A. Discuss Minnehaha Creek Watershed District Minor Plan AmendmentCITY OF
CgANHASSEN
7700 Market Boulevard
PO Box 147
Chanhassen, MN 55317
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MEMORANDUM
TO: Todd Gerhardt, City Manager
FROM: Terry Jeffery, Water Resources Coordinator +�
DATE: May 9, 2011 106
SUBJ: Discussion of Minnehaha Creek Watershed District Minor Plan
Amendment As It Pertains To Existing Local Controls and Surface
Water Management Plan
v
PROPOSED MOTION
This item is being presented for information purposes only. Staff will bring
necessary plan and code amendments for review(s) and public hearings if
needed. No action is needed or expected at this time.
BACKGROUND
Minnesota Rules Chapter 10313.231 requires that "A watershed management plan is
required for all minor watershed units wholly or partly within the metropolitan area."
Subdivision 3 of the same section states that "Where a watershed management
organization exists, the plan for the watershed must be prepared and adopted by the
organization."
Minnesota Rules Chapter 10313.235 states that "After a watershed plan is approved
and adopted, or amended, pursuant to section 10313.231 the local government units
having land use planning and regulatory responsibility for territory within the
watershed shall prepare or cause to be prepared a local water management plan,
capital improvement plan, and official controls as necessary to bring local water
management into conformance with the watershed plan within the time period
prescribed in the implementation program of the watershed plan and, as
necessary, shall prepare or cause to be prepared amendments to the local
comprehensive plan."
The following timeline describes the coincidence of the City's plan with the
District's plan:
• March 29, 2006: The City of Chanhassen submitted their Second
Generation Local Surface Water Management Plan (SWMP) for review to
all review agencies including the Minnehaha Creek Watershed District
(MCWD).
May 12, 2006: MCWD submits requests for additional information and
plan revisions.
Chanhassen is a Community for Life - Providing for Today and Planning for Tomorrow
Todd Gerhardt
Minnehaha Creek Watershed District Surface Water Management Plan
May 9, 2011
Page 2
• May 18, 2006: MCWD approves sixty -day extension request from City for review
process.
• July 12, 2006: Chanhassen submits requested information for approval.
• July 20, 2006: MCWD approves the SWMP with the following conditions:
• Execute a Memorandum of Understanding (MOU) with the MCWD; establishing
implementation responsibilities as between the two bodies.
• Incorporate prioritized list of capital improvements in the Chanhassen SWMP
within 120 days.
• Adoption of wetland ordinance the District determines to be at least as protective
as the MCWD Rule D within 6 months of execution of the MOU.
• July 5, 2007: MCWD approves their Comprehensive Water Resources Management
Plan.
• January 28, 2009: BWSR approves MCWD Comprehensive Water Resources
Management Plan Amendment.
• October 14, 2010: MCWD amended their 2007 Comprehensive Water Resources
Management Plan incorporating their new Erosion and Wetland rules.
• February 8, 2011: Met with Becky Houdek of MCWD to discus plan amendment and
rule changes.
• April 27, 2011: Met with Becky Houdek and Steve Christopher of MCWD to discuss
plan amendment and rule changes.
DISCUSSION
After a review of our existing plan, the Minnehaha Creek Plan and state rules staff has compiled a
list of amendments to the Chanhassen Second Generation Surface Water Management Plan (SWMP)
that will be required. This will be a "broad brush" overview with additional details coming in future
discussions.
The City of Chanhassen falls within the jurisdictional boundaries of four water management
organizations /watershed districts. All four of these agencies have been actively updating their local
water management plan over the last year and only recently has the last of these agencies adopted
their plan as shown in the following table.
District Date of Adoption
Minnehaha Creek Watershed District October 14, 2010
Carver County Water Management Organization October 26, 2010
Lower MN River Watershed District January 19, 2011
Riley Purgatory Bluff Creek Watershed District February 2, 2011
Table 1. Date of Plan Adoption for Local Water Plans
Minnesota Statute 10313.235 requires that Chanhassen submit their plan to these agencies for review
and comment and amend our plan to conform to the local water management plan. Most of the
amendments that will be proposed to the plan will be required for all local water management plans
regardless of the authoring agency. However, MCWD has incorporated rules into their plan. Carver
County Water Management Organization (WENR) is currently going through the rule making
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Todd Gerhardt
Minnehaha Creek Watershed District Surface Water Management Plan
May 9, 2011
Page 3
process. While they have similar goals as the MCWD rules, it appears that they will be less
restrictive. As a result, local controls that comply with MCWD rules will almost invariably be
adequate to meet any WENR rules eventually adopted.
Plan amendments can be grouped into 3 categories; general standards for local water management
plans per MN Statutes 10313.235, requirements based upon Appendix C of the 2007 MCWD Local
Water Management Plan, and local control changes based specifically upon MCWD rule revisions in
the 2010 Local Water Management Plan but required under 10313.235.
General Standards
The general standards include those items that all agencies with local water management authority
will require of Chanhassen. Many of these have already been incorporated and will simply need to
be updated. Still others already exist in some other document or as a standalone document but need
to be incorporated into the SWMP. Specifically, the City will need to:
1. Identify areas with known flooding issues as well as areas where our model predicts that
public roads, private roads and private drives might overtop during infrequent rain events or
where minimal freeboard exists.
2. Identify landlocked watersheds.
3. Include stormsewer infrastructure map. This map was not complete when the SWMP was
adopted but has since been completed although it is still being updated.
4. Define water quality and water quantity protection methods adequate to meet standards
established in the District's plan. This will be discussed further under Appendix C
requirements.
5. Inclusion of National Pollution Discharge Elimination System (NPDES) requirements for
Municipal Separate Storm Sewer System (MS4) cities including:
6. Identify areas of high erosion potential.
7. Metropolitan Land Planning Act (MLPA) Requirements.
MCWD Appendix C Requirements
Appendix C of the MCWD Local Water Management Plan is specific to waters within the district
boundary. It identifies current loading and sets loading reduction goals. It also identifies other
potential issues in surface waters and asks for specific management practices to address these issues.
Chanhassen plan must include phosphorus load reductions to three surface water bodies. These
waters and the reduction are included in Table 2 below.
Receiving Water Annual Phosphorus Reduction
Christmas Lake 7 lbs.
Lake Minnewashta 27 lbs.
South Lower Lake 3 lbs.
Table 2. Annual Phosphorus Load Reduction Allocation
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Todd Gerhardt
Minnehaha Creek Watershed District Surface Water Management Plan
May 9, 2011
Page 4
The current SWMP and Capital Improvement Plan address Christmas Lake and Lake Minnewashta.
However, when City staff and MCWD met during the authoring of the Chanhassen 2 nd Generation
SWMP, South Lower Lake was not a subwatershed that was being considered. This has since
changed and will need to be addressed in our plan amendment.
Other issues identified in Appendix C include the monitoring the areas shown in Table 3.
Monitoring Area Objective of Monitoring Efforts
Lake Minnewashta Outlet Conveyance capacity and erosion
Channel draining into Christmas Lake Scour, erosion and sediment deposition into Lake
Lake St. Joe Establish baseline water quality and vegetation data;
citizen involvement for education and outreach
Table 3. Appendix C Monitoring Sites
Under general standards a local water management plan must identify areas of high erosion
potential. Chanhassen will need to review existing stormwater modeling data and determine where
such areas exist and address these areas in our plan amendment.
Code Amendments
The City of Chanhassen is currently the local government authority with regulatory responsibility
over wetlands, erosion control and stormwater management. Minnesota Statutes 103B.235 states
that our plan must be amended to comply with the district plan(s). In this case that includes local
controls as well. The City of Chanhassen does have the choice of allowing the District to enforce
their rules within that portion of Chanhassen which lies within the District boundary. Staff feels that
it is in the best interest of Chanhassen to maintain this authority rather than granting permitting
authority of the District. Further, this is important to maintain continuity throughout the City of
Chanhassen rather than having different rules in different parts of the City. To this end, staff will
begin preparing code amendments to our existing wetland ordinance and erosion control ordinance
for review and public hearing. Stormwater ordinance amendments will be needed within 180 days
of the District's adopting their stormwater rule but will not be addressed at this time.
Erosion Control Rule
Changes to MCWD rules is not the sole impetus for amending our erosion control code. The 1972
Federal Clean Water Act (CWA) has led to the creation of the National Pollution Discharge
Elimination System (NPDES). There are three permits under the NPDES, two of which apply
directly to the City: the Municipal Separate Storm Sewer System (MS4) permit and.the General
Construction Permit. Both of these permits have very specific requirements for sediment and
erosion control best management practices; during construction and after final stabilization.
A review of the new rule indicates that the changes to content within city code will be relatively
minor. The changes will include what will trigger the need for preparing an erosion control plan and
what items are required on that plan in order to ensure consistency between all agencies. Current
city code is any land disturbing activity whereas the MCWD is 5,000 square feet of disturbance or
50 cubic yards of material.
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Todd Gerhardt
Minnehaha Creek Watershed District Surface Water Management Plan
May 9, 2011
Page 5
This amendment will also provide an opportunity to create a cleaner code regarding erosion and
sediment control by consolidating our controls and regulations. Currently erosion and sediment
control standards and practices can be found within Sections 7 -22, 7 -33, 18 -62, 19 -144 & 145, 20-
518 and 20 -1183 of the City Code.
Wetland Protection Rule
Chanhassen has had a wetland protection rule since before the 1991 MN Wetland Conservation Act.
This rule has gone through several iterations over the past two decades; most recently when we
adopted our Second Generation Surface Water Management Plan in August of 2006. The District
maintains LGU status other places within the District.
The new MCWD rule means three primary changes; what triggers buffers, required buffer widths,
and excavation within type 1 and 2 wetlands.
The following table illustrates the buffer requirements of each entity.
Currently, staff is evaluating ways to meet the District buffer requirements while not increasing the
encumbrance on privately owned land. It is important to note that these buffers would not apply to
single family residences that make improvements to an existing structure.
Under Minnesota Rules Chapter 8420 excavation within a Type 1 or 2- wetland is exempt from
WCA rules unless the excavation results in the conversion of the basin to non - wetland. Under
Chanhassen City Code, we exempt all activities exempted under Minnesota Rule. The new MCWD
rule requires mitigation for excavation within Type 1 or 2 wetlands.
Stormwater Management Rule
As with erosion control, the 1972 Clean Water Act (CWA) is the driver behind most water quality
rules. The CWA trickles down to local controls through the two National Pollution Discharge
Elimination System (NPDES) permits mentioned earlier. As part of Chanhassen's Municipal
Separate Storm Sewer System (MS4) permit, we were selected with 29 other cities to complete a
pollutant loading assessment and Nondegradation Plan. These nondegradation cities were required
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MCWD WETLAND
CHANHASSEN CITY CODE CH. 20; SEC. 20 -411
PROTECTION RULE: 6.
BUFFER WIDTH
*COMBINED PRINCIPAL
*MIN
*PRINCIPAL
*ACCESSORY
*PERMANENT
STRUCTURE SETBACK
% OF BUFFER
*BASE
APPLIED
WETLAND
STRUCTURE
STRUCTURE
BUFFER STRIP
& BUFFER WIDTH
REO. FOR
BUFFER
BUFFER
CLASSIFICATION
SETBACK
SETBACK
(MIN WIDTH)
FROM DELINEATED
NATIVE VEG.
WIDTH
WIDTH
BNDRY
OUTSTANDING
50
50
50
100
100
NIA
N/A
PRESERVE
40
20
40
80
100
75
67
MANAGE 1
30
15
25
55
100
40
34
MANAGE 2
30
15
20
50
OVER 50
30
24
MANAGE 3
30
15
16.5
46.5
OVER 50
20
16
Currently, staff is evaluating ways to meet the District buffer requirements while not increasing the
encumbrance on privately owned land. It is important to note that these buffers would not apply to
single family residences that make improvements to an existing structure.
Under Minnesota Rules Chapter 8420 excavation within a Type 1 or 2- wetland is exempt from
WCA rules unless the excavation results in the conversion of the basin to non - wetland. Under
Chanhassen City Code, we exempt all activities exempted under Minnesota Rule. The new MCWD
rule requires mitigation for excavation within Type 1 or 2 wetlands.
Stormwater Management Rule
As with erosion control, the 1972 Clean Water Act (CWA) is the driver behind most water quality
rules. The CWA trickles down to local controls through the two National Pollution Discharge
Elimination System (NPDES) permits mentioned earlier. As part of Chanhassen's Municipal
Separate Storm Sewer System (MS4) permit, we were selected with 29 other cities to complete a
pollutant loading assessment and Nondegradation Plan. These nondegradation cities were required
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Todd Gerhardt
Minnehaha Creek Watershed District Surface Water Management Plan
May 9, 2011
Page 6
to model pollutant loading for three parameters for 1988, 2010, and 2030. If they exceeded the 1988
level for any of the three parameters, they must amend their MS4 permit to include Best
Management Practices (BMPs) aimed at returning to the 1988 loading levels. As with each of the 30
cities, Chanhassen exceeded total volume of runoff in every watershed.
In addition to the soon -to -be adopted MCWD stormwater rule, the new NPDES MS4 permit is
scheduled to be issued in January of 2012. It is anticipated that the nondegradation cities will need
to amend their MS4 permits at this time to address loading. We will need to evaluate methods to
minimize the amount of stormwater running off the land into our lakes and streams. This can be
done through infiltration — percolating water through the soils into shallow, or deep, aquifers — or
abstraction — capturing water at the source.
MCWD's new rule is intended to address pollutant loading with an emphasis on capturing water on
site rather than sending it downstream. Currently they are looking for the abstraction and/or
infiltration of the first inch of rainfall unless it can be shown that is not possible, but in no case shall
it be less than the first one -half inch. This is consistent with the NPDES General Construction
permit requirements.
We are seeing deficiencies within our own infrastructure that would be well served to reduce the
amount of runoff from the landscape. So in addition to water quality benefits there will be a definite
benefit to our existing and future infrastructure.
Also involved with this rule are requirements for phosphorous reduction and reduced sediment
loading. Except in very rare cases, these requirements will only apply to new impervious surfaces
greater than 10,000 square feet.
This rule will have the final public hearing on May 5 and will likely be adopted the last regular
MCWD Board Meeting in May. By state law we will have one year to update our local controls to
be compliant with theirs. We will begin a more detailed review of our local controls but staff feels
that and amendments to our local controls be forestalled until we have a better understanding of what
the new MS4 requirements will be.
RECOMMENDATION
Staff intends to bring the proposed plan amendments before the planning commission for review and
public hearing and then to Council for further review and discussion. In order to meet the timeline
set forth by MN State Statute, this will need to be completed by September 1 of this year. If there is
specific information that Council wishes . to see, please let staff know so that we can be certain that
information is made available to you.
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