a raw load increase of 70 pounds per year, but treatment resulted in 80 pounds per year TSS removal. Thus development can result in a net decrease in TSS and TP load. Treatment rules have been in place since 1988, so development after 1988 was assumed to be treated to NURP standards (80 percent removal TSS, 60 percent removal TP). However, as discussed above, some development may not have required treatment. The estimated removal due to rules was calculated as the raw load increase times the 80 percent NURP removal rate, times the estimated fraction of development built under the rules shown in Table 3.1. Table 4.2. Predicted TSS and TP load increases between 1990 and 2020 and estimated removal due to d I I eve opment ru es. Total TSS Development Total TP Development Increase Rules Increase Rules Watershed 1990 - 2020 TSS Removal 1990 - 2020 TP Removal ID (Ibs/vr) (Ibs/vr) (Ibs/vr) (Ibs/vr) Lake Ann 6,439 3,975 22 11 Chaska Creek 15,544 17,095 51 88 Lotus Lake 3,905 14,135 13 184 Lower MN River 16,853 16,079 55 88 Lake Lucy 48,943 66,698 160 214 Minnehaha Creek WD 36,351 51,212 119 165 Lake Mitchell 20,663 34,025 99 162 Rice Marsh Lake 28,715 45,232 95 339 Lake Riley 57,091 68,975 265 245 Riley Purgatory Bluff Creek WD 448,348 469,214 1,470 1187 Silver Lake 3,321 4,829 11 27 Lake Susan 99,893 141,641 328 362 TOTAL 786,066 933,108 2,688 3,073 City of Chanhassen Nondegradation Assessment 22 DR AFT December 07 4.3.2 Street Sweeping The City of Chanhassen has a street sweeping program and maintains detailed records of material removed from streets. Much of the volume of material that accumulates on streets is trash and organic material such as leaves, and sand and sediment particles that are too heavy to become suspended in stormwater as TSS. To estimate the fraction of material removed by street sweeping that would likely have become a part of the TSS load, three samples of street sweepings taken in nearby Eden Prairie were analyzed and an actual particle size distribution developed. Based on that analysis, it is estimated that about 5.5 percent of the volume of street sweepings was of a particle size that fell into the P8 TSS particle size class distribution (see Table 4.3). That percent was applied to the average annual volume of street sweepings removed to obtain an estimate of TSS removal from sweeping. To calculate the estimated annual TP removal by street sweeping, the P8 fraction of TP associated with TSS (3,850 mglkg) was applied to the 3.3 percent that fell into the particle size distribution PO% to P50%. A literature value of 300 mglkg was applied to the 2.2 percent that fell into the P80% class. The annual average removal of TSS and TP was allocated among the watersheds based on the impervious acres in that subwatershed, assuming that the subwatersheds with more impervious acres had more road surface that were swept (Table 4.4). Table 4.3. Particle size breakdown by NURP particle size class for three samples taken from street sweepings in Eden Prairie. NURP % of Sample Particle Class Particle Class Sample 1 Sample 2 Sample 3 Average % PO% 0.0 0.0 0.0 0.00 PlO% 1.6 1.6 1.1 1.43 P30% 0.5 0.5 0.0 0.33 P50% 2.2 1.7 0.8 1.57 P80% 2.7 2.7 1.1 2.17 Total 2.7 6.5 3.0 5.50 T bl 4 4 TSS d TP It f t t . th C't f Ch h a e . . an remova as a resu o s ree swee lID\! ID e llV 0 an assen. Impervious Watershed TSS Removal TP Removal Watershed ID Area in 2000 (acres) (pounds) (pounds) Lake Ann 11 951 2 Chaska Creek 41 3,521 9 Lotus Lake 241 20,579 50 Lower MN River 76 6,504 16 Lake Lucy 117 9,986 24 Minnehaha Creek WD 386 32,983 80 Lake Mitchell 70 6,019 15 Rice Marsh Lake 209 17,834 43 Lake Riley 99 8,481 21 Riley Purgatory Bluff Creek WD 528 45,118 110 Silver Lake 28 2,385 6 Lake Susan 319 27,247 66 TOTAL 2,127 181,608 441 City of Chanhassen Nondegradation Assessment 23 DR AFT December 07 4.3.3 Volume Estimated volume increases for the major subwatersheds in the City are presented in Table 4.5. Although there is potential for a net loss from evaporation from constructed ponds, no BMPs or loss have been quantified for this study. T bl 4 5 P d' t d . th C't f Ch h b t 1990 d 2020. a e . . re IC e vo ume Increases In e uyo an assen e ween an Watershed Total Flow Increase Watershed ID Area (acres) 1990 - 2020 (ac.-ft./ yr) Lake Ann 130 28 Chaska Creek 177 56 Lotus Lake 998 14 Lower MN River 509 60 Lake Lucy 707 175 Minnehaha Creek WD 2,047 131 Lake Mitchell 129 76 Rice Marsh Lake 586 105 Lake Riley 683 204 Riley Pur~atory Bluff Creek WD 3,532 1,614 Silver Lake 113 12 Lake Susan 1,082 361 TOTAL 10,694 2,836 4.3.4 TSS Loading The total predicted increase in TSS loading from 1990 to 2020 was compared to removals by active BMPs in the City to assess compliance with nondegradation. Except for the Lake Ann subwatershed, annual TSS removals exceeded the estimated increase between 1990 and 2020 (Table 4.6). T bl 46 Pr d' d TSS I d' b 1990 d 2020 . BMP a e . . e lete oa Increases etween an In comparison to remova s. Total TSS TSS Removal Net Increase 1990-2000 2000-2020 Removal (-) or Watershed 1990 - 2020 Development Development Street Cleaning Net Increase (+) ID (Ibs/yr) Rules (lbs) Rules (lbs) (lbs) (lbs) Lake Ann 6,439 179 3,796 1,619 +845 Chaska Creek 15,544 4,610 12,485 4,646 -6,197 Lotus Lake 3,905 5,775 8,360 20,516 -30,746 Lower MN River 16,853 338 15,741 8,772 -7,998 Lake Lucy 48,943 16,459 50,239 14,124 -31,879 Minnehaha Creek WD 36,351 10,796 40,415 36,649 -51.509 Lake Mitchell 20,663 17,927 16,098 6,010 -19,372 Rice Marsh Lake 28,715 14,769 30,463 19,708 -36,225 Lake Riley 57,091 13,242 55,733 14,635 -26,519 Riley Purgatory Bluff Creek WD 448,348 70,377 398,837 91,889 -112,755 Silver Lake 3,321 1,599 3,229 2,376 -3,884 Lake Susan 99,893 48,567 93,074 33,502 -75,251 TOTAL 786,066 204,637 728,471 254,446 -401,488 City of Chanhassen Nondegradation Assessment 24 D R AFT December 07 4.3.5 TP Loading The total predicted increase in TP loading from 1990 to 2020 was compared to removals by active BMPs in the City to assess compliance with nondegradation. For all of the subwatersheds except Lake Ann and Riley-Purgatory-Bluff Creek, annual TP removals exceeded the estimated increase between 1990 and 2020 (Table 4.7). T bl 47 Pr d. t d TP I d. b t 1990 d 2020 . t BMP a e . . e IC e oa lDcreases e ween an lD comparIson 0 remova s. Total TP TP Removal Net Increase 1990-2000 2000-2020 Removal (-) or Watershed 1990 - 2020 Development Development Street Cleaning Net Increase (+) ID (Ibs/yr) Rules (Ibs) Rules (Ibs) (Ibs) (Ibs) Lake Ann 22 1 10 4 +8 Chaska Creek 51 38 50 11 -47 Lotus Lake 13 77 107 48 -219 Lower MN River 55 22 67 20 -54 Lake Lucy 160 66 149 33 -87 Minnehaha Creek WD 119 43 122 85 -131 Lake Mitchell 99 85 77 14 -76 Rice Marsh Lake 95 171 168 46 -291 Lake Riley 265 53 193 34 -14 Riley Purgatory Bluff Creek WD 1,470 201 986 213 +70 Silver Lake 11 14 14 6 -22 Lake Susan 328 128 234 78 -111 TOTAL 2,688 898 2.174 589 -974 4.4 Model Sensitivity Because the model is not calibrated and is only used for comparison purposes, it is useful to test the sensitivity of model to selected inputs, especially as we compare model results to real-world measured removals. The first parameter that may affect the results of the model is the selection of the particle file. The current modeling is based on the NURP50 file, which represents the median concentrations from the NURP studies. To assess the potential effects of underestimating runoff concentrations, the Rice Marsh subwatershed was analyzed using both the median runoff concentrations (NURP50) and 90th percentile runoff concentrations (NURP90). Results of the 50th and 90th percentile runs are presented in Table 4.8 and Table 4.9. Even if the actual concentrations were more similar to 90tfi percentile concentrations for both TSS and TP, the City of Chanhassen would be meeting the nondegradation requirement. City of Chanhassen Nondegradation Assessment 25 DR AFT December 07 Table 4.8. Rice Marsh subwatershed TSS loading and removals for the 50th and 90th percentiles of the NURP studies. Total TSS TSS Removal Net Increase Removal (-) or Watershed 1990 - 2020 Development Street Net Increase (+) ID (Ibs/vr.) Rules (Ibs) Cleaning (lbs) (lbs) Rice Marsh NURP 50 27,193 45,232 17,834 -35,873 Rice Marsh NURP 90 81,577 114,250 17,834 -50,507 Table 4.9. Rice Marsh subwatershed TP loading and removals for the 50th and 90th percentiles of the NURP studies. Total TP TP Removal Net Increase Removal (-) or Watershed 1990 - 2020 Development Street Net Increase (+) ID (lbs/vr) Rules (lbs) Cleaning (lbs) (lbs) Rice Marsh NURP 50 95 339 43 -287 Rice Marsh NURP 90 202 702 43 -543 City of Chanhassen Nondegradation Assessment 26 DR AFT December 07 5.0 SUMMARY AND PROPOSED BMPS The City of Chanhassen, in conjunction with the Riley-Purgatory- Bluff Creek and Minnehaha Creek Watershed Districts, has been actively managing water quality for many years. These activities have included developing and enforcing rules to minimize water quality impacts from development; building and maintaining BMPs throughout the city; and actively sweeping city streets to remove as much material as possible from the impervious surfaces. These activities have been very effective in the mitigation of increased TSS and TP loads from the watershed. The increase in impervious surface between 1990 and 2000 has resulted in increased stormwater runoff volume, and that volume is expected to continue to increase with further development. Volume is difficult to remove from the watershed, and it is unlikely that the City will be able to attain 1988 volume conditions. However, the effects of increased runoff volume can be minimized or mitigated through stream bank and shoreline stabilization programs, infiltration, and rate control. Consequently, the best approach to addressing volume is through aggressive abstraction and mitigation and opportunistic volume control. 5.1 Special and Impaired Waters Bluff Creek was added to the State of Minnesota 303( d) list of Impaired Waters in 2002 for excess turbidity and on 2004 based on its fish community index of biotic integrity score. TMDLs have not yet been completed for those impairments. Lotus Lake was added to the 303(d) list in 2002 for excess nutrients, and Lake Riley in 2002 for excess nutrients and mercury- fish consumption. Seminary Fen and Assumption Creek are Outstanding Resource Value Waters. 5.2 Total Suspended Solids The combination of development rules and street sweeping has proved effective in reducing the volume of total suspended solids to a level well below that estimated to have been contributed in 1988. Most ofthat removal is a result of application of development rules and other regulations, but almost one-quarter is achieved through the aggressive street maintenance program. Each subwatershed except Lake Ann meets the Nondegradation Total Suspended Solids requirement by removing more TSS through regulation and BMPs than the new load generated since 1988 (see Table 4.6). It should be noted that if any future TMDLs for any water resource to which Chanhassen discharges requires additional TSS load reduction, then the City may be required to remove additional TSS or TP load beyond simply meeting the Nondegradation TSS and TP requirement. 5.2.1 Regulatory Program Development rules will continue to require land-altering activities to provide at least NURP-Ievel removal (80%) of Total Suspended Solids prior to discharge. In accordance with its NPDES City of Chanhassen Nondegradation Assessment 27 DR AFT December 07 permit, the City annually inspects 20 percent of those detention ponds that are publicly-owned to determine maintenance needs and evaluate whether they continue to perform at the level to which they were designed. City ordinance requires owners of private stormwater facilities to perform regular maintenance and to operate those facilities so they continue to perform at the level to which they were designed. Developer's Agreements specify required maintenance. The City's Stormwater Management Plan designates Assumption Creek and Seminary Fen as "Preserve" classification water resources, requiring a higher level of treatment for discharges to those waters, including temperature controls. 5.2.2 Street Sweeping This maintenance program removes not only smaller particles that contribute to Total Suspended Solids, but also larger particles of inorganic and organic material that can contribute to downstream clarity and water quality issues as well as obstruct pipes, create sediment deltas at outlets, and aggrade in streams and impair biotic functions. Street sweeping also improves traffic safety and general aesthetics by removing unsafe or unsightly materials from the streets. The City will continue to sweep streets once per year -in the spring to remove sand and salt residue from winter de-icing plus any spring leaves and seeds and old organic material. Other street sweeping is performed throughout the year as necessary. Recent research in Wisconsin (Bannerman 2007) indicates that the incremental water quality benefit of increased street sweeping is small unless the frequency of sweeping is very aggressive. Street sweeping practices will be refined to improve the water quality and overall benefit of street sweeping: 1. Spring street sweeping will be performed as early as possible to remove material from the street before the spring rains. 2. Increased street sweeping frequency may be of benefit in sensitive locations, such as in the Lake Ann subwatershed or where there is noticeable aggradation in streams or below outfalls or where a UAA or TMDL indicates that efforts should be maximized to remove pollutant loading. The City will evaluate the potential benefits of more frequent street sweeping in sensitive areas. 3. Timing of street sweeping will be evaluated to maximize its efficacy, for example, sweeping prior to hydrant flushing. 5.2.3 Lake Ann Subwatershed The Lake Ann subwatershed is projected to generate 845 pounds more TSS in 2020 than was generated in 1990. This sub watershed is very small, and has a low watershed to lake area ratio. The lake also has good water quality and clarity. There are several outfalls into Lake Ann. The City will investigate the possibility of retrofitting those outfalls with sump manholes or other devices to collect sediment prior to discharge into the lake. The City will also look for opportunities to reduce runoff by increasing abstraction in the subwatershed, and evaluate land use policies governing development for opportunities to reduce the creation of new TSS. City of Chanhassen Nondegradation Assessment 28 D R AFT December 07 5.2.4 Other Activities The volume management activities described in section 5.3 below such as increased infiltration, biofiltration, and runoff volume controls may further reduce TSS and TP loading by pre-treating or reducing the amount of runoff volume conveying TSS and TP to waters. 5.3 Total Phosphorus As with TSS, the combination of development rules, manhole cleanout, and street sweeping has proved effective in reducing the volume of total phosphorus to a level below that estimated to have been contributed in 1988. Most of that removal is a result of application of development rules, but almost 20 percent is achieved through the aggressive street maintenance program. Each subwatershed meets the Nondegradation Total Phosphorus requirement by removing more TP through regulation and BMPs than the new load generated since 1988 (see Table 4.7). It should be noted that if any future TMDLs for any water resource to which land in Chanhassen drains requires additional TP or TSS load reduction, then the City may be required to remove additional TP or TSS load beyond simply meeting the Nondegradation TP and TSS requirement. 5.3.1 Regulatory Program Development rules will continue to require land-altering activities to provide at least NURP-Ievel removal (60%) of Total Phosphorus prior to discharge. In accordance with its NPDES permit, the City annually inspects 20 percent of those detention ponds that are publicly-owned to determine maintenance needs and evaluate whether they continue to perform at the level to which they were designed. City ordinance requires owners of private stormwater facilities to perform regular maintenance and to operate those facilities so they continue to perform at the level to which they were designed. Developer's Agreements specify required maintenance. The City's Stormwater Management Plan designates Assumption Creek and Seminary Fen as "Preserve" classification water resources, requiring a higher level of treatment for discharges to those waters, including temperature controls. 5.3.2 Street Sweeping This maintenance program removes not only smaller particles that are a fraction of the TSS load, but also larger particles of organic material that can contribute to downstream clarity and water quality issues. Street sweeping also improves traffic safety and general aesthetics by removing unsafe or unsightly materials from the streets, and reduces the amount of material on the street that can clog catch basin covers and limit street drainage. The City will continue to sweep streets once per year -in the spring to remove sand and salt residue from winter de-icing plus any spring leaves and seeds and old organic material. Other street sweeping is performed throughout the year as necessary. Recent research in Wisconsin (Bannerman 2007) indicates that the incremental water quality benefit of increased street sweeping is small unless the frequency of sweeping is very aggressive. City of Chanhassen Nondegradation Assessment 29 D R AFT December 07 Street sweeping practices will be refined to improve the water quality and overall benefit of street sweeping: 1. Spring street sweeping will be performed as early as possible to remove material from the street before the spring rains. 2. Increased street sweeping frequency may be of benefit in sensitive locations, where there is noticeable aggradation in streams or below outfalls or where a UAA or TMDL indicates that efforts should be maximized to remove pollutant loading. The City will evaluate the potential benefits of more frequent street sweeping in sensitive areas. 3. Timing of street sweeping will be evaluated to maximize its efficacy, for example, sweeping prior to hydrant flushing. 5.3.3 Lake Ann and Riley-Purgatory-Bluff Creek Subwatersheds The Lake Ann subwatershed is projected to generate 8 pounds more TP in 2020 than was generated in 1990, with 70 additional pounds TP estimated in the Riley-Purgatory-Bluff Creek subwatershed. The Lake Ann subwatershed is very small, and has a low watershed to lake area ratio. The lake also has good water quality and clarity. There are several outfalls into Lake Ann. Reduction in TSS loading from those outfalls as described above will also reduce phosphorus loading. The City will investigate the possibility of retrofitting those outfalls with sump manholes or other devices to collect sediment prior to discharge into the lake. The City will also look for opportunities to reduce runoff by increasing abstraction in the subwatershed, and evaluate land use policies governing development for opportunities to reduce the creation of new TP. The Riley-Purgatory-BluffCreek subwatershed encompasses about one-third of the city's area. Impervious cover is expected to double between 2000 and 2020. A significant portion of this subwatershed falls within the City's Bluff Creek Overlay District, described in Section 3.1.1 above. This ordinance contains a number of zoning and planning tools that will be applied to development and redevelopment in this overlay district as part of the City's overall policy to protect the Bluff Creek Corridor and its wetlands, bluffs, wooded areas, and water resources. If the regulatory program is not successful in limiting new TP the City will incorporate TP reduction BMPs into City projects as opportunities arise. 5.3.4 Other Activities The volume management activities described in section 5.3 below such as increased infiltration, biofiltration, and runoff volume controls may further reduce TP and TSS loading by pre-treating or reducing the amount of runoff volume conveying TP and TSS to waters. 5.4 Volume This report estimates that stormwater volume in the city will increase by about 50 percent between 1990 and 2020, with most of that volume increase occurring between 2000 and 2020. City of Chanhassen Nondegradation Assessment 30 DR AFT December 07 Each subwatershed, with the exception of Silver Lake and Lotus Lake, significantly exceeds the Nondegradation Volume Management requirement. Where new volume is expected to be generated as a result of future development or redevelopment, the regulatory program can be a means to achieve some level of volume management. Best Management Practices in already-developed areas will likely be confined to small volume management practices retrofitted where opportunities arise, and mitigation of water quality-related impacts of volume such as streambank stabilization. The City's water resources and environmental education programs can also provide information to residential and other property owners on small-scale volume management practices for individual properties. 5.4.1 Regulatory Program Abstraction/Infiltration. Neither the City nor the three watershed districts with land in the city require the infiltration or abstraction of stormwater runoff, although that concept is being discussed as a potential rule change in Minnehaha Creek. Abstraction is the removal of stormwater from runoff, and can include BMPs such as infiltration, evapotranspiration, pervious pavement, and capture and reuse. Most of the annual volume of stormwater runoff is generated by small rain events, so abstraction and infiltration of small events can significantly reduce the amount of annual runoff volume. Precipitation-frequency curves derived from precipitation records at the Minneapolis-St. Paul International Airport can be used to estimate the percent of total annual volume that could be captured through infiltration (see Figure 5.1). About 85 percent of annual stormwater volume is generated from the first one inch of rainfall - storm events of up to one inch, plus the first inch of events greater than one inch. A rule requiring abstraction of the first one inch of rainfall could theoretically reduce new runoff volume by 85 percent. About 80 percent of annual volume is generated from the first three-quarters inch and 65 percent from the first one-half inch of rainfall. Evaluation of Stormwater Infiltration Rules Determined from MSP Precipitation - Frequency Curves 1.00 ^ k>- - ~ r- -v .L"7- -- ~- ,A ~ ", 0.5" -65% /I If 0.75" - 80% I 1.0" - 85% jf v ...... c;...L ~ "0 0.75 c ~ <c.a '0 g. 0.50 cO ~~ ~:s 0.25 J... ns L1.a: 0.00 0.0 0.5 1 .0 1 .5 2.0 Infiltration Storm Depth Rule [in] 2.5 3.0 Figure 5.1. Annual stormwater volume that could be captured through abstraction/infiltration. (Wenck Associates, Inc. derived from MPCA Minnesota Stormwater Manual Appendix B.) City of Chanhassen Nondegradation Assessn1ent 31 D R AFT December 07 A secondary but important benefit of abstraction is that volume is no longer being contributed to runoff, and is not picking up and transporting pollutants to downstream waters. Research conducted by Prof. Robert Pitt (Pitt 1998) in the City of Milwaukee suggests that 25 percent of the annual total phosphorus load is conveyed in the first one-half inch of rainfall, and 15 percent of the annual TSS load. For the first inch of rainfall, that load is 65 percent of annual TP and 50 percent of annual TSS. In the Twin Cities, 90 percent of all rainfall events are one inch or less. The most common form of abstraction is infiltration. A growing number of watershed management organizations are enacting infiltration rules, with one-half inch infiltration from new impervious surface common. The Ramsey-Washington County Watershed District and Capitol Region Watershed Districts recently enacted a one inch from new impervious surface rule, and the Minnehaha Creek Watershed District is considering one inch as well. Adopting an abstraction requirement will reduce the new volume of runoff from developing and redeveloping areas. Chanhassen soils are mapped as generally being of soil hydrologic group B. These soils readily infiltrate. However, do to the highly urbanized land use throughout much of Chanhassen actual infiltration rates may be diminished from those anticipated for the mapped soil unit. There are pockets of less permeable C and D soils. Most development and redevelopment should be able to successfully incorporate infiltration. An abstraction requirement for new development will only address new volume predicted to occur between its promulgation and 2020 - about 1,950 acre-feet. However, in the very long- term, as existing development redevelops, the new volume generated between 1990 and 2000 and prior will slowly be mitigated as redevelopment and reconstruction occurs. The projected new storm water volume between 2000 and 2020 is 1,950 acre-feet. A one-half inch abstraction requirement might reduce new stormwater volume by an estimated 65 percent, or 1,270 acre-feet, leaving an estimated net new stormwater volume of 680 acre-feet. The City will work with the Watershed Districts to review and consider adopting a volume management requirement for new development and redevelopment. Soil Management Plan requirement. An assumption in calculating stormwater volume to be captured from an abstraction requirement is that the part of the site that is pervious and infiltrating stormwater pre-construction will be as pervious and infiltrate at least as much stormwater volume post-construction. In reality, construction activities such as mass grading, road and utility construction, and structure construction lead to soil compaction and loss of permeability. To maximize the effectiveness of an infiltration requirement, the City will consider revising its ordinances to require developers to submit a Soil Management Plan that details how the developer plans to 1) minimize soil compaction from construction activities, 2) phase construction activities to minimize exposed soils, and 3) restore site permeability through actions such as post-construction soil ripping or soil amendment. City of Chanhassen Nondegradation Assessment 32 D R AFT December 07 Encourage Low Impact Development (LID). Low Impact Development (LID), Integrated Management Practices (IMP), and Better Site Design principles and practices encourage developers to consider stormwater impacts of new development early in the planning process. The City's zoning code includes provisions for Planned Unit Developments that may vary from strict application of zoning requirements to make it easier to tailor a development to the terrain and minimize stormwater impacts such as new volume. The City will review its zoning code and Planned Unit Development process to evaluate existing zoning or development incentives to encourage developers to creatively apply LID, IMP and better site design principles to minimize new stormwater volumes and pollutant loading and to consider revisions to its zoning code and PUD process. 5.4.2 Education Program The City has in place an education and outreach program to provide information to various audiences on a wide variety of stormwater management and water quality issues. This program will target both residential property owners and commercial property owners on ways to incorporate small infiltration practices on their property. Small-scale practices such as rain gardens, conversion of turf to native vegetation, pond and wetland buffers, installation of rain barrels and cisterns, and use of pervious pavement and pavers, can add up to significant water quality and stormwater reductions when broadly applied. The City will utilize its currently existing educational programming as well as explore cooperative opportunities with outside agencies and will also develop targeted information for developers on incorporating Low Impact Development principles and water quality and volume management into development and redevelopment. 5.4.3 Structural Improvements Structural BMPs to manage storm water volume will be constructed as stand-alone projects or incorporated into other projects such as street reconstruction as opportunities arise. These BMPs store and infiltrate or evapotranspirate storm water at the street, block, or neighborhood scale. The cost per acre-foot for these types of BMPs can be significant as stand-alone projects, but may be more cost-effective when combined with other improvements such as a neighborhood street reconstruction project. These types of BMPs also will have the benefit of further reducing pollutant loading. Where it is difficult or too costly to significantly reduce new stormwater volume, downstream water resources will be protected from adverse effects through restoration and stabilization projects. Infiltration basins. An infiltration basin is a shallow, vegetated basin designed to hold and infiltrate stormwater. Some evapotranspiration also occurs. Infiltration basins also have an ongoing significant maintenance cost. Over time sediment discharged into the basins accumulates and reduces the infiltration capacity. This sediment must be removed periodically and permeability restored through soil ripping, soil amendment, etc. City of Chanhassen Nondegradation Assessment 33 D R AFT December 07 Constructed wetlands. Constructed wetlands can decrease stormwater volume through evapotranspiration from wetland vegetation as well as evaporation from open water stored in the wetland. Underground infiltration. New technologies are available to construct infiltration devices under large paved areas such as parking lots or streets Integrated Management Practices (IMP), and Better site Design principles and practices. There is an ongoing annual cost to remove and dispose of accumulated material from the device. Streambank stabilization. The new volume of storm water generated through land use change is conveyed through the system of lakes, wetlands, and small channels into the major streams that drain the City: Bluff Creek and Riley Creek and to a lesser extent Assumption Creek. This additional volume increases peak flow rates and elevations in the streams, and has the potential to destabilize and erode streambanks. The increased peak flows and streambank erosion also may stress biological communities in the streams. These adverse impacts can be mitigated by strengthening streambanks and restoring areas of existing erosion, as well as considering structural amendments to the stream channel such as rock vanes. Habitat lost to past impacts can be mitigated with this restoration by re-vegetating streambanks, adding step pools, and enhancing substrate. The City and the watershed districts have performed general inventories of the major streams to identify areas of existing erosion. The City is currently taking steps to stabilize a number of the identified erosion areas and will continue to work in partnership with the watershed districts to undertake a program of stream restoration. These projects would range from simple spot repairs of streambanks to potential total restoration of the stream. These projects will combine both stabilization and habitat enhancement. 5.4.4 Nonstructural Improvements Reforestation. Urban trees are an integral part of the storm water management system. Trees intercept rain and snow fall, storing event volume for later evaporation. Trees also use surface storage for transpiration, removing additional storm water volume from the stormwater system. Trees have other benefits as well. Trees increase property values, provide habitat, take in C02 and release oxygen, enhance neighborhood aesthetics, and decrease home heating and cooling costs. The City recognizes this value by requiring, by ordinance, replacement of trees lost to construction or land alteration. Numerous studies have been conducted estimating the volume ofrainfall that trees intercept (for example, Xiong et al 2000, McPherson 2005) This annual volume is dependant on the type and species of tree, and whether the tree is isolated, such as an urban street tree, or part of a forest canopy. For example, evergreen trees can intercept and store more stormwater than deciduous trees because their narrow leaves provide a greater leaf surface area. The volume also depends on the intensity of the storm, with less intense events resulting in more interception. On average, however, literature suggests that an isolated deciduous tree can intercept approximately 25 percent of the annual volume of rainfall that falls upon it. Combined with the daily water use for City of Chanhassen Nondegradation Assessment 34 DR AFT December 07 transpiration (Wullschleger 1998), it is estimated that a single deciduous tree can evapotranspirate 2,000 - 3,000 gallons of stormwater per year. A coniferous tree can evapotranspirate an even greater amount. It is estimated that about 10,000 trees could evapotranspirate about 100 acre-feet of stormwater volume. The City will evaluate its existing reforestation program and current preservation practices to reduce the amount of rainfall that runs off the landscape. WetlandlUpland Restoration. The City has restored dozens of acres of wetlands and will continue to look for additional opportunities to restore wetland areas and the associated upland. Wetland vegetation is very efficient at transpiring significant volumes of water, reducing the overall volume discharged to water resources downstream. Native vegetation planted in restored uplands can increase the infiltration capacity of poorer soils by increasing organic matter in the soil and by creating long root channels to convey water deep into the soil. City of Chanhassen Nondegradation Assessment 35 DR AFT December 07 6.0 SWPPP MODIFICATIONS The following are the proposed modifications to the City of Chanhassen SWPPP to address the findings of this analysis. 6.1 Total Suspended Solids The City currently meets the Total Suspended Solids requirement. Modifications to the SWPPP are confined to some refinement of the BMPs for those activities that reduce TSS throughout the City, and specifically in the Lake Ann subwatershed. 6.1.1 Regulatory Program Development rules will continue to require land-altering activities to provide at least NURP-Ievel removal (80%) of Total Suspended Solids prior to discharge. The City's Surface Water Management ordinance specifies design criteria, including NURP-Ievel removals. BMP 5b-l Regulatory Mechanism to Address Post Construction Runoff from New Development and Redevelopment provides for review and update of ordinances to ensure they are adequate and consistent with storm water management plan requirements. No additional update is necessary. 6.1.2 Street Sweeping Increased street sweeping frequency may be of benefit in sensitive locations, where there is noticeable aggradation in streams or below outfalls or where a UAA or TMDL indicates that efforts should be maximized to remove pollutant loading. BMP 6a-2 Street Sweeping will be revised to add an evaluation of locations where additional street sweeping would be most effective. Based on that evaluation the City may perform additional sweeping in those sensitive areas. 6.1.3 Lake Ann Subwatershed BMP 5a-l will be revised to include an evaluation of land use policies for the Lake Ann watershed that would minimize increase in TSS and also complement the Comprehensive Land Use plan promoting the dedication of park land and preservation of buffers and open space within the watershed. Such policies may include park expansion, increased setbacks or buffers, tiered density, promotion of cluster housing, or restrictions on the amount of land in anyone phase of construction. The City will continue to actively manage the forested area within Lake Ann Park to maximize canopy cover as well as look for additional opportunities in Lake Ann Park for abstraction. City of Chanhassen Nondegradation Assessment 36 DR AFT December 07 Opportunities for additional stormwater treatment, abstraction and infiltration will be identified within the Lake Ann watershed and the City will work with adjacent property owners to facilitate these opportunities. 6.1.4 Other Activities The volume management activities described in section 5.3 above such as increased infiltration, biofiltration, and runoff volume controls may further reduce TSS loading by pre-treating or reducing the amount of runoff volume conveying TSS to waters. BMP 5a-l Development and Implementation of Structural and/or Non-structural BMPs will be amended to incorporate these practices into city construction projects. 6.2 Total Phosphorus The City currently meets the Total Phosphorus requirement. Modifications to the SWPPP are confined to some refinement of the BMPs for those activities that reduce TP throughout the City, and specifically in the Lake Ann and Riley-Purgatory-Bluff Creek subwatersheds. 6.2.1 Regulatory Program Development rules will continue to require land-altering activities to provide at least NURP-level removal (60%) of Total Phosphorus prior to discharge. The City's Surface Water Management ordinance specifies design criteria, including NURP-level removals. BMP 5b-l Regulatory Mechanism to Address Post Construction Runoff from New Development and Redevelopment provides for review and update of ordinances to ensure they are adequate and consistent with storm water management plan requirements. No additional update is necessary. 6.2.2 Street Sweeping Increased street sweeping frequency may be of benefit in sensitive locations, where there is noticeable aggradation in streams or below outfalls or where a UAA or TMDL indicates that efforts should be maximized to remove pollutant loading. BMP 6a-2 Street Sweeping will be revised to add an evaluation of locations where additional street sweeping would be most effective. Based on that evaluation the City may perform additional sweeping in those sensitive areas. The City will also review the coordination and timing of street sweeping activities with other City management activities to maximize efficacy of sweepings. 6.2.3 Lake Ann and Riley Purgatory Bluff Creek Subwatersheds The BMPS identified in Section 6.1.3 above would also reduce TP load to Lake Ann. A significant portion of this subwatershed falls within the City's Bluff Creek Overlay District, described in Section 3.1.1 above. This ordinance contains a number of zoning and planning tools that will be applied to development and redevelopment in this overlay district as part of the City's overall policy to protect the Bluff Creek Corridor and its wetlands, bluffs, wooded areas, and water resources. BMP 5b-l Regulatory Mechanism to Address Post Construction Runoff from New Development and Redevelopment will be revised to provide for a review of the City of Chanhassen Nondegradation Assessment 37 DR AFT December 07 Overlay District ordinance to determine whether revisions are necessary to provide additional protection. 6.2.4 Other Activities The volume management activities described in section 5.3 above such as increased infiltration, biofiltration, and runoff volume controls may further reduce TP loading by pre-treating or reducing the amount of runoff volume conveying TP to waters. BMP 5a-l Development and Implementation of Structural and/or Non-structural BMPs will be amended to incorporate these practices into city construction projects. 6.3 Volume The City will work cooperatively with the three watershed districts with land in the city to coordinate regulatory volume management BMPs with watershed district rules. 6.3.1 Regulatory Program Abstraction requirement BMP 5b-l Regulatory Mechanism to Address Post Construction Runoff from New Development and Redevelopment will be revised to provide for review and amendment of local controls and the local water management plan to evaluate and implement an abstraction/infiltration requirement for new development and redevelopment that is consistent with watershed district requirements. Soil Management Plan requirement. BMP 5b-l Regulatory Mechanism to Address Post Construction Runoff from New Development and Redevelopment will be revised to provide for review and amendment of local controls and the local water management plan to evaluate and implement a soil management plan requirement for new development and redevelopment. Evaluate regulatory means to encourage Better Site Design. BMP 5b-l Regulatory Mechanism to Address Post Construction Runoff from New Development and Redevelopment will be revised to provide for a review of City Ordinances and procedures to identify means such as zoning or development incentives to encourage developers to incorporate Low Impact Development (LID), Integrated Management Practices (IMP) or Better Site Design principles to minimize new stormwater volumes and pollutant loading. 6.3.2 Education Program The City undertakes an education and outreach program to providing education to various audiences on a wide variety of stormwater management and water quality issues. These are described in various BMPs implementing Minimum Measure 1: Public Education and Outreach. These BMPs adequately generally describe the education and outreach program. Specific topics to be covered in these activities vary from year to year. The annual list of topics will include information on small practices for water quality and volume management such as rain gardens, conversion of turf to native vegetation, installation of rain barrels and cisterns, and use of pervious pavement and pavers. Topics will also include developer education regarding City of Chanhassen Nondegradation Assessment 38 DR AFT December 07 storm water management. Other educational and outreach activities will include continuation of the existing Arbor Day tree sale and promotion of the Carver County Soil and Water Conservation District's seedling pack purchase program. Current methods to communicate with the public will be evaluated and revised as necessary. 6.3.3 Structural Improvements Structural Projects. Structural BMPs will be constructed as stand-alone projects or incorporated into other projects such as street reconstruction as opportunities arise. The highest need is for the reduction of new stormwater volume generated since 1988. Most structural volume-management improvements are not cost-effective as stand-alone projects, but may be more cost-effective if they can be incorporated into other projects such as street reconstruction. BMP 5a-l Development and Implementation of Structural and/or Non-structural BMPs will be revised to incorporate pollutant loading and volume management BMPs on city projects. Mitigation Projects. Where it is difficult to significantly reduce new storm water volume, downstream water resources can be protected from adverse effects through restoration and stabilization projects. BMP 5a-l Development and Implementation of Structural and/or Non- structural BMPs will be revised to incorporate development of a stream and shoreline restoration program to mitigate past erosion, enhance habitat, and prevent future erosion. The City will continue identifying eroded gullies, escarpment and wash areas and begin to cooperatively mitigate these areas whenever possible with the Watershed Districts. This program may include city or watershed district projects, and assistance to property owners in completing such projects. 6.3.4 Nonstructural Improvements Reforestation. BMP 5a-l Development and Implementation of Structural and/or Non-structural BMPs will be revised to include a goal to provide opportunities for resident to purchase or plant trees for increased storm water abstraction based upon the existing spring tree sale held annually by the City and the tree coupon program the City currently operates. The City will continue its policy of preserving existing woodland areas where opportunities arise through density transfer, conservation easements, park dedication and other planning tools. BMP 5b-l Regulatory Mechanism to Address Post Construction Runoff from New Development and Redevelopment describes the ordinance review process the City will undertake to determine if its regulatory program is adequate to effectively prevent or reduce nonpoint source pollution. As part of that review process the City will review its existing Landscaping and Tree Preservation Requirements and revise if necessary to promote tree preservation and reforestation. WetlandlUpland Restoration. BMP 5a-l Development and Implementation of Structural and/or Non-structural BMPs will be revised to note that the city will continue to look for opportunities to undertake wetland and upland restorations as volume management BMPs that are part of an overall volume management program. City of Chanhassen Nondegradation Assessment 39 DR AFT December 07 References Bannerman, R.T. et al. 1993. Sources of pollutants in Wisconsin storm water. Wisconsin Department of Natural Resources. Water, Science and Technology. 28 (3-5): 241-259. Bannerman, R.T. 2007. Reducing the uncertainty in the calculations of street cleaner performance for Wisconsin municipalities. Wisconsin Department of Natural Resources. Unpublished research. Frelich, Lee E. 1992. Predicting dimensional relationships for Twin Cities shade trees. St. Paul, MN: University of Minnesota, Department of Forest Resources. McPherson, G. et al. 2005. Municipal forest benefits and costs in five US cities. Journal of Forestry. December 2005: 411-416. Minnesota Department of Transportation. 2005. The cost and effectiveness of stormwater management practices. Report No. MNIRC - 2005-23. St. Paul, MN: MnDOT Research Services Section. Minnesota Pollution Control Agency. 2000. Protecting Water Quality in Urban Areas. St. Paul, MN. " http://www.pca.state.mn.us/water/oubs/sw-bmomanual.html>> Minnesota Pollution Control Agency. 2006. Minnesota Stormwater Manual. St. Paul, MN. << http://www.pca.state.mn.us/water/stormwater/stormwater-manual.html>> Obermeyer, B. Riley-Purgatory Creek-Bluff Creek and Nine Mile Creek Watershed District engineer. Pers. corresp. 6/8/06, 7/12/06 Pitt, Robert E. April 29-30, 1998. Course notes presented at the workshop: Storm Water Quality Management through the Use of Detention Basins. Earl Brown Continuing Education Center, Univ. of Minnesota, St. Paul, Minn. Pitt, R., J. Lantrip, and R. Harrison. 1999. Infiltration through disturbed urban soils and compost- amended soil effects on runoff quality and quantity. Report No. EPAl6001 R-001016 US EPA. National Risk Management Research Laboratory, Cincinnati, OH. USEPA. 1999. Preliminary data summary of urban storm water best management practices. Report No. EPA-821-R-99-012 Wullschleger, S. D., F.e. Meinzer, and R.A. Vertessy. 1998. A review of whole-plant water use studies in trees. Tree Physiology. 18:499-512. Xiao, Q., et al. 2000. Winter rainfall interception by two mature open-grown trees in Davis, California. Hydrological Processes. 14:763-784. Xiao, Q., et al. 2000. A new approach to modeling tree rainfall interception. Journal of Geophysical Research. 105(D23):29,173-29,188. City of Chanhassen Nondegradation Assessment 40 DR AFT December 07 ~jAd Metropolitan Council A'l..f1 December26, 2007 Environmental Services Mr. Terry Jeffery Water Resources Coordinator City of Chanhassen 7700 Market Blvd Chanhassen, MN 55317 CITY OF CHANHASSEN fRl[g(G~n'W~fD) DEe 3 1. 2007 RE: Chanhassen Draft Nondegradation Plan ENGINEERiNG DEPT Dear Mr. Jeffery: Metropolitan Council staff has reviewed the draft Nondegradation Assessment plan prepared for the city as part of its MS4 NPDES permit requirements. Council staff has found the plan to be consistent with the Council's Water Resources Management Policy Plan. The above plan indicates that the amount of suspended solids and phosphorus will be reduced between 1990 and 2020. However, the total runoff volume will increase by over 50 percent :fiom 1990 conditions. The plan outlines several strategies which the city will consider to reduce the runoff volume between current conditions and 2020. However, the plan does not detail a clear action plan for achieving reductions in stom1 water volume. There are a number of "impaired waters" in the city which are being degraded because of increased sto11n water runoff. It is critical that a clearly defined action plan be proposed on how the city will reduce storm water volume so these impaired water bodies can be improved. Requiring abstraction/infiltration for development and redevelopment as well as a soil management plan and promoting low impact development will all lead toward improved waters by reducing runoff volume but it takes a strong regulatory conunitment from the city to bring this to fruition. Thank you for the opportunity to review the city's nondegradation plan. If you have any questions about the comments, please contact Jack Frost of my office at 651-602-1078. sincere7~ -- Keith Buttleman, Assistant General Manager Environmental Quality Assurance Department KB:jf cc: Diane Spector, Wenck and Associates Jim Dttley, Metropolitan Council Sector Represelitative www.metrocouncil.org 390 Robert Street North. St. Paul, MN 55101-1805 . (651) 602-1005 . Fax (651) 602-1477 . TI'Y (651) 291-0904 An Equal Opportunity Employer Page 1 of 1 Jeffery, Terry From: Aanenson, Kate Sent: Monday, January 14, 2008 3:56 PM To: Jeffery, Terry Subject: FW: Chanhassen Lakes assessment From: Sstrohma@aol.com [mailto:Sstrohma@aol.com] Sent: Monday, January 14, 20084:01 PM To: City Council; Aanenson, Kate Subject: Chanhassen Lakes assessment To: City of Chanhassen Planning commission and City Council I am a resident of Chanhassen concerned about the qualtiy of Lotus Lake. The non-degradation assessment the city has developed appears to be an excellent, well developed document. I appreciate the work that has gone into it. I support the recommendations to have the city adopt the more advanced storm water management practices mentioned in the document on page 2 of the executive summary and section 5.4.1. The report also points out that Lotus Lake will meet the 1988 guideline due to the fact that the Lake was fully developed in 1988 and thus will not get much attention due to this assessment. I'd like to point out, however, that Lotus Lake is still on the impaired waters list and needs to be improved well beyond 1988 standards. Therefore, I want to strongly recommend that you support the Lotus Lake improvement project that the Watershed is proposing as part of the its 10 year plan. This plan implements the more advanced storm water management practices by reducing volume and improving the quality and can be used a stepping stone for the rest of the city's lakes and streams. Thank you for your consideration of this issue. Sincerely, Shelley Stroh maier Strohmaier Consumer Insights 80 Sandy Hook Road Chanhassen, MN 55317 Phone: 952-949-1143 Fax: 952-949-1157 sstrohma@aol.com Start the year off right. Easy ways to stay in shape in the new year. 1/15/2008 Page 1 of 1 Jeffery, Terry From: Aanenson, Kate Sent: Tuesday, January 15, 2008 7:54 AM To: Jeffery, Terry Subject: FW: Lotus Lake From: Dave Susla [mailto:Dave.Susla@palmcoveofbradenton.com] Sent: Monday, January 14, 2008 5:22 PM To: City Council; Aanenson, Kate Subject: Lotus Lake Hi, my name is Dave Susla, I am the recently elected President of the Lotus Lake Homeowners Association. I am writing to you out of concern for Lotus Lake as it relates to the recent studies on the non-degradation assessments. While the assessment the city has developed appears to be an excellent document and I appreciate the fine work that has gone into it, I am concerned that it does not go far enough to protect and preserve Lotus Lake and, more importantly, ultimately get Lotus Lake removed from the impaired waters list. strongly support the recommendations to have the city adopt the more advanced storm water management practices mentioned in the document on page 2 of the executive summary and section 5.4.1 . While it is fairly evident that Lotus Lake will meet the 1988 guideline, it is mainly due to the fact that Lotus Lake was fully developed in 1988. So the 'bar' was set pretty low with regards to improvement, as the majority of the damage from development was already present in 1988. The bottom line is that Lotus Lake will receive very little benefit by meeting the 1988 guideline. Given this fact and the fact that Lotus Lake is still on the impaired waters list, it needs to be improved well beyond 1988 standards. While there has been no formal homeowner vote on this subject, I can tell you from personal conversations with many lakeshore owners, water quality is a primary and growing concern on the lake. As a group, I can assure you that we are very interested in seeing you support the Lotus Lake improvement project that the Watershed is proposing as part of the watershed's 10 year plan. As I am sure you know, the plan will implement more advanced Storm water management practices than are currently being proposed. The ultimate goal of the watershed's program is to get Lotus Lake off of the impaired waters list. I want to thank you in advance for taking the time to read this note and, ultimately, for your support. Regards, Dave Susla 1/15/2008 Page 1 of 1 Jeffery, Terry From: Aanenson, Kate Sent: Tuesday, January 15, 2008 7:55 AM To: Jeffery, Terry Subject: FW: Non Degradation Assessment From: Joe Pfankuch [mailto:j.pfankuch@mchsi.com] Sent: Monday, January 14, 2008 6:23 PM To: City Council; Aanenson, Kate Subject: Non Degradation Assessment Dear City of Chanhassen Planning commission and City Council: As a Lotus Lake resident and Chanhassen citizen since 1991 and I'm very proud of our lake, and we feel privileged to have this type of resource. But I'm embarrassed that some Chanhassen residents still won't swim in Lotus Lake due to the pollution. My family is very interested in improving the "impaired" status of our lake and we have taken a proactive effort: . Picking up garbage on the lake during ice fishing season . Helping to educate neighbors to become good stewards. . Cleaning the streets from harmful items which could wash into the lake · Communicating DNR and City water preservation ideas to the lake's watershed area . Etc. It appears the non-degradation assessment the city has developed is a commendable document with sound results. It shows that Lotus Lake has passed this assessment when related to 1988 guidelines. At first glance, one would think that this is good - and it's certainly not bad. But the lake was fully developed and fairly polluted in 1988 and so even meeting these guidelines we are still "impaired". To this end, going back to a previously unacceptable standard just doesn't make sense. I don't think Cleveland wants to go back to 1969 when the Cuyahoga River was on fire. It's the same scenario. Although I appreciate the hard work put into the assessment, we need to (and can) do better by comparing ourselves against excellence, not mediocrity. Our Schools don't aim for mediocrity and I wouldn't think we'd want our natural resources to be satisfied with it either. We need to strive for better than this. And we have a great opportunity to do so with a huge groundswell of support. Therefore, I am strongly in favor of the recommendations to have the city adopt the more advanced storm water management practices mentioned in the document on page 2 of the executive summary and section 5.4.1. Furthermore, I want to strongly recommend that you support the Lotus Lake improvement project that the Watershed is proposing as part of the watersheds 10 year plan. This plan basically implements the more advanced Storm water management practices by reducing volume and improving the quality and can be used a stepping stone for the rest of the city's lakes and streams. Thank you for your considerations, I look forward to doing more than my share to help clean up one of our best resources. Regards, Joe Pfankuch 1/15/2008 Jeffery, Terry From: Sent: To: Subject: Aanenson, Kate Tuesday, January 15, 2008 11 :42 AM Jeffery, Terry FW: Non Degradation Meeting Tonight -----Original Message----- From: corpmech@netzero.net [mailto:corpmech@netzero.net] Sent: Tuesday, January 15, 2008 11:34 AM To: Aanenson, Kate Subject: Non Degradation Meeting Tonight Kate, The non-degradation assessment the city has developed appears to be an excellent document well developed and with sound results. I appreciate the fine work that has gone into it. I am writing to support the recommendations to have the city adopt the more advanced storm water management practices mentioned in the document on page 2 of the executive summary and section 5.4.1. I commend Paul Oehme & Terry Jeffery for their recent combined efforts with the Riley Purgatory Bluff Creek Watershed. They have both been very open minded & have offered many out-of-the-box suggestions that will benefit the environment while meeting the growing needs of Chanhassen. Paul & Terry are currently working together with the RPBC watershed? engineer on the Meadow Green Wetland project in the Carver Beach area to maximize the end result of clean water leaving the pond, as well as, taking advantage of possibly $800,000 of watershed funding to meet common goals. By partnering on projects with common goals, the resolutions will take both perspectives into consideration & our city tax dollars will go farther. It is imperative that we make funds available to focus on implementing redevelopment standards of infiltration for retrofitting volume management where opportunities arise on city street & reconstruction projects throughout all of Chanhassen. These projects will reduce erosion while Improving water quality for all of our lakes & streams. Lotus Lake was already a fully developed residential lake in 1988i the phosphorous & suspended solid statistics were already at a level beyond it?s classification of a recreational lakei which is defined as fishable & swimable. Regardless of the fact that Lotus scathes by on the non-degradation report required by the city (being the same as 1988) i the volume of surface water run-off is extremely high and we are recognized as an impaired water with the State since 2003. Accepting 1988 (post development) levels of phosphorous & pollutants for this particular lake would be less than mediocrity. Lotus being added to the MN303D impaired list dictated that tax payers conduct an $80,000 Use Attainability Analysis (UAA). The UAA was completed by Barr Engineering in 2005. This comprehensive study analyzes the phosphorous, nitrate, suspended solid loading, and invasive plant specie issues and their many sources. Barr?s report addresses exact steps that need to be taken including 4 years of herbicide treatment to kill the excessive mil foil and curly leaf pond weed that was enabled by high phosphorous levels. Alum treatment during years 5-7 to prevent the phosphorous already on the bottom of the lake from recirculating throughout the lake. Years 8-10 continual monitoring and possible reapplication of herbicide or alum. We also need to terminate the purple loosestrife by introducing Galerualla Beetles supplied by the DNR. In addition to Barr?s recommendations, the watershed?s proposed ten year plan would implement more advanced storm water management practices by reducing volume and improving the quality. The only way the proposed ten year plan will PERMANENTLY improve the lake is by PERMANENTLY reducing volume & phosphorous entering the lake. This is true of all Chanhassen lakes & streams. Since the report was released in 2005, some holding ponds have been modified & cleaned out. None of the many recommendations by Barr Engineering have taken place, and unfortunately there has not been any measurable improvements to water quality. So to consider Lotus Lake with two city parks, public swimming beaches & a fishing dock up to par is a huge misconception. Three dedicated members or our Lotus Lake Clean Water Organization (LLCWO), Steve Donen, Scott Maeyaert & myself, have been working with the Riley Purgatory Bluff Creek Water Shed District since May of 2007 to implement the 10 year plan recommended by Barr Engineering. By working with local watersheds the city will have a better opportunity to develop plans that work & defray costs from city funds. This plan would reduce volume and improve quality of the storm water run off. We strongly encourage the support of city managers and Council to encourage the watershed to proceed with the proposed ten year RPBC plan. Thank you for your considerations. Sincerely, Mary Borns 7199 Frontier Trail Beauty Product Reviews Read unbiased beauty product reviews and join our product review team! http://thirdpartyoffers.netzero.net/TGL2221/fc/JKFkuJkEB6rxyQH339M6Ur6wvu8Dr09cDXEJTns65zb KSfp28sgRmN/ 2 Jeffery, Terry From: Sent: To: Subject: Aanenson, Kate Tuesday, January 15, 2008 2:56 PM Jeffery, Terry FW: non degradation assesment -----Original Message----- From: Scott P Maeyaert [mailto:scott.p.maeyaert@ampf.com] Sent: Tuesday, January 15, 2008 1:43 PM To: City Council; Aanenson, Kate Subject: non degradation assesment The non-degradation assessment the city has developed appears to be an excellent document well developed and with sound results. I appreciate the fine work that has gone into it. I am taking this time to write this note to support the recommendations to have the city adopt the more advanced storm water management practices mentioned in the document on page 2 of the executive summary and section 5.4.1. Also, it points out that Lotus Lake will meet the 1988 guideline due to the fact that Lotus Lake was fully developed in 1988 and thus will not get much attention due to this assessment. I want to remind you that Lotus Lake is still on the impaired waters list and needs to be improved well beyond 1988 standards, for this reason I want to strongly recommend that you support the Lotus Lake improvement project that the Watershed is proposing as part of the watersheds 10 year plan. This plan basically implements the more advanced Storm water management practices by reducing volume and improving the quality and can be used a stepping stone for the rest of the city's lakes and streams. Thank you for your considerations; > > > > > > > > Scott. P. Maeyaert, CFP@ Senior Financial Advisor An Ameriprise Platinum Financial ServicesSM practice Ameriprise Financial Services, Inc. 7601 France Ave South. Suite 550 Edina, MN. 55435-5970 Office: 952.857.1280 I Fax: 952.831.0974 scott.p.maeyaert@ampf.com ameriprise.com We shape financial solutions for a lifetime@ Ameriprise Financial Services, Inc. offers financial advisory services, investments, insurance and annuity products. RiverSource@ products are offered by affiliates of Ameriprise Financial Services, Inc., Member FINRA and SIPC. ************************************************************-****************** "This message and any attachments are solely for the intended recipient and may contain confidential or privileged information. If you are not the intended recipient, any disclosure, copying, use, or distribution of the information included in this message and any attachments is prohibited. If you have received this communication in error, please notify us by reply e-mail and immediately and permanently delete this message and any attachments. Thank you." ****************************************************************************** 1 Page 1 of 1 Jeffery, Terry From: Aanenson, Kate Sent: Tuesday, January 15, 2008 4:35 PM To: Jeffery, Terry Subject: FW: Chanhassen Non-degradation Plan -Lotus Lake needs more help From: Greg Fletcher [mailto:fletch_55317@yahoo.com] Sent: Tuesday, January 15, 2008 4:38 PM To: City Council; Aanenson, Kate Subject: Chanhassen Non-degradation Plan -Lotus Lake needs more help Subject: RE: Chanhassen Non-Degradation Plan - Lotus Lake needs more help. I think the City is moving in the right direction and support the general Non-Degradation Plans. But additional attention needs to be given to the water quality of Lotus Lake. It is classified as impaired and would have been classified as impaired in 1988 -the targeted levels of 'improvement'. I recommend the the Council and City staff work with the Riley, Purgagory Bluff Creek Watershed District and other concerned organizations (Lotus Lake Clean Water Organization, Lotus Lake Homeowners Association) to implement Best Practice Water Management strategies to improve the water quality in Lotus Lake. We need to: . Reduce the run off volume entering Lotus Lake. . Reduce Total Disolved Solids entering the Lake . Study in-flow and out-flow to determine ways of better managing bounce after rains. . Reduce Phosphorus levels entering the Lake . Treat the phosphorus existing within the Lake. . Manage invasive and destructive Carp Thank you, Greg Fletcher 7616 S. Shore Drive Chanhassen, MN 55317 612-710-9481 c Looking for last minute shopping deals? Find them fast with Yahoo! Search. 1/15/2008 Memorandum To: Terry Schwalbe Project: Chanhassen Nondegradation Assessment Date: 1/8/2008 From: Dan Murphy Client: LMRWD Re: LMRWD Review File No: 1460-08-000 Remarks: Per your request. we have reviewed the December 2007 Chanhassen Nondegradation Assessment Draft on behalf of the LMRWD. The non-structural BMPs (regulatory and educational programs) and structural BMPs listed by the Assessment as measures to reduce citywide stormwater runoff volume and pollution meet the goals, policies and criteria of the District as described in the 1999 LMRWD Water Management Plan (WMP). Detailed comments follow below: The Assessment has determined that volumes of Total Suspended Solids (TSS) and Total Phosphorus (TP) generated city-wide have been reduced to a level below that estimated to have been contributed in 1990 (Sections 5.2 & 5.3). However, increases in TSS and TP from 1990 to 2020 are projected to occur at a smaller scale for the Lake Ann and Riley-Purgatory- Bluff Creek subwatersheds. The Lake Ann subwatershed is projected to generate 845 pounds more TSS in 2020 than was generated in 1990 (Section 5.2.3). In addition, the Lake Ann subwatershed is projected to generate 8 pounds more TP in 2020 than was generated in 1990, with 70 additional pounds TP estimated in the Riley-Purgatory-Bluff Creek Subwatershed (Section 5.3.3). 1) The measures listed below are included in the Assessment as sources of the past citywide TSS and TP reductions. These measures will continue to be implemented by the City in the future. a. Sections 5.2.1 and 5.3.1 of the Nondegradation Assessment state that the City has and will continue to apply development rules which require that land-altering activities provide NURP-Ievel removal of TSS (80%) and TP (60%) prior to discharge. For waterbodies classified by the LMRWD as Level I or II (the most restrictive classification), Section 5. 13.3 of the LMRWD WMP requires that new developments construct ponds which provide water quality volume greater than or equal to the 2. 5- inch, 24-hour storm. Providing this amount of water quality volume is equivalent to providing the NURP-Ievel removal of TSS and TP listed in the Assessment. . Bonestroo 2335 Highway 36 W St. Paul. MN 55113 Tel 651-636-4600 Fax 651-636-1311 www.bonestroo.com b. Sections 5.2.2 and 5.3.2 of the Nondegradation Assessment state that the City sweeps its streets once per year in the spring and other street sweeping is performed throughout the year as necessary. Street sweeping practices will be refined to improve the water quality and overall benefit of street sweeping. Street sweeping supports the LMRWD goal, listed in Section 5.4 of the WMP, of reducing non-point source pollution in the District. The LMRWD WMP also lists street sweeping as a Non-structural Source Control8MP (WMP Table 5-9) to be potentially implemented into Runoff Management Plans as required in Section 5. 13. 1 of the WMP. 2) Section 5.2.3 of the Nondegradation Assessment states that the Lake Ann subwatershed is projected to generate 845 pounds more TSS in 2020 than was generated in 1990. The Nondegradation Assessment lists the following BMPs that will be considered to mitigate TSS within the watershed: a. The City will investigate the possibility of retrofitting those outfalls with sump manholes or other devices to collect sediment prior to discharge to the lake. The use of sump manholes as a structural storm water 8MP is not specifically addressed in the LMRWD WMP. However, this type of measure is generally supported by the goals and policies listed in the LMRWD WMP. b. The City will look for opportunities to reduce runoff by increasing abstraction in the subwatershed to reduce the creation of new TSS. Policy 3 in Section 5.5.2 of the LMRWD WMP states that the District "encourages the use of temporary surface storm water storage facilities and infiltration techniques wherever practical and environmentally sound". c. The City will evaluate land use policies governing development for opportunities to reduce the creation of new TSS. This measure is generally supported by the goals and policies listed in the LMRWD WMP. 3) Section 5.3.3 of the Nondegradation Assessment states that the Lake Ann subwatershed is projected to generate 8 pounds more TP in 2020 than was generated in 1990, with 70 additional pounds TP estimated in the Riley-Purgatory-Bluff Creek subwatershed. The City proposes to reduce TP and TSS in the same manner as described about in item 2). The City proposes to reduce TP in the Riley-Purgatory-Bluff Creek subwatershed using the following BMPs: a. The City will use its Bluff Creek Overlay District ordinance to protect the Bluff Creek corridor and its wetlands, bluffs, wooded areas, and water resources. A significant portion of the subwatershed is within the aforementioned Overlay District. Page2of4 This measure is generally supported by the goals and policies listed in the LMRWD WMP. b. The City will incorporate TP reduction BMPs into City projects as opportunities arise if the regulatory program is not successful in limiting new TP. This measure is generally supported by the goals and policies listed in the LMRWD WMP. 4) The Assessment estimates that stormwater volume increases citywide by about 50% between 1990 and 2020. To mitigate some of this increase, the City lists the following regulatory and structural BMPs: a. Section 5.4.1 of the Assessment states that the City will work with the Watershed Districts to review and consider adopting a volume management requirement. Specific measures would be to require Soil Management Plans for development and redevelopment projects and encourage Low Impact Development practices. Currently the LMRWD does not require the infiltration or abstraction of stormwater. However, Policy 3 in Section 5.5.2 of the LMRWD WMP states that the District "encourages the use of temporary surface storm water storage facilities and infiltration techniques wherever practical and environmentally sound". b. Section 5.4.2 of the Assessment states the City will continue to facilitate its education and outreach program to educate citizens of small scale measures that can be implemented on their property to reduce stormwater volume citywide. The City will also seek to educate developers on incorporating Low Impact Development practices into development and redevelopment projects. Policy 6 in Section 5.6 of the LMRWD WMP states that the District will coordinate with other groups and units of government in developing education programs or implementing ongoing efforts. c. Section 5.4.3 of the Assessment discusses utilizing the following structural BMPs to reduce storm water volume or its effects: infiltration basins, constructed wetlands, underground infiltration and streambank stabilization. Infiltration basins, wetland treatment areas and infiltration trenches are listed as example BMPs in Table 5-8 of the LMRWD WMP to be potentially implemented into Runoff Management Plans as required in Section 5. 13. 1 of the WMP. The LMRWD WMP also lists the "development and maintenance of recharge areas" as a structural discharge elimination BMP (WMP Table 5-9) to be potentially implemented into Runoff Management Plans. Policy 1 in Section 5.3.2 of the LMRWD WMP states that the District will promote and encourage restoration of disturbed streambanks. Page 3 of 4 d. Section 5.4.4 of the Assessment describes how reforestation is a potential non- structural BMP that could be utilized to reduce stormwater volumes and states that the City will reevaluate its existing reforestation program and current preservation practices to reduce the amount of rainfall that runs off the landscape. Reforestation as a storm water BMP is not explicitly described in the LMRWD WMP. However, this type of measure is generally supported by goals and policies listed in the LMRWD WMP. e. Section 5.4.4 of the Nondegradation Assessment describes how wetland vegetation has the ability to transpire large amounts of water thereby reducing stormwater volume. The City will continue to look for additional opportunities to restore wetland areas and the associated upland. Wetland restoration is supported by Section 5.9 of the LMRWD WMP which states that one of the goals of the LMRWD is to preserve wetlands for water retention, recharge, soil conservation, wildlife habitat, aesthetics, and natural enhancement of water quality. Page 4 of 4