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32 <br /> <br />Moving Forward <br />It is clear that a different approach must be taken to meet the original goals of the Task Force. The <br />group was restricted in their deliberations by adhering to features of a project proposal that is in <br />violation of federal and state laws. If federal floodplain guidelines, and Minnesota statues are to be <br />enforced, a successful design must be made on the following basis: <br />1. Only the most reasonable contiguous developed area must be protected. Fargo, <br />and to some extent, Moorhead, are built in a flood plain. While there was good reason <br />for their location 150 years ago, those reasons do not apply to future growth. Moorhead <br />has virtually unlimited area to grow outside the 100, and 500 hundred year flood plains. <br />Transportation arteries and existing infrastructure and development can be protected <br />within state and federal floodplain laws. The natural floodplain and river channels <br />weren’t determined by state or federal law. It is a waste of the region’s economic <br />resources to design a project with provincial protection instead of regional flood <br />protection. <br />2. A diversion alignment must remove as little natural floodplain as possible. The <br />identified alignment that has the least floodplain impact is the original plan proposed by <br />the Army Corps on the Minnesota side of the river. If that is not adopted, then any <br />North Dakota route must follow the edges of the contiguous developed area as closely <br />possible to avoid draining the natural floodplain. Rural structure counts used to justify <br />large scale destruction of the flood plain are misleading and easily manipulated. Rural <br />flood plain destruction requires a one to one trade with areas upstream and downstream <br />that do not currently flood. The size of the rural 100 year floodplain transfer has huge <br />impacts on communities, school districts, and townships, with no inexpensive <br />compensation plan identified. <br />3. Distributed storage should be utilized for protection above the 100 year flood <br />level. The cost of DSA construction can be shared regionally and nationally. A smaller, <br />and less costly diversion can be constructed if it is sized for a 100 year flood. <br />4. State and local officials should consider a plan that is locally sponsored and <br />constructed. It is clear that the length and complexity of any diversion is going to make <br />the project costly. The Army Corps has constructed two simple diversions of less than <br />five miles in length in the region in the last ten years. Both doubled in cost. Fargo <br />engineers reported to the Task Force that their levee system will double in cost. The <br />Oxbow ring dike and country club enhancement project doubled in cost. There is no <br />reason to expect this project would be any different. The size of the proposed diversion <br />will make an Army Corps directed project financially unsustainable. <br />Thank you for the opportunity to serve on the Task Force. <br /> <br />