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Metropolitan Council Environmental Services August 26, 2011 Ms_ Melissa Lewis Board of Water and Soil Resources 520 Lafayette Road North St. Paul, MN 55155 RE: Grass Lake Watershed Management Plan — June 2011 Referral File No. 20873 -1 Dear Ms. Lewis: Metropolitan Council staff has reviewed the draft Grass Lake Watershed Management Plan dated June 2011. The draft plan proposes many additional future studies and planning efforts, identifies few priorities, and lacks identification or targeting of structural practices to be put in place to resolve issues identified in the plan. The plan lacks clearly identifiable activities associated with the goals of the plan. Therefore, it is difficult to determine whether or not the goals of the plan will be met in the future and whether or not the draft plan will be effective. The draft plan proposes two funding options. Option l reflects an activity level over the next ten years given the existing financial structure of the watershed. Option 2 reflects a more proactive approach which is based on the identified needs of the water resources in the watershed. Option 2 raises almost $1 million more in revenue over a ten year period. While Option 2 is a very ambitious undertaking, it clearly does a better job of addressing the water resource needs identified in the needs assessment completed as part of the plan preparation than Option 1. However, it is still unclear whether or not there is sufficient or a consistent funding mechanism in order to implement the scale of proposed water monitoring or education and public outreach. Finally, after the 2011 plan is adopted, the WMO Board of Commissioners plans to evaluate the governance structure and financing mechanisms for the WMO. This type of assessment should have been completed prior to this plan being prepared and submitted for approval. Until such a study is completed it is extremely difficult to comment on the effectiveness of the plan. Due to the facts that this is a third generation watershed plan and that this plan clearly lacks critical elements of typical third generation plans, Council staff finds that the plan is not consistent with Council's Water Resources Management Policy Plan, and recommends that BWSR not approve the plan as written. If you have any questions please contact Judy Sventek, 651- 602 -1156. Sincowly, ilium G. Moore General Manager WM: jlf vlh�� CC: Karen Eckman, Chair Grass Lake WMO John Doan, Metropolitan Council District 10 Keith Buttleman, Assistant General Manager, MCES, Environmental Quality Assurance Dept. Lisa Barajas, Metropolitan Council Sector Representative www.metrocoundLorg 390 Robert Street North • St. Paul, MN 55101 -1805 • (651) 602 -1005 • Fax (651) 602 -1477 • TTY (651) 291 -0904 - FT-I Opportunity Emptay-