071408 CC WS AgPCITY OF SHOREWOOD
CITY COUNCIL WORK SESSION
MONDAY, JULY 14, 2008
AGENDA
1. CONVENE CITY COUNCIL WORK SESSION
A. Roll Call
5755 COUNTRY CLUB ROAD
COUNCIL CHAMBERS
6:30 P.M.
Mayor Lizee
Woodruff
Turgeon
Bailey
Wellens
B. Review Agenda
2. STORMWATER MANAGEMENT PLAN (Att. -Engineer's memorandum)
3. ADJOURN
Infrastructure ^ Engineering ^ Planning ^ Construction 701 Xenia Avenue South
Suite #300
rti r..~=~,trec. ~„~,. Minneapolis, MN 55416
Tel: 763 541-4800
Fax: 763 541-1700
July 14, 2008
The Honorable Mayor and City Council
City of Shorewood
5755 Country Club Road
Shorewood, MN 55331
Re: Comprehensive Surface Water Management Plan
City of Shorewood
WSB Project No. 1459-23
Dear Honorable Mayor and City Council:
As you are aware, we recently submitted the City's Comprehensive Surface Water Management
Plan to the Metropolitan Council, Minnehaha Creek Watershed District (MCWD), and Riley-
Purgatory-Bluff Creek Watershed District (RPBCWD). Attached you will find comment letters that
were received within the 60-day deadline period, which ended on June 1, 2008.
We have drafted a response letter and are presenting it to you for your information. The responses
follow the format of the comment letters received. Please note that, in the interest of brevity, items
that have been marked complete are not included in this response letter. Further, items that may
require further discussion are highlighted with an asterisk (*). The proposed changes to the Surface
Water Management Plan are also enclosed. Changes to the text are identified as strike-through
edits. In the next week, I will be meeting with MCWD staff to discuss these changes before
submitting the plan for final approval.
Should you have any questions, please feel free to contact me at 763-287-7164.
Sincerely,
WSB 8c Associates, Inc.
Steven G. Gurney, PE
Project Manager
Enclosures
cc: James Landini, PE, City of Shorewood
Larry Brown, PE, City of Shorewood
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infrastructure ^ Engineering ^ Planning ^ Construction 701 Xenia Avenue South
.~~ Suite #300
-~>:~,~;<~,. ~,, 1~::. IVlinneapolis, MN 55416
Tel: 763 541-4800
Fax: 763 541-1700
July 18, 2008
Mr. L. Eric Evenson Mr. William G. Moore
Administrator General Manager
Minnehaha Creek Watershed District Metropolitan Council
18202 Minnetonka Blvd. 390 Robert Street N.
Deephaven, MN 55391 St. Paul, MN 55101
Re: Comprehensive Surface Water Management Plan
City of Shorewood, MN
WSB Project No. 1459-23
Dear Mr. Evenson and Mr. Moore:
This letter will serve as a response to the comments received during the 60-day comment period for
the City of Shorewood's Comprehensive Surface Water Management Plan. Comments were
received from the Metropolitan Council and Minnehaha Creek Watershed District (MCWD) before
the June 1, 2008, deadline. Provided below are the responses to those comments received. The
revised Comprehensive Surface Water Management Plan is also enclosed for review.
In conformance with the Metropolitan Surface Water Management Act and Minnesota Rules
Chapter 8410, we are pleased to submit to you the City of Shorewood's Comprehensive Surface
Water Management Plan. Please review the attached plan and provide us with your comments
and/or approval. The 60-day comment deadline will end on September 16, 2008.
RESPONSE TO MCWD LETTER
A comment letter was received from MCWD dated May 30, 2008. This letter indicates that many
items within the City's plan are complete. This response will address only the items listed as
incomplete.
Subp. 2 -Incomplete. The City recently completed such an agreement with MCWD; at a
minimum, this agreement should be included in Appendix A.
Response: A copy of the recently completed agreement with MCWD regarding the Local
Government Unit (LGU) authority for the City of Shorewood is included in Appendix A.
Reference to this has also been made throughout the text of the document.
Kr01459-23!Admin!Docs'LTR-evenson-moor•e-070808. doc
Mr. L. Eric Evenson
Mr. William G, Moore
July 18, 2008
Page 2
Subp. 4 -Incomplete, 8410.0060 requires each of the following:
• Public Waters and Ditch map -Figure III-6 must include any dams, ditches, and control
structures (or a statement that none exist).
Response: A statement stating that no public ditches, dams, and control structures
exist within the City of Shorewood has been added to Figure III-6.
Major Hydrologic Characteristics -Incomplete. The 100-year HWL (931.5) for Lake
Minnetonka should be explicitly referenced in the plan. Information from the DNR may be
found at httb://www.dnr.state.mn.us/lalcefind/index.html.
Response: A note for the 100-year high water level for Lake Minnetonka has been
added to Figure III-6. Additionally, a note that the elevation of 931.5 is inconsistent
with the published FEMA map elevation of 931 has been added to Appendix C.
100-Year Flood Levels and Peak Discharges of Stormwater Ponds/Channels -
Ineomplete. Appendix B must include a discussion of the consistency of the stormwater
management plan with FEMA.
Response: Discussion of the 100-year flood levels and peak discharges has been
added to Appendix B. With the exception of Lake Minnetonka, there are no detailed
study areas within the City of Shorewood.
Flood Insurance Map -Incomplete. In the interest of utilizing the LWMP as an index of
water information, the link to the FEMA website should be directly to Shorewood
information, or the relevant information should be reproduced in Appendix C.
Response: Additional instructions have been added to the narrative in Appendix C
because the direct link to the FEMA website showing Shorewood information is
impractical. The cumbersome link is:
htt~//nlsc.fema,.gov/webatap/wes/stores/servlet/GategoryDisplay?storeId=100
01&catalo~Id=10001&lan Ig d=-
1 &cate~or~ Id=.12001 &parent cate~Y rn=12001 &tYpe=CAT MAPPANEL
&stateId=1303 0&countyId=143 57&communityId=346625&stateName=MIN
NES OTA&countyName=HENNEPIN+COLTNTY&communityName=SHOR
EWOOD%2CCTY%2FHENNEPIN+CO&dfirm kit id=&dfirmCatId=1200
9&isCountySelected=&isCommSeleeted=&userTYpe=G&urlUserType=G&s
fc=0&eat state=13030&cat county=14357&cat community=346625
Water Quality Data -Incomplete. In addition to Mercury, Lake Virginia is impaired for
nutrients -the Plan should reflect this. The relevant materials in the Water Resource
Library should be available via the plan -either with a direct link to an online resource, or
included in an appendix.
Response: The discussion of impairments in Section IV, Part A, has been expanded
to include nutrients for Lake Virginia. A link regarding TMDL resources has also
been provided.
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Mr. L. Eric Evenson
Mr. William G. Moore
July 18, 2008
Page 3
Ground Water Appropriations/Data -Incomplete. If no groundwater is appropriated for
needs in the City, a statement to that effect would be sufficient.
Response: Figure III-9 shows the known groundwater appropriations within the
City.
Reference to MUSA -Incomplete. The plan must include a map showing where the
MUSA falls within City jurisdiction, or include a statement that the City is entirely within/
without the MUSA.
Response: A statement indicating that the City is entirely within the MUSA
boundary has been added to Figures III-11 and III-12.
Recreation -Incomplete. The plan must include a map of all public recreation areas and
public access to water resources.
Response: This section is complete based on Chapter 8410.0060, subp. 8, which
indicates that a map OR a discussion of these features can be provided.
• Fish and Wildlife Habitat -Incomplete. The Plan must include a map of MLCCS data
(where available) and outline any biological studies or State Management Plans performed
fully or partially within the City.
Response: The information from the MLCCS has been included as Figure III-15.
• Unique Features -Incomplete. A map of the unique areas listed in Section III, Part N is
required.
Response: Chapter 8410.0060, subp. 10, requires a map or a description or a listing
of unique features and scenic areas. The listing given in Section III, Part N, meets
this requirement.
Subp. 5 -Incomplete. The references to Appendices and tables in the implementation section
greatly increase the coherence of the Plan as a whole. Item 3 under Wetlands incorrectly states the
City, instead of MCWD, is the LGU in RPBCWD area in the City. Item 19 under Internal
Operations indicates the SO ib loading reduction will be met by water quality regulations,
contradicting Appendix I.
Response: Item 3 has been changed to reference the MCWD as the LGU. The Joint
Powers Agreement has been included in Appendix A. Item 19 has been deleted from the
Plan.
Subp. 6 -Incomplete: Overall Section IV and Appendix G are very thorough. The Phosphorus
reduction and Key Conservation Area sections need further development; see MCWD
Comprehensive Plan requirements section.
Response: These items will be addressed under MCWD Comprehensive Plan Requirements
section.
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Mr. L. Eric Evenson
Mr. William G. Moore
July 18, 2008
Page 4
Subp. 7 -Incomplete: The proposed corrective action for Item H must include more specifics.
Response: Additional text has been added to Section IV, Part H, indicating that the City
will review redevelopment areas (if and when they are proposed), for compliance with the
City's stormwater management goals and policies.
XSubp. 8 -Incomplete:
• Discussion of Funding Ability -Incomplete. 8410 requires a discussion of the following
funding issues. If they do not apply to the City, the Plan must explain why that is the case.
o Levy Limit Constraints -Incomplete
o Effect on Other City Funding Needs -Incomplete
o Establishment of Watershed Management Taxing Districts -Incomplete
o Creation of Stormwater Utility -Incomplete
o Monetary Impact on Households -Incomplete
Response: This discussion was previously presented in Section VII, but has been
expanded to include discussion of project to be funded by potential grant money.
The City intends to maintain its existing storm sewer system by using funds collected
under the existing Storm Water Utility Fee. For this reason, there are no anticipated
impacts on the City's General Fund. Levy limits are not anticipated to impact this
fund either. Monetary impacts on households will be limited to the same level it is
currently impacting households.
• Impact under Ad Valorem Financing -Incomplete
Response: The City does not intend to use Ad Valorem Financing to fund storm
sewer related CIP projects.
• Grant Funding -Incomplete
Response: Based on guidance given under Subp. 9 of the MCWD response letter,
the City has identified projects in Tables VI-1, VI-2, and VI-3 for which MCWD
funding is desired. Other sources of grant money are identified in these tables, as
well.
Subp. 11-Incomplete: In Section VIII, the text must be amended to indicate that amendments
will be required within two years of the adoption of a watershed plan by a Watershed District or
Watershed Management Organization, consistent with 8410.0160.
Response: Specific text referencing Chapter 8410.0160 has been added to the discussion on
amendment procedures reiterated here as well.
Requirement 1-Incomplete. See above.
Response: These items have been addressed above, primarily in Subp. 4.
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Mr. L. Bric Evenson
Mr. William G. Moore
July 18, 2008
Page 5
Requirement 3 -Incomplete: Either the included stormwater system map (Figure III-4) must
show all connected devices, such as ponds, grit chambers, and wetlands used for stormwater storage
as well as outlets; or a separate map should be included.
Response: Figure III-16 shows known storm sewer data for the City of Shorewood
available at this time. The City is in the process of updating this map. An updated map will
be included in future editions of the Stormwater Management Plan.
Requirement 4 -Pending: Following submittal of the stormwater infrastructure map, engineering
review will determine the adequacy of stormwater storage.
Response: It is our understanding that a determination of adequacy of stormwater storage
has already been included in the HHPLS that was previously performed. Based on the
District's Local Plan Requirements Sheet for the City of Shorewood, no specific flooding
areas were identified.
XRequirement 9 -Incomplete:
• Lake Minnetonka - Carsons, East Upper, South Lower, Spring, St. Albans, Tonka, West
Upper: Load allocation to Shorewood = SO ib reduction annually.
The street sweeping calculations are well considered and could be sufficient for reducing
loading goals; the estimated 701b reduction is greater than the required 50 lb reduction. The
development projects met, but did not exceed, regulatory requirements, and so do not
qualify for load reductions. MCWD recognizes the contribution of the City to the Gideon's
Glen project; approximately half of the estimated total load reduction may be used to meet
the allocated load reduction. MCWD encourages the City other such joint projects in the
future to meet City and MCWD water quality goals.
After specifying the percentage of City streets to be swept and approximate areas in which
the sweeping will occur, the phosphorus removal proposal will undergo engineer review.
The phosphorus removal study indicated that 22.9 miles of road would be swept. The City
proposes to evaluate the effectiveness of a fall street sweeping and adjust the sweeping
accordingly. Areas to be swept first will include those that are directly tributary to key
conservation areas, lakes, and wetlands.
Response: The storm water treatment pond constructed on the South Lake Office Building
property exceeds the required treatment needed for this site (less than 3 acres). Based on
this, we feel this pond should be credited toward the City's reduction goal.
Requirement 11-Incomplete: In addition to Figure III-14, the Plan must include a discussion of
the adequacy of regulation to protect MCWD-identified Key Conservation Areas.
Response: A discussion of MCWD-identified Key Conservation Areas has been added as
Section III, Part Q.
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Mr. L. Eric Evenson
Mr. William G. Moore
July 18, 2008
Page 6
Requirement 12 -Incomplete: The City must specify which wetland classification it proposes to
use.
Response: Policy 10 under Section V, Part C. Regulation -Wetlands has been added to
indicate the City adopts the MCWD MCRAM assessment and the most recent BWSR
methodology.
Requirement 14 -Incomplete: Appendix H includes the relevant ordinances. The MCWD plan
requires a discussion of: 1) the process by which an applicant obtains a permit for wetland/land
alteration, 2) the monitoring process, and 3) the adequacy of such controls, as well as the
amendment process for the ordinances in question.
Response: The City's wetland ordinance, Chapter 1102, is included in Appendix H.
Because MCWD is the LGU for the entire City, Policy 3 under Section V, Part C,
Regulation-Wetlands has been modified to reference district procedures.
Extension 1-Incomplete: The Pian must include a discussion in the narrative section. A map of
sensitive groundwater areas would strengthen this section. The Plan includes a CIP entry to create a
Wellhead Protection Plan to which all groundwater goals refer; the goals/policies regarding
groundwater should have separate CIP entries.
Response: Sensitive groundwater areas will be identified as part of the Wellhead Protection
Plan. Since all these goals and policies are related to that Plan, the City prefers to leave this
item as a single line item in Table VI-3.
Extension 2 -Incomplete: Section V would be a good fit for this discussion.
Response: Discussion on the water quality protections in open spaces and parklands has
been added to Section V, Part D -Internal Operations. See Item 21.
Extension 3 -Incomplete: Section V would be a good fit for this discussion.
Response: The dedication of easements over new stormwater management ponds is already
required under the regulation strategy of Section V, Part C -Regulation-Water Quality
Treatment. Please see Item 2.
*Extension 4 -Incomplete: The Infiltration/Volume Control section includes an entry on LID
techniques. A discussion of integrating such techniques into local land use regulations is required.
Response: Due to the nature of the soils in Shorewood, LID techniques may not be
appropriate in all locations. Rather than mandating any LID techniques, the City prefers to
work with developers to encourage them to use such techniques wherever possible. Specific
LID techniques will be incorporated into the site plans at the discretion of the developer's
engineer.
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NIr. L. Eric Evenson
Mr. William G. Moore
July 18, 2008
Page 7
Extension 5 -Incomplete: Section V would be a good fit for this discussion.
Response: Policy 22 has been added to Section V, Part D -Internal Operations.
XExtension 6 -Incomplete: The Plan currently specifies that stormwater ponds must be covered
by easements to allow City access. MCWD encourages the City to require such facilities to be
constructed on outlots, to discourage property owner encroachment and ensure proper maintenance.
This language must be extended to include all stormwater facilities and wetlands.
Response: By requiring future stormwater ponds to be constructed within City-owned
outlots, the City would be placing an undue burden on developers, possibly reducing the
number of buildable lots within a subdivision. It will also remove property from the current
tax base. At this time, the City is unwilling to place further restrictions on private property
or forfeit tax revenue.
Extension 7 -Incomplete: If such language exists it should be included in Appendix H. If not, the
plan should state intent to adopt such language.
Response: Policy 7 has been added to Section V, Part CRegulation-Flood Control, stating
that the subdivision ordinance will require property owners to provide the MCWD with
copies of proposed preliminary plats.
Requirement 1-Incomplete: The Plan mentions street sweeping as a potential BMP. A narrative
or table of current practices is required. A separate "Housekeeping" section would be beneficial.
Response: The City's current BMPs are listed in Section V primarily in Part D Internal
Operations. Specifically, Item 1 lists the current level of street sweeping undertaken by the
City. Other BMPs are listed throughout the section, as well as the City's Surface Water
Pollution Prevention Pian (SWPPP).
Requirement 3 -Incomplete: A discussion of potential barriers to the proposed changes in
Section V is required.
Response: Section VII, Financial Considerations, indicates that the amount of stormwater
related work within the City exceeded the revenue currently generated by the stormwater
utility. This would be the greatest barrier to implementing any of this work. The City
intends to pursue other avenues (i.e., grant funding) to close the funding gap. The potential
sources of grants have been added into the tables in Section VI and also noted in Section
VII.
Requirement 4 -Incomplete: No changes to housekeeping practices are required; all proposed
changes must include the information indicated in this section.
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Mr. L. Eric Evenson
NIr. William G. Moore
July 18, 2008
Page 8
Response: It is unclear what direction the MCWD wishes us to proceed for this item. It is
indicated that this item is complete; however, it also states that no changes to housekeeping
practices are required. Please provide additional clarification on this item.
Requirement 5 -Incomplete: Housekeeping changes that are not intended to meet MCWD TP
reduction goals do not require the same level of detail included in the street sweeping calculations;
however, some quantification is required.
Response: It is unclear how the proposed housekeeping changes will result in a quantitative
improvement to water quality; however, we feel the City has developed a strong Surface
Water Management Plan that balances all the needs of the City while protecting water
quality.
METROPOLITAN COUNCIL COMMENTS
As part of the City's implementation plan, it has programmed the completion of its wetland function
and value assessment for 2011. The City should utilize MnRAM3.0 or the latest approved version
in its wetland assessment.
Response: So noted.
This concludes our response to comments. Should you have any questions regarding these items,
please feel free to contact me at 763-287-7164.
Sincerely,
WSB & Associates, Inc.
~~---a-
Steven G. Gurney, PE
Project Manager
cc: James Landini, PE, City of Shorewood
Larry Brown, PE, City of Shorewood
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