6.2. SR 03-07-2005
Item # 6.2.
March 7, 2005
League of Minnesota Cities
145 University Ave. West
St. Paul, MN 55103
RE: Implications of the Upcoming Nondegradation Requirements for Municipal
Separate Storm Sewer System (MS4) Cities
To Whom It May Concern:
The City of Elk River is in full support of restoring and maintaining the chemical,
physical and biological integrity of waters of the State through management and
treatment of urban storm water runoff; however, the City feels it necessary to request an
extension for the nondegradation requirements for MS4 Cities. The City is scheduled to
submit their plan for nondegradation of all waters and, if appropriate, modify the City's
Storm Water Pollution Prevention Program by October 6, 2006.
This time frame puts a huge financial burden on the City since money has not been
budgeted to complete the requirements. Even if the City had money for these
requirements, the city would be unable to complete them in the allowed time frame. We
are actually unsure of how costly these requirements might be, since no criteria has been
set for calculating flow volume and pollutant loadings back to 1988 levels. The City
would like to see the Minnesota Pollution Control Agency (MPCA) establish some
criteria for calculating flow volume and pollutant loadings as well as establish guidelines
for communities to use to sustain the levels through future developments. The city is
pleading for an extension on this time frame so accurate and complete information can be
obtained to meet the requirements.
Sincerely,
Stephanie Klinzing
Mayor of the City of Elk River