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27 <br /> <br />conditions. <br /> <br />3. Minnesota Project Sets Ceiling on Permissible Impacts. The North Dakota alignment has <br />significantly greater downstream Impacts than Minnesota alignment of the same capacity and <br />results in nearly twice the stage increase. This doubling of impact results because the LPP <br />eliminates floodplain storage south and northwest of Fargo. Engineer Anderson put it this way: <br /> <br />“The North Dakota diversion flows through a low floodplain area thus draining <br />floodplain and also isolating existing floodplain areas, by levees along its alignment, <br />resulting in excessive loss of floodplain storage. The MN Diversion flows through <br />higher ground generally not within the floodplain thereby having minimal effect on <br />floodplain storage along the alignment.” <br /> <br />To avoid these impacts, the project must abandon its attempt to flood protect the undeveloped <br />floodplain, whether the diversion flows through Minnesota or North Dakota. <br /> <br />4. Minnesota Alternative Meets National Objectives. The USACE selected the Minnesota <br />diversion as the least impact project which best meets national objectives. The LPP costs $1 <br />billion more than the least impact project, eliminates 50 square miles of floodplain storage more <br />than the Minnesota diversion, and consequently develops more downstream impacts. The <br />billion dollars saved could then be used for distributed storage or other needed improvements. <br /> <br />5. Change the operative underlying principles—maximize floodplain retention. If a North <br />Dakota alternative is deemed desirable, the Technical Panel should have been asked-- to design a <br />North Dakota project that maximizes floodplain retention. None of the options studied by the <br />Technical panels were based on that concept. Rather, the task force was continually pressured <br />to foster as much flood plain development as possible. As a result, the task force never <br />considered, options that fully minimize floodplain loss. The Technical Panel inappropriately <br />eliminated options which preserved the floodplain northwest of Fargo. Developing that <br />floodplain is bad for Fargo’s sound development: In separate articles, Governor Burgum is <br />quoted in the Fargo Forum as follows: “ <br /> <br />The reverse of smart growth, in Burgum's view, is sparse development on the city's <br />edge, where it costs the city more to deliver services than developed property contributes <br />in property tax revenues…. <br /> <br />Our city has an ability to grow and grow smarter than other cities by growing more <br />densely as opposed to growing horizontally," he told the Planning Commission. "The <br />52 square miles is enough to hold us for a long time." <br /> <br />Over half of the flood storage eliminated in the LPP is found on the Northwest floodplain. <br />Instead of eliminating that storage, it should be enhanced. <br /> <br />6. Federal and State Law Prohibits Avoidable Floodplain Development. The current project