09.c1 12-21-2021 Engineering Updates
City of Scandia
Engineering Updates 12/21/2021
Engineering italics = old information
· 2022 Street Improvement Project (Melanie Trail N and 238th Street N)
City Council authorized Plans and Specifications for the 2022 Street Improvement Project at the June
15th City Council Meeting.
Staff met with Scandia Public Works on November 23rd to discuss scope of the project, as
well as go over any questions or concerns.
Received final Geotechnical report from AET December 2nd, 2021.
We plan to request Approval of Plans & Specifications/Authorize Ad for Bid at the January
18, 2022 Council Meeting.
Bid opening tentatively set for February 9, 2022.
· Bliss Drainfield System
Both the 2020 permit application for this system and the “final report” for nitrogen mitigation have
been completed and submitted to the MPCA. The memo which serves as a final report doesn’t
present final solutions for the nitrogen issue, but instead outlines the issues that have been found
and solved in this treatment system, as well as some additional testing that will now be
recommended to get a handle on the nitrogen, BOD, and TSS entering and leaving the facility. The
hope is to gain us a little more time from the MPCA before they mandate action. We’ll use this time
to perform the aforementioned testing and evaluate options for removing nitrogen at Bliss.
City received on February 22, 2021 a Pre-Public Notice Review of Draft Permit - Bliss Collector WWTP
(#MN0054119) that also included a statement of basis outlining any changes or new requirements to
the draft permit. This 30 day pre-public notice review period starts on February 22, 2021 and ends on
March 24, 2021. Once your pre-public notice review is complete the draft SDS permit will be placed
on public notice for 60 days.
· First thing that needs to be done is complete a Facility Evaluation Report within 180 days of
issuance of the new permit they requested. Based on the report, MPCA will then ask the City
to follow either Track 1 or Track 2. Track one is the new monitoring well. Track two is a
facility upgrade. There are a few other changes to the permit, they include some additional
monitoring required over this permit. Also, MPCA is requesting flow monitoring at WS 004,
WS 005 and WS 006. These are to each of the infiltration trenches. We are in the pre-public
draft notice stage where just the City received these draft documents and can
comment. We can review and suggest changes or modifications prior to March 24th.
· Current updates: Under track 1, the requirement to abandon GW 008 is included because
using this well for monitoring is problematic, since we have no information on the well’s
construction nor well boring records. Based on the limited information we do have, it is the
opinion of MPCA hydrologist, Steven Stark, that this well is too deep to be used as a
monitoring well and may be sampling a confined aquifer. All monitoring wells should be
sampling the surficial aquifer and have well screens that bisect the watertable.
· The justification for proposed timeline is sufficient and the new timeline will be incorporated
into the draft permit. Shown below (last page of this report) is a revised compliance
schedule. Flow monitoring requirements at WS 004, WS 005, and WS 006 will become
effective upon installation of the flow monitoring equipment. The permit will continue to
the 60-day Public Notice period.
The final permit has been issued. The assumption is that we’ll end up on Track 2, with
required system improvements due to the nitrate issue. Only thing that needs to take
place in the next 6 months (February 28, 2022) is for new flow meters to be installed at the
system, something we’ll begin working on. At the one year mark (September 1, 2022), we’ll
need to have a Facility Evaluation Report drafted to summarize the system’s ability or
inability to meet the nitrate limit.
· Sump Pump Inspection Program
2 homes/cabin remain to be inspected.
· Bliss Addition Stormwater Planning
Recent engagement with the Carnelian Marine St. Croix Watershed District resulted in the two bullet
points below:
· Cost responsibility - Who would take on what costs and how? Ideally the District would like
to participate with a Clean Water Fund Grant.
· Timeline - The District is working to complete the Subwatershed analysis for Big Marine
Lake. It will be complete by June 2021. Clean Water Fund Grants are awarded based on
how the score. Without a completed Subwatershed analysis for the entire lake and
application would score low. We planned to apply for a CWF grant in the fall of 2021 (after
the completion of the analysis). If the City would like to dedicate funding and move up the
timeline, they could request the CMSCWD Board of Managers consider funding a phase of
the project without a CWF grant. I do know that next year’s budget is tight with the state
required 10-year management plan update.
Temporary drainage improvements that included two options were presented at the August 5th City
Council Workshop that were intended to relieve drainage concerns at the property of 19123 Layton
Ave. Upon the discussion there seems to be separate opinions forming on both sides of the street of
what temporary solutions are favored but why the ultimate correction is not just completed in
conjunction with the storm sewer improvements identified in the neighborhood stormwater study.
On October 14, 2020 at the Watershed Board meeting, Board Managers approved $3,600 cost share
for option 1.
Watershed anticipates in 2021 they will apply for 2022-2025 Clean Water Funds to implement stage
1 and 2, but could potentially also apply for all three stages. It should also be noted it will be difficult
for the District to participate in just the directional pipe installation without the water quality BMPs
being installed in that area. City may want to consider adding water quality practices to this stage to
leverage more funds from District (with or without Clean Water Funds).
· Stage 1 – directional drilled pipe to re-route drainage to wetland
· Stage 2 – North Layton Ave bioinfiltration basin, concrete trench and enhanced ditch
improvements, west bioinfilration basins, and 189th culvert crossings and enhanced ditches.
Watershed has completed the evaluation of potential projects on Big Marine. The Subwatershed
Analysis is currently being prepared. Schedule still anticipates to be on track to apply for Clean Water
Funds in July 2021.
Meeting scheduled with City Staff and Watershed District to discuss Clean Water Fund Grant
Application on Thursday, July 22nd.
The final permit has been issued. The assumption is that we’ll end up on Track 2, with
required system improvements due to the nitrate issue. Only thing that needs to take
place in the next 6 months (February 28, 2022) is for new flow meters to be installed at the
system, something we’ll begin working on. At the one year mark (September 1, 2022), we’ll
need to have a Facility Evaluation Report drafted to summarize the system’s ability or
inability to meet the nitrate limit.
· CLFLWD Comprehensive Watershed Management Plan
Board of Water and Soil Resources approved the Plan on August 26
CLFLWD Board adopted final Plan on September 23
CLFLWD distributed the final approved Watershed Management Plan to partners and
required entities on October 21st, completing the final step in the WMP update process.
The final Plan is available at https://www.clflwd.org/watershed-management-plan.php.
Municipalities were informed of the requirement to revise or prepare LWMPs that conform
to this Plan. Please see section 8.1.2 of the Plan for more information. Note that some of
the requirements have been revised since the previous Plan.
· CLFLWD & Scandia Staff Quarterly Meetings
Meeting held on October 19, 2020.
Meeting on February 9, 2021.
Meeting on May 11, 2021 covered the following topics:
· Lake Management District Updates
· Bone Lake projects status
· Greenway Corridor Planning & Parks
· Roadway projects
· CMSCWD Managment Plan
· Bone Lake H&H Modeling Update at 5/13 Board Meeting.
· Meeting on September 13, 2021 covered the following topics:
· Permitting Update
· Roadway Projects
· Tiller Mining and WD Boundaries
· Bone Lake projects status (SE wetland restorations, NE wetland restoration, agricultural
practices)
· FY22 Clean Water Fund grant application – Moody Lake projects
· Greenway Corridor Planning & Parks
· CLFLWD Watershed Management Plan
· CMSCWD Watershed Management Plan
Meeting on May 11, 2021 covered the following topics:
· Permitting Update (Nick)
· Roadway Projects (Ken)
· Bone Lake projects status: SE wetland restorations, NE wetland restoration,
agricultural practices (Blayne)
· FY22 Clean Water Fund grant award – Moody Lake projects (Emily/Blayne)
· Greenway Corridor Planning & Parks Update (Nick)
· CMSCWD Management Plan (Mike Isensee)
· MnDOT/Washington County – Hwy 97 & Oakhill/CR 52
First initial contact/conference meeting with MnDOT to discuss issues and concerns with intersection
safety on October 13, 2020.
· This work has been completed; Signing – MnDOT will upgrade the size of all the fluorescent
yellow-green signs and add fluorescent yellow green tape to the sign structure (the post). At
the crossing itself MnDOT will be placing the enlarged signs back to back as to warn
motorist on approach of the crossing on Hwy 97. These additions will enhance the visibility
of the intersection.
· Striping - The school Xing pavement markings were completed with the last pavement
maintenance project, if City staff observes that these are worn out, please send in a request
to MnDOT and they will submit it to our pavement makings crew.
County Road 52/Oakhill
· City Council Workshop on June 2, 2021; Scandia City Council heard concerns residents who
live along Oakhill Road, east of the business area, where they have observed speeding traffic
and parking issues. One resident who lives at the site of the 30 mph zone remarked that the
majority of drivers do not slow their speed at all and race in and out of town, causing safety
concerns for the many pedestrians and bicyclists who share the road.
· Washington County has scheduled a meeting with City Staff on June 21, 2021 to discuss the
concerns brought forward to the City Council.
· Coincidentally the County has been communicating with the City Engineer to discuss Oakhill,
Highway 97, and Olinda Trail. We think this is a good time to have a conversation about
overall traffic flow, pedestrian connections, speeding, bike routing, school issues, etc. in the
“downtown” Scandia area and potentially start to develop a joint strategic plan for this
entire area – including engaging MnDOT about improvements to highway 97.
· Floodplain Risk Assessment
Online Workshop held, January 5, 2021
The Brown’s Creek Watershed District (BCWD), Carnelian-Marine-St. Croix Watershed District (CMSCWD) and
the Comfort Lake – Forest Lake Watershed District (CLFLWD) are jointly evaluating approaches to conducting a
floodplain mapping/flood risk assessment with two goals in mind:
· The short-term goal is to outline potential approaches the watershed districts could take to map and
quantify future flood risk.
· The long-term goal for these watershed districts is to build a common understanding of risk and
prioritize projects and other resiliency actions.
Recommendations from consultants were to: 1. Conduct a GIS-based flood hazard assessment and workshop
and 2. Model both historical and projected rainfall data to evaluate current design practices and inform future
planning and management decisions.
CMSCWD has a completed Hydraulic and Hydrologic Model that was updated and calibrated in 2021. This model
will be the foundation for any future climate resiliency modeling we conduct.
CMSCWD has identified climate resiliency/floodplain risk assessment work to be conducted in the 2023 in the
CMSCWD Draft 10 Year Management Plan. The public comment period for the Management Plan ends October
15th and the public hearing for the final plan is scheduled for November 18th.
Staff is working with our respective boards to approve submitting a collaborative grant
application to the MPCA by December 21st. (Planning grants for stormwater, wastewater,
and community resilience)
· Uptown Drainfield System Capacity Review
Recent inspection of interior of pumped-down EQ tank by Smilie’s didn’t detect any apparent
sources of I/I – we still don’t know where the additional flow that seems to be reaching the
treatment system is coming from.
Recently received some info which should help us predict flows from the downtown café once it
reopens.
After a final review we’re looking at allowing the proposed Heritage Center to connect to the
existing system without modification. However, we’d like one more specialist to take a look at
the system, specifically the drainfields, and verify that there isn’t evidence of an immediate
capacity problem. We’re currently working with this specialist to schedule a time for him to do
a site visit in the next 1-2 weeks.
· Regional Update – Highway 243 Osceola Bridge
MnDOT are in process of designing the reconstruction of the Hwy 243/Osceola Bridge over
the St. Croix National and Scenic Riverway, in partnership with the Wisconsin Department
of Transportation (WisDOT). The Osceola Bridge was built in 1953.
The purpose of this project is to maintain a reliable highway connection over the St. Croix
River for Hwy 243 between Washington/Chisago counties in Minnesota and the Village of
Osceola and Polk County in Wisconsin. The project team will work with federal, state and
local interests to minimizing project impacts to the St Croix River and other natural
resources in the area.
Project website: http://www.dot.state.mn.us/metro/projects/hwy243osceola/index.html
Schedule:
· Environmental documentation and preliminary design: 2021 through 2023
· Final design: 2023 through 2025
· Anticipated construction: 2025 through 2026
Denise Workcuff Dmitry Tomasevich
Communications and Engagement Project manager
denise.workcuff@state.mn.us dmitry.tomasevich@state.mn.us
651-775-0025 651-245-4406
· CMSCWD 2022-2031 Watershed Management Plan and Rule Revision
· The Carnelian-Marine-St. Croix Watershed District (CMSCWD) has completed the public
notification period to consider the Draft Fourth Generation Watershed Management
Plan (2022-2031). Final response comments received during the 60-day comment
period are attached to this report.
· In addition to receiving written public comment, the CMSCWD held two public hearings
at the Scandia Community Center, City of Scandia on September 8, 2021 and November
18, 2021 and at which time all interested persons will had the opportunity to address
the CMSCWD Board of Managers concerning the proposed draft plan and the draft
response to comments. Additional information can be found on the District website at
https://www.cmscwd.org/10year-management-plan-update.
· Gateway Trail Planning
Meeting with Washington County has been scheduled for Monday, November 29, 2021 to
discuss partnership on Gateway Trail Planning opportunities within Scandia.
· Martin Marietta Mine (old name Tiller Mine)
Annual site inspection was completed Friday, November 12, 2021.
· Merry Christmas & Happy New Year
CMSCWD 2022‐2031 Watershed Management Plan and Rule Revision ‐Response to Public Comment November 29, 2021
#Agency Commentor Section PageComment
MaterialEditorialChange Made Y/N Response
1 Public
Jim Siedel, Vice
President of Square
Lake Association
Grateful for the work that Administrator Isensee and others have put into the Draft Plan.
Commented that Administrator Isensee has been very helpful to him in understanding the Plan
and what the District is doing in the community. Mr. Siedel communicated with Matt Downing
in preparation for this meeting and learned that WCD conducted 488 hours of inspections on
Square Lake and he believes that assisted in keeping aquatic invasive species out of the Lake.
The Plan gives him great encouragement that the District will continue to work on reducing or
keeping aquatic invasive species out of the Lake.
NNNThe District appreciates the comment and look forward to continued collaboration with the
Square Lake Association
2 Public
Jim Siedel, Vice
President of Square
Lake Association
Wilder Land and Legacy Program should have a transparent and collaborative discussion by
CMSCWD, Washington County, May Township, and the Square Lake Association.NNNThe District will collaborate with the Wilder Foundation and Washington County and will provide
information to the public as it becomes available.
3 Public Barb Bickford 1.12 12 In 2nd sentence, change "limits...does" to "limits...do". N Y Y The change will be made as noted.
4 City of Marine
on St. Croix City Council Add funding to measure, monitor, or protect local groundwater quantity and quality Y N Y
Thank you for this comment. The District agrees that groundwater protections are an important
aspect of watershed management. Section IV.D. includes three goals related to groundwater
resources including protections for groundwater quality and groundwater dependent natural
resources. Description of the District's monitoring program in Section VI.B.iv of the Plan calls for
groundwater monitoring in at least 10 locations and includes a goal to "evaluate baseline
conditions and track trends in groundwater levels." While these activities are not currently funded,
they are included in Table 6‐3 (item # 26) and may be completed as funding or partnerships are
available. The District collaborates with other agencies in the implementation of the Washington
County Groundwater Plan, including strategies to identify and upgrade failing SSTS (Table 6‐3, item
#1) and includes a placeholder for upgrading high risk SSTS if funding or partnerships are available
(Table 6‐3, item #13). Further, the District reviews groundwater appropriation applications and
enforces rules to promote infiltration and groundwater recharge to benefit groundwater
dependent natural resources (Table 6‐3, item #2). Finally, education on groundwater quality and
quantity is included in the Communication and Outreach programs (Table 6‐3, items #39 & 40).
Table 6‐3 will be revised to remove terminology "currently not planned to be completed" and
replace with "Currently no funding identified. This activity may be completed as partnerships and
funding is available"
5 City of Marine
on St. Croix City Council
Add funding and plans to identify, monitor and protect unnamed seep springs that are a unique
characteristic within Marine on St Croix and within the St Croix watershed. These springs, likely
numbering in the 100s, located south of William O'Brien to south of Nasson Hill Road, are
unique water resources that support rare plants and animals while contributing high quality
cold water to the St Croix River.
YNN
Thank you for raising this issue. The District agrees these are unique features in the watershed.
Unfortunately, at this time this activity is a lower priority when compared to other priorities for
the District and is not planned to be completed at this time. Groundwater resources are protected
through the implementation of District rules and the wetland conservation act. This activity may
be completed as additional funding and partnerships become available. The District may consider
a new activity and plan amendment in the future if funding or partnerships arise.
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CMSCWD 2022‐2031 Watershed Management Plan and Rule Revision ‐Response to Public Comment November 29, 2021
6 Met Council Sam Paske
The Plan puts forth a detailed roadmap to protect water resources within the watershed and is
consistent with Council policies outlined in the Council’s 2040 Water Resources Policy Plan
(Policy Plan).
Staff commends the CMSCWD for preparation of a plan that includes a clear inventory of land
and water resources, included local and regional partners in the discussion of priority issues and
opportunities, contains clear statements of goals and policies, and provides a robust history of
accomplishments achieved by the CMSCWD efforts.
Council staff also applaud the Plan’s clear intent to improve, restore, and delist numerous
waterbodies. The use of adaptive management and targeted approaches allow the CMSCWD to
use data to drive their water resources goals. By assigning focused and routine implementation
strategies for waterbodies within the watershed, CMSCWD has created an efficient, clear
method to ensure all waters are monitored for water quality.
Finally, the emphasis on public and agency engagement for input and the coordination with
other water resources organizations and agencies is very impressive. These strengthened
relationships and collaborations will help to improve the water quality throughout the
CMSCWD.
N N N Thank you! The District looks forward to continued collaboration with the Metropolitan Council.
7 Met Council Sam Paske
Climate resiliency will be a shared challenge for all involved in watershed planning and the
Council appreciates its inclusion in the Watershed Issues and Goals. Council staff have some
experience in Climate Vulnerability Assessments, Groundwater‐Surface Water Interaction
Assessments, and other relevant technical analysis. As CMSCWD proceeds, please consider
Council staff as a resource.
NNNThank you. The District will certainly look to Met Council for data, analyses, and important insights
regarding these challenging topics.
8 Met Council Sam Paske
The Plan identified chloride is an increasing challenge for waterbodies in the watershed district.
However, the Plan only explicitly mentions chloride in the Groundwater Goals (GW1). The Plan
could be strengthened to include chloride as a water quality goal for lakes and streams and an
inclusion of a chloride monitoring plan in Appendix B
YNN
Thank you for highlighting this pollutant. Many of the over‐arching goals for water quality address
overall lake and stream protections and improvements (Section IV.B.) which would capture
protections from chloride pollution. At this point, the District is working to establish a baseline for
existing chloride levels. The Plan includes chloride monitoring in lakes (Table 6‐3, item #24; and
Appendix B) with chloride data collected in all lakes 3x/year. Chloride monitoring in streams will be
assessed as stream health information becomes available. In addition, Communications and
Outreach activity #40 in Table 6‐3 includes the outcome goal of all road authorities have Smart
Salting certificated winter maintenance crews.
9 Met Council Sam Paske
As a part of the Council’s Watershed Outlet Monitoring Program (WOMP), Council staff annually
perform invertebrate monitoring on Silver Creek. Please keep this in mind as you cycle through
the stream biomonitoring in CMSCWD. Council staff can provide you with our historic dataset if
this helps in your stream evaluations.
YNNThank you. The District will work with Met Council staff to incorporate these data into its dataset
when performing trend analyses and prioritization analyses.
2 of 16
CMSCWD 2022‐2031 Watershed Management Plan and Rule Revision ‐Response to Public Comment November 29, 2021
10 MnDNR Dan Scollan
The draft plan contains many goals, strategies and actions consistent with DNR’s priority issues
for the watershed. In particular, I am pleased to see these positive updates to the plan:
• Monitoring to evaluate shoreline vegetative cover with measurement of progress towards
75% of lakeshores having 50% natural vegetative cover. DNR encourages the use of site‐
appropriate native plants for shoreline stabilization, buffers, and erosion control. These species
provide important stabilization and erosion control functions, have the greatest chance of
establishment success, and contribute to biodiversity of landscape vegetation. A monitoring
approach for shoreline vegetation is an excellent addition to the plan.
• Enforcing unpermitted shoreland violations. DNR looks forward to participation in the
District’s new Shoreland Compliance & Enforcement Team.
• Supporting member community’s adoption of MIDS or more restrictive requirements into
local ordinance. MIDS was developed by the Minnesota Pollution Control Agency to minimize
stormwater runoff, minimize the amount of pollution reaching lakes, rivers, and streams, and to
recharge groundwater. The development of MIDS is based on low impact development (LID), an
approach to storm water management that mimics a site’s natural hydrology as the landscape is
developed.
• Monitoring chloride levels in lakes. Chloride released into local lakes and streams does not
break down, and instead accumulates in the environment, potentially reaching levels that are
toxic to aquatic wildlife and plants.
• Collaborating to facilitate native tree transition of black ash wetlands that will be decimated
by Emerald Ash Borer (EAB). DNR encourages communities to plan for EAB impacts and take
action now to reduce future problems.
NNNThank you! The District looks forward to continued and expanded collaboration with the
Department of Natural Resources.
3 of 16
CMSCWD 2022‐2031 Watershed Management Plan and Rule Revision ‐Response to Public Comment November 29, 2021
11 MnDNR Dan Scollan
With respect to proposed alum treatment in the plan, please consider applying the framework
developed by the Prior Lake – Spring Lake Watershed District for evaluating whether and when
alum treatment of a lake is appropriate. The
framework is a series of questions with parameters for evaluation, that relate to internal and
external phosphorus loading, rough fish, aquatic vegetation, cost, and water quality. Additional
DNR recommendations include:
• Alum treatment should be considered to address the historical internal reservoirs of nutrients
only after external sources of nutrients have been addressed.
• Alum treatments need to be timed to minimize fish management impacts as well as other non‐
target organisms such as benthic invertebrates.
• Complete pre‐ and post‐treatment assessments to document the amount and duration of the
alum treatment response.
• Due to potential non‐target impacts, consider completing pre‐ and post‐treatment
assessments of benthic invertebrates and amphibians.
• Take into consideration factors that could disrupt the alum layer, thus reducing the length of
time you would expect water quality benefits, such as wind fetch, carp and/or other benthic
feeding fish species, recreational activities, and shallow basins in general.
• When considering alum treatment on a lake, coordinate with MPCA and DNR’s East Metro
area fisheries supervisor, TJ Debates (651‐259‐5770; timothy.debates@dnr.state.mn.us).
• Refer to the Minnesota State and Regional Government Review of Internal Phosphorus Load
Control Lake management guide for additional information.
NNY
Thank you. The District agrees with this framework and the recommended actions for
consideration of alum treatments. Some of the actions and analyses listed are incorporated into
the internal load analyses as described in Section VI.A.5 of the Plan. Page 64, #5 Internal Load
Analysis will be revised to include coordination of evaluation and treatment with BWSR Board
Conservationist, MPCA, and DNR's East Metro Area Fisheries Supervisor. Table 6‐3 #56 and #69 will
be revised to include in coordination with BWSR, MDNR, and MPCA.
12 MnDNR Dan Scollan
The proposed minor rule revisions contain important clarifications that will benefit the
watershed. I’m pleased to see the District’s buffer requirements apply to the spring creeks that
flow into the St. Croix River. These creeks support high quality ecosystems with native Brook
Trout. In addition, I am pleased to see limits on retaining walls in the buffer zone. This rule
revision will guard against excessive topographic and vegetative alteration in this sensitive area.
N N N Thank you.
4 of 16
CMSCWD 2022‐2031 Watershed Management Plan and Rule Revision ‐Response to Public Comment November 29, 2021
13 Washington
County
Jessica L. Collin‐
Pilarski
Public Health and Environment (PHE) thanks the Carnelian‐Marine‐St. Croix Watershed District
(CMSCWD) for recognizing the county as a partner in water resources management. This is
apparent as the Watershed Management Plan (Plan) recognizes the framework and
collaboration that the county Groundwater Plan provides. The Plan also incorporates
groundwater throughout showing that the CMSCWD recognizes the importance groundwater
plays in the entire watershed system.
The Plan is very comprehensive and connects many topics that are of great importance to its
district residents to public health. The CMSCWD discusses partnerships, strategies and policies
surrounding:
Groundwater contamination
Failing septic systems
Sealing abandoned wells
Aquatic Invasive Species
Flooding and channel maintenance
Climate impacts
Recognizing the Washington County Governance Study
Active participation in the Washington County Water Consortium
N N N Thank you. The District looks forward to continued collaboration with Washington County.
14 Washington
County
Jessica L. Collin‐
Pilarski Include reference to the county abandoned well sealing cost share program. N Y Y
Table 6‐3, Item #40, note #1 will be revised to add the County abandoned well sealing cost share
program.
15 Washington
County
Jessica L. Collin‐
Pilarski
The county has worked with East Metro Water Resources Education Program to develop
educational brochures and flyers around septic systems, flooding and other groundwater issues.
Please reach out when you are ready so we can share what has been created and then you can
determine what additional is needed. Also, it would be great to collaborate on anything new to
be sure the messages include information on any county programs that residents may find
helpful.
NNN
Thank you for the suggestion. As noted in the Plan, the District partners with EMWREP for most of
its education and outreach activities. The District will continue to collaborate with EMWREP and
the County through the Washington County Water Consortium and other avenues, as warranted.
16 Washington
County
Jessica L. Collin‐
Pilarski 0
The Watershed District is proposing language related to direct conveyance to groundwater‐
dependent natural resources. To help provide clarity, we are requesting for the Watershed
District to add “Direct Conveyance” to section 0.0 Definitions.
N Y Y The change will be made as noted
17 Washington
County
Jessica L. Collin‐
Pilarski
Washington County Public Works is supportive of O&M3, which states that ‘District rules should
be clear, impactful, streamlined, and enforced’.N N N Thank you.
18 BWSR Melissa King Provide hyperlinks to stated webpages and for referenced studies and plans and ensure
hyperlinks are valid.N Y Y The change will be made as noted
19 BWSR Melissa King Many map figures in the main body of the Plan are not legible or are difficult to read. Please
address.N Y Y Maps will be updated for better clarity within the plan.
20 BWSR Melissa King I Section I. Per MN Rule 8410.0050(B) please include a map of the organization N Y Y A map of the District will be added to Section I.
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CMSCWD 2022‐2031 Watershed Management Plan and Rule Revision ‐Response to Public Comment November 29, 2021
21 BWSR Melissa King I.D. 19
Section I.D. Table 1‐1. Ensure information is consistent with planned implementation budgets,
activities and outcomes presented in the Section VI and Table 6‐3. For example, internal lake
load evaluations for Fish and Goose Lakes are identified as capital improvements on Table 6‐3.
N Y Y Table 1.1 will be updated for consistency with planned costs in Table 6‐3.
22 BWSR Melissa King I.D.
Section I.D. The Plan implementation results identified on page 16‐17 (i.e., years and specific
lakes anticipated to be delisted, improved condition for specific lakes & parameters), which are
noted again on page 53, are not explicit with information presented in Section V and Section VI.
This information should be
clear and consistent with goals and implementation actions presented later in the Plan. Some
examples include:
a. Specific water resources that are impaired are only identified in Appendix A. Section IV.B.
does note that “…some waterbodies are being considered for delisting, or being removed
from…”, however, the specific water resources and expected schedule to achieve are not clearly
identified in the Plan goals or
implementation section.
b. Specific lake water quality goals presented on Table 5‐1 or Table 5‐2 do not identify lake
water quality goals for chlorophyll‐a.
c. Improved clarity is noted for Big Carnelian and Big Marine however, current condition
growing season averages identified on Table 5‐1 currently exceed the District’s secchi depth
goal for each lake.
YNY
The Plan will be revised for consistency and accuracy among Tables 5‐1, 5‐2, 5‐3, and 6‐3 and
Figure 5‐1; along with "Plan Implementation Results" as listed in Section I.D. and Section V.
Tables 5‐1 and 5‐3 will be revised to include a column indicating impaired vs. unimpaired
waterbodies.
The goals shown in Section IV.B. will be revised to include a reference to the specific water quality
goals outlined in these tables and figure plus load reduction goal for the St. Croix River.
The District water quality goals focus on total phosphorus (TP) and TSS and do not include specific
numeric goals for chlorophyll‐a. Improvements to TP and TSS should result in improvements to
chlorophyll‐a levels.
Short term TP and Secchi trends for Big Carnelian and Big Marine are Strongly Worsening and
Minimally Improving, respectively, and considering these trends the District has established
further watersheds load reductions to ensure District goals continue to be met (i.e. attempt to
reverse short term trends). Table 5‐1 indicates a measurable goal of "Improve 10 Year TP & Secchi
Trends" and "Maintain Improving 10 Year Trends".
23 BWSR Melissa King I.D. 18
Section I.D. Some implementation actions identified on page 18 are either not identified in the
Plan’s implementation section (e.g., Jellum’s & Long Lake internal load evaluation) or noted in
Table 6‐3 as ‘Currently not planned to be completed’ (e.g., Black Ash seep restoration, AIS
Detectors). Information
presented should be consistent with activities identified in the implementation section to be
completed within the life of the Plan.
NYY
The implementation items listed in Section I.D., page 18 indicate those activities that are NEW to
the District, as noted in the paragraph describing the list. While not all of these activities are
currently funded, the District believes it is important to keep these activities in the Plan so they
can be implemented as funding becomes available. The District does not wish to "lose sight" of
these activities as implementation moves forward in the next 10 years and beyond. As noted in the
paragraph, Table 1‐1 includes the HIGH PRIORITY activities that are funded and planned for
implementation.
Table 6‐3 will be revised to remove terminology "currently not planned to be completed" and
replace with ""Currently no funding identified. This activity may be completed as partnerships and
funding is available"
24 BWSR Melissa King I.D. 19
Section I.D. Table 1‐1. Ensure information is consistent with planned implementation budgets,
activities and outcomes presented in the Section VI and Table 6‐3. For example, internal lake
load evaluations for Fish and Goose Lakes are identified as capital improvements on Table 6‐3.
N Y Y Table 1.1 will be updated for consistency with planned costs in Table 6‐3
25 BWSR Melissa King II 23
Section II. History & Accomplishments (page 23).
a. Revise reference to Minnesota Statue 103D in the first paragraph to 103B.N Y Y The change will be made as noted
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26 BWSR Melissa King II 23
The summary of accomplishments included does not provide context for the District’s success,
or extent of progress made related to the accomplishment of the previous Plan’s goals,
particularly in consideration of specific lake water quality goals. The success of implementing
the previous Plan, if any, must be summarized and considered in identifying priority issues (MN
Rule 8410.0045 Subp. 7). Please incorporate additional narrative related to the District’s
achievement of goals from the previous Plan.
YNY
The success of implementing the previous plan was considered throughout the planning process.
The Plan will be revised to expand information on the extent to which the previous plans program
goals in Section IV of the 2015 CMSCWD Watershed Management Plan were or were not
accomplished.
27 BWSR Melissa King IV.A & App G
Section IV.A, Appendix G. It is unclear if notification was distributed to or any input was received
as a result of the notification required (MN Rule 8410.0045 Subp. 4), from local government
units located within the watershed or known stakeholders. Please clarify how this requirement
was satisfied and include a summary of any early input received from local government units
and known stakeholders.
YNY
The first sentence in Section IV.A.i. will be revised to include reference to the Rule: "At the outset
of the plan development process, and in accordance with MN Rule 8410.0045, Minnesota state
agencies including……"
That section goes on to describe input gathered from the TAC, which includes multiple known
stakeholders as listed in the "approvals and acknowledgements" section. Further, that section
describes input from the public (aka, stakeholders), and the CAC.
Appendix G will be revised to include the initial input letters from state agencies.
28 BWSR Melissa King IV.A & App G Section IV.A, Appendix G. Please clarify how the initial planning meeting requirement was
satisfied (MN Rule 8410.0045 Subp. 5).NYYSection IV.A. and Appendix G will be revised to include a description of the initial planning meeting
and list of attendees.
29 BWSR Melissa King IV.A & App G
Section IV.A, Appendix G. Revise with a summary of all early input received and the District
Board’s assessment process for evaluating all early input received in identification of priority
issues (MN Rule 8410.0045 Subp. 7).
YNY
Appendix G will be revised to include the initial input letters from state agencies.
Section IV.A. will be revised to further describe the process used by the Board, staff, and CAC to
develop and prioritize issue statements based on early input and survey responses.
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30 BWSR Melissa King IV.B. ‐ IV.I
Sections IV.B‐IV.I. Many of the overarching Plan goals lack specificity/measurability to ascertain
what the goal will accomplish and allow for the success or failure to be measured (MN Rule
8410.0080 Subp. 1). Plan goals need to be reviewed and revised so that the goal relates to the
priority issue(s) being addressed and express the extent of progress that the District will make
during, or the outcomes to be accomplished, by the end of the Plan period. Some proposed
implementation activities are proposed to address sediment
discharges to the St. Croix River, phosphorous loading to Lake St. Croix (see comment # 18),
bacteria impairments, emerging contaminants such as chlorides, pollutants loading from non‐
compliant septics, etc., however, in many instances neither the over‐arching nor any of the
specific water quality resource goals
directly addresses.
YNY
As stated in the paragraph at the bottom of page 37, the goals listed in Section IV.B. are over‐
arching goals developed to address the issues identified by stakeholders. Most goal statements
will be revised to include more specific water quality goals, pollutant reduction goals, and
measurable outputs by brining outputs found in Tables 5‐1, 5‐2, 5‐3, and 6‐3 into the goal
statements, where appropriate (including all water quality goals, and some goals related to
wetlands, uplands, and AIS). Specific water quality goals for District lakes and streams are found in
Section V.
The Plan will be revised to include a measurable water quality goal for St. Croix River of a
reduction of 100 pounds of TP/year. This will be included in goal WQ2 and in Section V under the
St. Croix River.
Page 54 of the Plan will be revised to include a description of measurable progress to address
bacteria impairments on Carnelian Creek through the Carnelian Creek Cattle Exclusion, identified
in Table 6‐3 Ten‐Year Implementation Plan item #67. Following exclusion of bacteria sources and
subsequent bacteria monitoring identified in 2027 in the streams monitoring plan in Appendix B,
progress toward delisting will be evaluated. The plan further be revised to identify the goal of
delisting Swedish Flag and Gilbertson's Creeks through the confirmation of non‐anthropogenic
sources of bacteria through molecular biomarker testing identified for funding in 2025 in the
streams monitoring plan in Appendix B.
Chloride pollution is not explicitly mentioned in issue statements but is being addressed through
training of road authorities. And, establishing baseline conditions of chloride levels in lakes is
included in the monitoring plan.
Washington County and MDH regulate SSTS ‐ the District's goal related to SSTS includes improving
education as stated in GW3.
While not every possible pollutant has a specific goal, the District wishes to keep these issues and
over‐arching goals in the Plan to acknowledge the issue.
31 BWSR Melissa King IV.B.
Section IV.B. The Plan needs to make a stronger correlation from the specific water quality goals
identified for the 31 lakes (table 5‐1), phosphorous load reduction goals for the 31 lakes (Table 5‐
2), and the stream health goals for the 21 streams (Table 5‐3) presented in Section V to the
overarching goals in Section IV.B and proposed schedule of implementation activities. The Plan
would benefit from clarity, to more clearly identify the schedule in which priority waters will be
addressed and identify which Plan implementation activities are proposed to benefit which lake
water quality and stream health goals.
YNY
The goal listed as WQ4 will be revised to include a reference to Table 5‐2 and will note the total
phosphorus loading reduction expected across all waterbodies during the life of the plan.
For streams, specific pollutant load reductions cannot be assigned at this time because more
robust data are needed to help identify the current health of the streams, riparian conditions need
to be evaluated on streams slated for restoration, and SWAs are needed to target implementation
and assess pollutant reductions needed.
We believe the schedule for activities is clearly laid out in Table 6‐3, particularly with regards to
CIP implementation and SWA analyses.
32 BWSR Melissa King IV.B 38
Section IV.B. Identify how the runoff volume reduction goal (WQ5) correlates to proposed water
quantity goals.NYYThe goal listed as "FLOOD3" will be revised to cross reference goal "WQ5." Further, FLOOD2 will
be revised to reference the Carnelian Channel Operation and Maintenance Plan.
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33 BWSR Melissa King IV.B.
Section IV.B. Clarify if noted “high priority” lakes and streams are equivalent to water resources
identified as “focused” in Section V.NYY
Goal statements will be revised for consistency with terminology. In WQ6 and WQ7, "priority" will
be revised to "focused." WQ10 will be revised to read "All lakes are regularly monitored
through a robust water monitoring program." WQ11 will be revised to read "All streams are
monitored to identify stream health trends." Under wetland goals, WTL2 will be revised to read
"Evaluate and mitigate nutrient contributions to focused water resources." Additionally, UP1 will
be revised to "Increase terrestrial invasive species management and/or native vegetation
restoration of private and public lands around focused lakes.
34 BWSR Melissa King V 53
Section V, page 53. The implementation outcomes are not consistent with those presented in
the Executive Summary and Section V Tables (5‐1, 5‐2, 5‐3). Please review and revise for
consistency.
NYYThe outcomes listed on pages 17 and 53 and shown in Figure 5‐1 will be updated for consistency
with Tables 5‐1, 5‐2, and 5‐3.
35 BWSR Melissa King V
Section V, St. Croix River. The collective load reduction the District hopes to accomplish within
the life of the Plan, towards the phosphorous load allocation for Lake St. Croix should be
articulated in the Plan goals.
YNY
Total phosphorus reductions to the St. Croix River are expected to be the result of targeted Plan
implementation. The Plan will be revised to include a goal of reducing annual total phosphorus
loads to the St. Croix River by 100 pounds. This change will be reflected in goal statement WQ2
(Section IV.B.) and in Section V.
36 BWSR Melissa King V Section V, Streams. Please clarify the differences between the proposed stream outcomes. N Y Y
The text will be revised in Section V (under "Streams") to define the terms "preserve," "restore,"
and "improve." Preserve = maintain stream health grade determined from 2014 evaluations.
Improve = increase stream health grade determined from 2014 evaluations. Restore = achieve
district stream health goal during life of this Plan.
37 BWSR Melissa King V
Table 5‐
1
Provide a measurable goal for Maple Marsh Lake. If none, remove this water resource from
Table 5‐1 and Table 5‐2. YNY
Maple Marsh Lake will remain in Tables 5‐1 and 5‐2. The lake has not historically been monitored
because it was created through an impoundment of a wetland and has low ecological quality due
to historic land uses within it's contributing catchments. The ten year monitoring plan identities
short‐term intensive monitoring for Maple Marsh to facilitate more accurate management goal
setting.
38 BWSR Melissa King V
Table 5‐
1 Review and revise table values for consistency with Table 5‐2 and Table A‐17. N Y Y Table A‐17 in Appendix A will be revised for consistency with Table 5‐2.
39 BWSR Melissa King V
Table 5‐
1
Review TP and secchi goal values identified in the “2022 WMP” column for consistency with
those under “District Goals”. In some instances, the proposed 2022 WMP TP/secchi goal results
in greater water quality improvement than the stated “District” TP/secchi goal. In some
instances, the WMP TP/secchi goal is less than the state “District” goals, but the “District” goal is
noted to be currently achieved based on concurrent conditions (example: Big Carnelian).
NYYTable 5‐1 will be reviewed and revised as needed. If additional clarity of goals or implementation
strategy is warranted, it will be added in text or with footnotes.
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40 BWSR Melissa King V
Table 5‐
1
This table would benefit from additional clarifying information including identification of which
lakes are impaired, which are ‘nearly’ impaired, and noting outcomes for those specific lakes
proposed to be delisted. Providing additional context for what is meant by insufficient trend
data would also be helpful. Is trend data insufficient based on a lack of monitoring data
available or insufficient because there is a lack of confidence in the statistical significance?
NYY
Table 5‐1 will be revised to include impairments. We believe this table clearly states the outcomes
expected. For instance, "achieve state goal" ensuring the lake is meeting state goals, i.e., removing
the lake from the impaired waters list.
The table will be revised to include a footnote indicating that "Insufficient data" means there is a
lack of monitoring data needed for trend analysis.
41 BWSR Melissa King V
Table 5‐
1
Please clarify the outcomes for noted ‘District’ versus ‘State’ goal, when the numeric secchi and
TP goals for both are the same.NNNThere is nothing to clarify. If District and State goals are the same, it doesn't matter which goal the
Plan is aiming to achieve as they are the same numeric standard.
42 BWSR Melissa King V
Table 5‐
1
Proposed WQ goals (for either TP and secchi or both parameters) for many of the lakes, are
currently met based on the 10‐year average of current conditions, and in some instances with
lake trends noted to be improving. The Plan needs to more clearly articulate the proposed
outcomes to be achieved by the end of the Plan period, where the benchmarks for these goals
are met going into the start of the Plan; particularly in those instances where a resource is noted
as “focused”, is not currently impaired, and status as a ‘nearly’ impaired resource is unclear.
N Y Y Table 5‐1 water quality goals based on short term (10‐year) trends will be clarified.
43 BWSR Melissa King V
Table 5‐
2
Provide measurable Plan goals for all water resources with no identified phosphorous load
reduction or a phosphorous load reduction of zero. If none, remove those resources from the
table.
NYY
We believe it is important to keep all District lakes in Table 5‐2 so that Plan readers know the lake
was considered and analyzed for possible load reductions. A footnote will be added to Table 5‐1
explaining why these lakes do not have an assigned load reduction as they are already meeting
standards.
44 BWSR Melissa King V
Table 5‐
2 Review and revise table values for consistency with Table 5‐1, Table 6‐3, and Table A‐6. N Y Y These tables will be revised, as needed, for accuracy and consistency.
45 BWSR Melissa King V
Table 5‐
2
Review values presented in the load reduction columns (needed, achieved, remaining). For
some resources no load reduction is proposed to be achieved, yet there is a net reduction
identified (e.g., Big Carnelian, Big Marine, Carol, Square Lakes). Proposed load reductions to be
achieved by CIPs is not consistent those specific resources outcomes identified in Table 6‐3 (e.g.,
Goose, Sand). No specific proposed load reductions are identified to be achieved by CIPs,
however, outcomes presented in Table 6‐3 identify load reductions for some lakes (e.g., Big
Carnelian, Big Marine, Fish, Little Carnelian and Long Lake‐Scandia).
YNY
Column headings in Table 5‐2 will be revised for clarity. For instance, "load reductions achieved by
CIPs" refers to previously implemented CIPs rather than future CIPs. A new column will be added
to show load reductions expected during the life of the Plan which total 447.8 lbs. TP/year
46 BWSR Melissa King V
Table 5‐
3
This table would benefit from additional clarifying information including identification of
impaired resources and distinguishment between the outcomes proposed (see comment #19).
(our comments 43‐ 45)
NYY
Table 5‐3 will be revised to include a column listing current impairments (which include Carnelian
Creek, Swedish Flag Creek and Gilbertson's Creek). The Plan will be revised to include explanations
of "preserve, improve, and restore."
47 BWSR Melissa King V
Table 5‐
3
Stream health grades and proposed goals should be reviewed for consistency with Table 6‐3,
Appendix B, and pages 17 and 53. Proposed health goals (e.g., William O’Brien, Spring, Willow
Brook, Cedar Bend Trout Farm) or measurable outcomes vary.
N Y Y The Plan will be checked for consistency as recommended and revised as needed.
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48 BWSR Melissa King V
Table 5‐
3
The proposed measurable outcome should be clarified to more clearly articulate the proposed
outcomes that will be achieved by the end of the Plan periods. Ten creeks have no noted
improvement in stream health proposed. Carnelian Creek identifies no proposed change to
stream health, but the noted outcome is ‘improve’.
YNY
Data are lacking to fully understand the current health of District streams. This is the first District
Plan that focuses effort and financial resources on assessing and addressing stream health. Once
stream health assessments are complete, priority areas will be defined and/or refined. On
Carnelian Creek, a cattle exclusion project is planned and is expected to reduce bacteria (hence
"improve" conditions). However, that project is not expected to impact stream health score.
As noted above, Table 5‐3 will be revised to include a column listing current impairments. Text will
be revised to define "preserve, improve, and restore."
49 BWSR Melissa King VI.A. 1‐7
The narrative provides a good overview for how each assessment type is proposed to be
conducted. However, not all sections identify activities proposed to be completed within the
period of the Plan. Where known, identify those specific studies in this section and/or in Section
VI.B.v.
YNN
Section VI.A. 1 ‐ 7 is simply a description of various assessment and diagnostic activities the District
(or any watershed) has at its disposal to help identify and target implementation. Section VI.B.v.
describes the District's prioritization and analysis program (similar to how other District programs
are described in the sections preceding it). Table 6‐3 includes known specific studies or
assessments that will take place during the life of the Plan.
50 BWSR Melissa King VI.A. 1‐7
Suggest providing reference to Table 6‐1, with added hyperlinks. Where Table 6‐1 does not
include, provide a detailed list of each study/assessment/analysis completed and approved,
with hyperlinks, that the District intends to implement within the period of this Plan. For
example, completed subwatershed
assessments are not identified in Section VI.A or on Table 6‐1.
NYYTable 6‐1 will be updated to include completed subwatershed analyses (with links) and links to
completed diagnostic studies.
51 BWSR Melissa King VIA.1 61
Section VI.A.1. The results of the pollutant delivery hotspot is a great resource to help prioritize
and target implementation activities. Additional context should be provided on how the District
intends to use the results to prioritize and target implementation and/or identify the specific
priority area(s) that the District intends to focus implementation for the time period of this Plan.
NYY
The Plan will be revised to include The District prioritizes catchments for BMP retrofitting or for
cost share assistance based on pollutant hotspot mapping, which includes delivery efficiency of
pollutants to water resources. This data is used to conduct subwatershed analyses which target
and prioritize water quality improvement practices. The District also utilizes this data to prioritize
outreach, technical assistance, and cost share for voluntary water quality improvements.
52 BWSR Melissa King VI.A.4 and 7
Section VI.A.4 and VI.A.7 Appendix C provides an overview of the process to complete lake and
stream diagnostic studies. Copies of studies completed were not located within the Plan. Please
clarify.
NYY
The Plan will be revised to include weblinks to completed diagnostic studies and SWAs. Further, it
will be revised to refer to Appendix C for further detail on data and methodology used in
diagnostic studies, rather than the studies themselves.
53 BWSR Melissa King VI.A. 765
Section VI.A.7. Clarify what streams are proposed to have diagnostic studies completed. It is not
clear which streams have not met State goals outside of the identified District stream health
goals.
NYY
Table 5‐3 will be revised (as noted above) to include a column noting impaired streams. Stream
diagnostic studies are not planned at this time but may be utilized in the future as funding
becomes available or needs arise after additional stream data are gathered.
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54 BWSR Melissa King VI.B.ii & VI.E.
Section VI.B.ii and Section VI.E. The Plan does not identify the enforcement process specific to
violations of regulatory controls, nor does the Plan include an assessment of existing controls
within the watershed (MN Rule 8410.0105 Subp. 6). Please address.
YNY
Section VI.B.ii will be updated to indicate that the enforcement process for violations to District
Rules is included in Section 10 of the Rules document. (The Section will also be updated to
reference Rules by weblink rather than including them with the Plan as an appendix. See response
to comment #82.)
Section VI.B.ii will be updated to note that the District recognizes that the primary control and
determination of appropriate land uses is the responsibility of the municipalities. Accordingly, the
District will coordinate permit application reviews with the municipality where the land is located.
Proposed projects will be reviewed for compliance with District Rules concurrently with reviews
performed by LGUs and Washington County in instances where the proposed project is within a
township and a shoreland zone.
Section VI.E. includes a narrative that describes the existing controls of State and Federal agencies
and the Met Council. The section will be revised to include a description or list of relevant existing
local controls within the watershed including those of member cities and Washington County.
Table 6‐3, Item #3 District Rules Updates will be updated to indicate assessment of existing
controls in addition to the funding and technical assistance to update community local controls
concurrent with District rules updates.
55 BWSR Melissa King VI.B.iii 72
Section VI.B.iii. Inspection and maintenance of Silver Creek areas are identified but specific
implementation activities and budgetary considerations are not directly identified in Table 6‐3.NYY
Activity #14 in Table 6‐3 will be revised be more comprehensive and will read "Channel and Outlet
Inspections and Maintenance". The 10‐year Outcome for Activity #14 will be revised to include
annual inspection and maintenance of Silver Creek Areas in addition to Carnelian Creek Channel.
56 BWSR Melissa King VI.B.iii 75 Section VI.B.iii CI‐4. Identify the party responsible for maintenance. N Y Y
The Plan will be revised to describe maintenance responsibilities for Marine on St. Croix Phase 1
BMPs. The County maintains the facilities within the county right‐of‐way. The District maintains
the basins in city right of way in collaboration with residents (through landowner maintenance
agreements).
57 BWSR Melissa King VI.B.iv. 82
Targeted monitoring was noted in Section VI.A.3 but proposed monitoring activities were not
identified in Appendix B. Please clarify.YNN
As stated in Section VI.A.3, "targeted monitoring" will be used as one tool for assessment and
prioritization when a subwatershed analysis would benefit from such monitoring to better
pinpoint possible pollution sources. Since the specific locations and parameters of such monitoring
are not currently known, it cannot be included in Appendix B. However, please note that targeted
monitoring of wetlands is included in Table 6‐3 #29.
58 BWSR Melissa King VI.B.iv. 82
Proposed monitoring activities noted on page 82 include groundwater level monitoring in at 10
locations. However, Table 6‐3 identifies groundwater level monitoring is “not planned to be
completed” and the proposed monitoring plan included in Appendix B does not identify
groundwater monitoring
activities. Please clarify. The District’s policies and objectives for groundwater monitoring should
also be revised accordingly.
YNY
While important, at this time groundwater monitoring is not a high enough priority to complete
with the District's limited funding. If funding or ample partnerships become available, this activity
may be completed. Text in Table 6‐3 will be revised from "not planned to be completed" to
"Currently no funding identified. This activity may be completed as partnerships and funding is
available"
59 BWSR Melissa King VI.B.iv. 82
The Plan does not address whether the established monitoring programs can produce an
accurate evaluation of progress towards identified Plan goals (MN Rule 8410.0105 Subp. 5).
Please address.
YNN
The goals of the water monitoring in Section VI.B.iv include "Track water quality trends and
progress toward meeting water quality goals, "Provide data to focus, prioritize, and target District
work and funding," and "Evaluate the impact of District projects and programs." Further, Appendix
B lays out a clear and very detailed monitoring program for all lakes and streams. We believe these
sections satisfy 8410.0105 Subp 5.
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60 BWSR Melissa King VI.B.v 85
Section VI.B.v. Page 85 identifies diagnostics studies planned to be completed, however the
resources identified are not consistent with those identified on Table 6‐3. Please clarify.NNNAs stated in the title, Table 6‐1 in Section VI.B.v shows studies completed, not planned to be
completed.
61 BWSR Melissa King VI.B.vi. 87
Section VI.B.vi. Page 87. Training AIS detectors was noted in Table 6‐3 as “not planned to be
completed”.
Please clarify.
YNN
While important, at this time AIS detector training is not a high enough priority to complete with
the District's limited funding. If funding or ample partnerships become available, this activity may
be completed. Text in Table 6‐3 will be revised from "not planned to be completed" to "Currently
no funding identified. This activity may be completed as partnerships and funding is available"
62 BWSR Melissa King VI.B.vi. 87
Section VI.B.vi. Page 87. Policies 2 and 4 and policies 1 and 3 seems very similar yet identify
different areas/species of focus. Consider consolidating and clarifying.NYY
Policies 1 and 3 list distinct priorities and should be listed separately for easier reading. Policy #3
will be moved to the second spot on the list to keep similar policies together. Policies 2 and 4 focus
on two different threats: water quality through increase in TP, and ecological health. They should
be listed separately (although their position in the list will change.)
63 BWSR Melissa King VI.B.vii. 88 Section VI.B.vii. Identify the specific areas to be prioritized for targeted implementation. N Y Y
This section describes the cost share program and indicates that projects are "actively pursued in
targeted and prioritized areas." Clarity will be added to note that projects will be actively pursued
in the watersheds of "focus" lakes and streams and will be targeted in specific areas as determined
through prioritization analyses such as SWAs.
Section VI.B.vii will also be updated to include the fact that the Seven Lakes SWA, St. Croix and
Spring Streams SWAs, existing pollutant hot spot mapping, and future SWAs will help identify
possible projects where cost share will be targeted.
Also please note in Section VI.B.viii (Objective #4) and Table 6‐3 #40, communication and
outreach will be targeted to landowners in priority areas to help improve the level of voluntary
implementation that's so critical to reaching the outcomes and goals.
64 BWSR Melissa King VI.B.vii. 89
Section VI.B.vii. The weblink provided to the District’s cost‐share policies is not valid. Please
address.N Y Y The weblink will be updated.
65 BWSR Melissa King VI.D.i
Section VI.D.i. Revise the narrative to distinguish the procedure and timeframes to evaluate Plan
goal progress (minimum every 2 year per MN Rule 8410.0080 Subp. 1) and goals and
implementation action progress (minimum every 2 years per MN Rule 8410.0150 Subp. 3.E),
from the annual activity reporting
requirements (MN Rule 8410.0150). When the assessment of goals & implementation action
progress are completed, those results should also be included within the annual activity report.
YNY
The Plan will be revised as recommended to better distinguish between annual reporting
requirements and Plan goal progress in Sections VI.D.i and VI.D.ii. An example of an annual
progress report will be included in the Plan.
66 BWSR Melissa King VI.D.i 97
Section VI.D.i. Please revise the annual activity report content requirements to be consistent
with MN Rule 8410.0150 Subp. 3 and MN Statute 103D.351. Required annual reporting also
includes information on the District’s financials per MN Rule 8410.0150 Subp. 1 and MN Statute
103D.355.
YNYThe Plan will be revised as recommended to include, explicitly, the annual report contents as
required by MN Rule and Statute and will include an example of an annual progress report.
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CMSCWD 2022‐2031 Watershed Management Plan and Rule Revision ‐Response to Public Comment November 29, 2021
67 BWSR Melissa King VI.D.ii.
Section VI.D.ii. As noted in comments #12 (this document #31) and #37 (this document #68) the
Plan must define a procedure to evaluate progress for each goal and implementation activities.
Anticipated outcomes for identified implementation actions should be included for those
actions identified in the implementation section narrative and/or Table 6‐3. Plan goals need to
be revised to incorporate greater specificity so that the success or failure is able to be
evaluated, specific water resources goals correlated to the overarching goals, and the Plan will
need to define a specific procedure by which the District will conduct that evaluation.
YNY
As written, Section VI.D.ii. clearly states how progress will be assessed for the goals and outcomes.
Numeric/quantifiable goals and outcomes, including progress toward meeting water quality goals,
will be evaluated through water monitoring data, number of projects installed, number of projects
inspected, number of educational programs delivered, number of partner meetings held, etc. Also
as stated in Section VI.D.ii., other metrics are not easily quantified and progress will be reported
through a narrative discussion that includes level of effort and effort leveraged through
partnerships. These are well established procedures for assessing watershed management
progress. However, Section VI.D.ii will be revised to include an example of an annual progress
report. The Section will also be revised to include a description of how the biennial progress
evaluation will be used in annual work planning and to assess the need for plan amendments. It
will also include a note on how BWSR's PRAP Level II results will be incorporated into future
implementation actions.
68 BWSR Melissa King VI.D.ii.
Table 6‐
2 Section VI.D.ii, Table 6‐2. Review for consistency with Appendix A, Section 15. N Y Y Appendix A Section 15 will be revised for consistency with Table 6‐2 in Section VI.D.ii.
69 BWSR Melissa King VI.D.ii. 102
Section VI.D.ii, page 102. The procedure to address a local government unit’s failure to
implement should contain more specific criteria and timelines. Suggest removing reference to
MN Rule 8410.0180 as the process outlined is largely not applicable as well as reference to
submission of “annual report or audit” as
those requirements for local water management plan implementation have not been outlined
in the Plan or are not required by MN Rule 8410.0160 or MN Statute 103B.235.
YNY
The section of text entitled "Cooperation and Implementation of LWMPs" on page 102 in Section
VI.D.ii, will be removed. The language describing cooperation on and assistance with the
development of LWMPs will be added to appropriate paragraphs regarding LWMPs in Section
VI.D.ii page 100 to provide consistency with Metropolitan Council Surface Water Management Act
State Statutory requirements to:
• Describe existing and proposed physical environment and land use.
• Define drainage areas and the volumes, rates, and paths of stormwater runoff.
• Identify areas and elevations for stormwater storage adequate to meet performance standards
established in the watershed plan.
• Define water quality and water quality protection methods adequate to meet performance
standards established in the watershed plan.
• Identify regulated areas.
• Set forth an implementation program, including a description of official controls and, as
appropriate, a capital improvement program.
. In this section, a new paragraph will also be added:
"The District will periodically review LGU compliance with the goals, policies, and requirements
established in this Plan. This action will include:
• Evaluation of the status of local water plan adoption and local implementation of activities
• Review of LGU ordinance revisions addressing management of water resources, including
enforcement in 2023 and 2024 (implementation item number 3)
If review of LGU practices reveals implementation inconsistent with this Plan, the District will take
administrative or legal action to ensure that District rules and policies are being implemented by
the LGU "
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CMSCWD 2022‐2031 Watershed Management Plan and Rule Revision ‐Response to Public Comment November 29, 2021
70 BWSR Melissa King VI.F.
Table 6‐
3
Section VI.F. Planned implementation actions need to correlate to the goals they are intended
to address, including specific lake and stream water quality goals. All overarching water quality
goals are generally identified to be addressed; however, the noted measurable outputs and
outcomes do not correspond to all the overarching goals.
YNY
Issue and goal statements are referenced for each of the planned activities. Pollutant reduction
goals for lakes and streams are included, where applicable within Table 6‐3. Pollutant reduction
expected during the life of the plan for each waterbody will be added in a new column in Table 5‐
2. Further, total pollutant reductions expected across the entire watershed resulting from the
implementation of all planned activities will be reported where appropriate in the Plan.
71 BWSR Melissa King VI.F.
Table 6‐
3
Section VI.F. Eleven of the 72 identified implementation actions were identified as “Currently
not planned to be completed” although completion of some of these actions and measurable
outcomes were identified as outcomes elsewhere in the Plan, and regardless of assigned
priority. The implementation and capital
improvement program should identify those actions the District intends to accomplish for the
life of the Plan. Completion of planned implementation activities dependent on receiving new
or grant funding sources may be identified, but actions that the District does not intend to
implement should not be included in the Plan.
NYY
Because there is not enough funding to accomplish all activities, the District prioritized activities as
shown the priority level column in Table 6‐3 as A, B, or C. All activities assigned an "A" priority level
are funded as well as many "B" priority level activities. Some "B" level and all "C" level activities
are currently unfunded. As noted in response to comments #58 and #61 above, if funding or ample
partnerships become available, currently unfunded activities may be completed. Text in Table 6‐3
will be revised from "not planned to be completed" to "Currently no funding identified. This
activity may be completed as partnerships and funding is available."
Column title in Table 6‐3 will be changed from "draft priority" to "priority level"
72 BWSR Melissa King VI.F.
Table 6‐
3
Section VI.F. Review table information to ensure that priority is assigned to each activity,
activities and measurable outcomes/outputs relate back to the goals achieved, and that
proposed actions and outcomes are consistent with information presented elsewhere in the
Plan. Examples of inconsistencies identified include:
a. Phosphorous load reduction outcomes that differ from those identified in Table 5‐2.
b. Proposed monitoring activities and budgets that differ from those presented in the proposed
monitoring plan in Appendix B.
c. Stream health, water quality and wetland restoration outcomes that differ from or have not
been previously identified (i.e., stream water quality, bacteria impairments, etc.).
YNY
The Plan will be revised with additional information on the total amount of pollutant reduction
expected across the entire watershed resulting from the implementation of all planned activities.
Appendix B will be revised so that budgets correspond to those in Table 6‐3.
Tables 5‐2 will be updated to include pollutant load reductions expected for each lake during the
life of the Plan.
Table 5‐3 will be updated to include information on impaired waters.
Consistency among all references and outcomes will be checked and revised, as needed.
Priority levels will be assigned for items missing priorities.
73 BWSR Melissa King VII Section VII, Amendments A‐D. Revise for consistency with MN Rule 8410.0140 Subp. 2. N Y Y
The Plan will be revised in to include a provision stating "the amendments are not necessary to
make the plan consistent with an approved and adopted county groundwater plan."
74 BWSR Melissa King App A Sec 6.3 21
6.3 Wetlands, Page 21. Revise the plan reference date. The wetland plan included in Appendix D
is dated 2010.N Y Y Appendix A will be updated as recommended.
75 BWSR Melissa King App A Sec 6.4 23
6.4 Impaired Waters, Page 23. Update this section, impairments listed are not current.
Completion of a TMDL for Barker Lake has not been previously identified. Please provide
clarification regarding entity leading this work. If the District will be completing the TMDL, this
needs to be reflected in the implementation section.
NYY
Appendix A will be updated to:
Add a summary table of the 2020 Impaired waters list.
Update text to clarify which water bodies were in which TMDL
Add a note that there are not efforts under way to develop TMDLs for the impaired water bodies
that have not yet been addressed in the 2 TMDLs
76 BWSR Melissa King App A Sec 9.6 48
9.6 Groundwater Studies, pages 48‐49. 14 District Study Inventory, pages 64‐67. These sections
should be updated with current studies and information.NYY
Appendix A will be updated to:
Replace the summary of 2003 Groundwater Plan with a summary of the Wash Co 2014‐2024
Groundwater plan and
Add information on District studies completed since 2010 and weblinks for studies available on the
District website.
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CMSCWD 2022‐2031 Watershed Management Plan and Rule Revision ‐Response to Public Comment November 29, 2021
77 BWSR Melissa King App A Sec 10
10 Monitoring. Tables do not appear updated based on the dates provided for years monitored
and the proposed monitoring plan included in Appendix B. Provide a summary of water quality
and quantity trends at key locations (MN Rule 8410.0060 Subp. 1.F).
NNN
The monitoring tables in Section 10 of Appendix A are up to date. There has not been a significant
amount of stream monitoring in recent years. 10‐year trends for lake water quality are identified
in Table 5.1. Insufficient data has been collected to identify trends on streams. Tables will be
reviewed and updated and trend analysis will be added.
78 BWSR Melissa King App A Sec 11 11 Land Cover and Public Utilities. Identify development proposed in local comprehensive plans
(Mn Rule 8410.0060 Subp. 1.L).NYYWill add map of 2040 land use and text explaining that no specific locations for development were
provided in comp plans
79 BWSR Melissa King App A Sec 15 15 Status of Local Comprehensive Plans. Update with current information and review for
consistency with Section VI.E.ii.N Y Y Appendix A will be updated as recommended.
80 BWSR Melissa King App A Table A‐
17
Table A‐17. Add data where missing. Review for consistency with Table A‐12 and Table 5‐1.
Stream monitoring efforts should also be summarized (see comment 37d).N Y Y Lake data is not missing and is consistent with the main body of the plan.
81 BWSR Melissa King App B
Appendix B Lake and Stream Monitoring Plans. Budgets noted for stream monitoring differ from
those identified in Table 6‐3. Please clarify those monitoring activities the District expects to
conduct.
N Y Y Appendix B will be updated as recommended.
82 BWSR Melissa King App F
Appendix F Draft Watershed Rules. It is recommended that the District not incorporate a
detailed draft of proposed watershed rule revisions or the approved watershed rules directly
into the Plan. The process and
timeframe required for a rule revision is separate and different from that to update and amend
the District’s Plan. Updates to documents currently included in the Plan appendices, would
require a Plan amendment per MN Rule 8410.0140 to bring the Plan current when a referenced
document is updated. This information may be more easily incorporated into the Plan by
reference with a weblink to the reference document on the District’s website and would not
require a Plan amendment if/once a document is updated.
YNYAppendix F (Rules) will be removed from the Plan. The Plan will instead reference District Rules
through a weblink.
83 CAC Pam Arnold
The 10‐year CMSC Watershed Management Plan is a stunning resource. As a plan, it is
visionary…offering information, resources and structure that will guide important deliberations
and discussions at all levels with clarity. This plan is a beautiful example of what representative
leadership should be. A resident of Scandia I feel proud to be involved with–and to live in–such
a progressive Watershed District. I love this beautiful watershed so much, but believe that as a
resident I have a responsibility to live here as a steward, a keeper of hugely significant resources
that none of us owns but which all of us has the ability to improve—and the potential to
squander. The Carnelian Marine St Croix Watershed District has authored a plan for the future.
And it is a powerfully inclusive plan. I sincerely hope that it is adopted, and that all of us value
the quality of its leadership, integrity, and knowledge. We are so fortunate.
YNNThank you! The District looks forward to continuing its work with the CAC and other residents of
the watershed!
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