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Rural Collaborative Water Management Plan Fails to Comply with BWSR Requirements 
Each plan must contain a summary assessment of existing or potential water resource related problems, including those identified in organization plans that affect the community. The problem assessment must be completed for only those areas within the corporate limits of the community and meet the same content requirements as those outlined for organization plans under part 8410.0080, subparts 1 and 2.
Instead of focusing on local problems, the Rural Collaborative Plan incorporates whole sections of the Joint Powers Organization's Plan, which covers the entire watershed.  In Section 1.0.3 of the Rural Plan, the author admits:
The Rural Collaborative Plan incorporates many of the VRWJPO Plan components. Section 1 Existing and Future Environment, Section 2 Water Resources, Section 3 Issues Identification, and Section 4 Goals, Policies, Objectives, and Actions (as amended in February 2008) are incorporated in their entirety.
Instead of focusing on any actual problems existing within a community adopting this Rural Plan, the Plan assumes that each of the different rural communities has the same problems as every other rural community, and that they all have the same water related problems that exist in Burnsville, Hastings, Elko/New Market, Apple Valley, Lakeville, Rosemount and Farmington. 

By making this obviously incorrect assumption, the Plan cannot achieve the objective of formulating a plan to improve water quality, simply because it is starting with an incorrect assumption.  Instead of arriving at a logical conclusion of what steps might be taken to address any real problems that these rural communities might face, the Plan instead employs a one size fits all approach and mandates certain requirements that may or may not have any impact on water issues in any given rural community.

If you don't accurately state the problem, you  have no hope of coming up with an effective solution.

The Prescribed Actions are not Limited to What Can be Implemented at a Local Level.  Subpart 7 of BWSR Regulation Sec. 8410.0170 requires that actions outlined in a local water managment plan be limited to those that can be implemented at a local level.  As quoted above, the author of the Rural Plan admits that the goals, policies, objectives and actions of the JPO watershed-wide plan are "incorporated in their entirety" into the Rural Collaborative Plan.

This results in nonsensical language in the Rural Plan stating that the rural communities will perform actions they have neither the authority nor the ability to accomplish.  For example, some of the actions set out in the Rural Plan:
"Develop Watershed standards as a minor amendment to this Plan."
"Compile design and guidance documents for stormwater management within the Watershed"
"Collaborate with other agencies to develop and implement a groundwater monitoring system throughout the Watershed to monitor changes in groundwater levels and contaminants"
The Rural Plan does contain several matrices that attempt, in an extremely confusing way, to identify which goals, objectives and actions do or do not require direct action or cooperation from the "LGU" (local government unit).  There is nothing in the Plan that actually explains what these matrices are for, and the only reason I know about it is that I attended a meeting where this mystery was revealed.  Even after having been enlightened about this, it's still very difficult to understand what applies to any given rural community and how it applies.

The bwsr requirement that the actions outlined in the local water management plan be limited to those that can be implemented at a local level would help to make the plan understandable and effective.  The complete failure to meet this requirement creates a lack of clarity that is bound to limit the plan's effectiveness.  If people can't understand what it means, how can it be effective?

The Plan Completely Fails to Address Financial Considerations.  Subpart 8 of BWSR's Reg. Sec. 8410.0170 contains very detailed requirements addressing financial considerations:

Each local plan must contain an analysis of the financial impact of implementation of the proposed regulatory controls and programs identified under subpart 7. The analysis must include, at a minimum, the following items:
A.  the estimated cost of adoption and enforcement of local controls and standards for the local municipality;

B.  the estimated annual cost of implementation of other specified programs to each local municipality;

C.  a discussion of local ability to fund adoption of and enforcement of local controls and standards, implementation of other specified programs, and capital improvements, including:
(1) levy limit constraints;
(2) effect on other city funding needs;
(3) establishment of watershed management taxing districts;
(4) creation of stormwater utilities; and
(5) monetary impact against homes or farmsteads in affected community;
D.  the impact on the local municipality of local implementation of each capital improvement project component if ad valorem financing is used; and

E.  a summary of grant funding that would likely be available to fund water management projects and programs.
The Rural Plan simply either ignores these considerations or sweeps them under the rug with generalities:
5.3 Impact of Collaborative Plan Implementation on Residents
Implementation of the Rural Collaborative Plan will include the establishment of permit requirements, including fees that may not have previously existed. Whether the Collaborative communities or the VRWJPO act as LGU, the implementation of the Collaborative Plan and water resource management ordinance or the VRWJPO Plan and Standards would have the same basic impact.
(This is the opposite of what the author has been telling the officials of these rural communities.  He has been telling him that, by adopting the Rural Collaborative Plan, they can save their landowners money by charging lower fees than the escrow requirements of the JPO.)

And how's this for a discussion of the "monetary impact against homes or farmsteads in affected community:"
Collaborative communities or the VRWJPO, whichever is the LGU, will also be establishing new setback and buffering standards from wetlands and water courses. In some instances these are viewed as additional burdens on land owners.
And then we get an explanation of why the JPO isn't worried about where the money will come from.  Of course, there's no recognition of any additional burden and costs on the adopting rural community:
At the present time, the VRWJPO implements an ad valorem tax for administration of the JPO, ongoing feasibility studies, and monitoring programs. The VRWJPO also has the authority to establish subtaxing districts to generate additional funding for special projects within individual communities or to recover costs where the VRWJPO has permitting authority. The preparation and implementation of the Collaborative Plan will not increase or accelerate any potential financial impacts on its general taxpayers.
This bwsr requirement to address financial considerations recognizes that the cost of implementing the goals, objectives and actions will have a cost, and that this cost should be balanced against the hoped-for results.  But of course, when you begin your analysis without accurately identifying the existing problem, you don't really know the "benefit" side of the
cost/benefit analysis anyway.