In the coming 18 months, the RCWD will revise the Rice Creek Watershed District Plan and offer local residents and water quality advocates an opportunity to make additional improvements to the district’s water quality protection. FMR has identifies two areas for improvement that the RCWD Board should consider as this plan revision process moves forward.

Rule E, Section 3(a-f)

Background

The RCWD states three policies regarding flood plain alteration in the DRAFT rules document.

1. “Preserve existing water storage capacity in the 100 year floodplain of all water bodies and wetlands in the watershed…”
2. “Enhance floodplain characteristics that promote the natural attenuation of high water, provide for water quality treatment and promote groundwater recharge.”
3. “Preserve and enhance the natural vegetation existing in floodplain areas for fish and wildlife habitat.”

This rule allows cities to build in FEMA designated floodplain areas. Some cities have already gone through a special delineation process that allows them to do limited construction in the flood plain. This delineation process involves drawing a line between the “flood way” and the “flood fringe” and allows development inside that flood fringe.

Our Position

Generally speaking, any development in the flood plain is not a good idea. There are public safety concerns as well as some obvious environmental consequences, including habitat loss and water quality degradation. The proposed rule would allow new developments in the flood fringe area if the city has delineated the flood fringe. We feel that this is not in the best interests of residents of the watershed, and it is unnecessary and unwise to encourage or allow flood plain development in this new RCWD Rules revision. Here’s why:

• Encroachment into the flood plain presents a potential public safety hazard and economic loss in the event of severe flooding.
• Increased floodplain development can further degrade water quality and stream habitat throughout the watershed. It certainly won’t help.
• Given the amount of undeveloped land still available within the Watershed, and the risks associated with floodplain development, it is neither necessary nor in the best interests of Watershed residents to allow or encourage development within floodplain areas.

Given the risks of any floodplain development, and the clearly stated policy objectives of the RCWD Board, we suggest a revision of Rule E, Section 3(a-f). We do not see a need for the Watershed District to allow encroachment into and the placement of fill within the 100-year floodplain. This proposed rule should be amended during the RCWD Plan revision process to restricting future development plans from incorporating flood fringe development.

Minimum stream buffers standards

Background

The new rules specify setbacks for ditches, but do not include any provision for stream buffers for the three core streams of the watershed: Rice Creek, Hardwood Creek and Clearwater Creek. These streams are vital natural resources and deserve stream buffer protections.

Our Position

A minimum buffer for these streams is essential to prevent lawn pesticides, sediments, human wastes and other contaminants from washing into the river and threatening human and stream health. We encourage the RCWD Board to explore the potential for adoption of comprehensive stream buffers along these three vital streams. Here’s why:

• Stream buffers provide considerable nutrient and sediment removal, keeping streams clean and healthy.
• Stream buffers prevent erosion and help stabilize stream banks.
• Buffers provide shade and woody debris to streams, which enhance aquatic habitat and help keep streams cool and safe for fish and other aquatic life.
• Stream buffers provide vital habitat for birds and animals, and critical flood control capacity in the event of severe flood events.

The RCWD Board should consider the inclusion of stream buffers rules in the current RCWD rules revision process.