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September 6, 2011 Camillla Correll, Project Manager Emmons & Olivier Resources, Inc. 651 Hale Ave North Oakdale, MN 55128 RE: 60 -day review of Grass Lake Watershed Management Organization 2011 Plan Dear Ms. Correll, Board of Water and Soil Resources staff have completed the 60 -day review of the Grass Lake Watershed Management Organization Watershed Management Plan and have the following comments. 1.0 Executive Summary • Page 4: include a reference to the GLWMO website. • Page 9, Stormwater Management; and page 128, 6.3.3 Stormwater Management: for consistency with 5.2.4, revise the last sentence to be definitive that the permitting authority will remain (rather than 'would like') with member communities and the WMO has provided standards within the plan. • Page 10, GLWMO Standards and Criteria: clarify if this plan addresses the need for more protective standards or if it simply identifies the need. • Page 11, Financing: VLAWMO does not have taxing authority. 3.0 Land and Water Resource Inventory • Page 13, 4 t paragraph and Regulatory and Non - regulatory Framework pages 86 and page 89: the Ramsey County Groundwater Protection Plan referenced was drafted in 2009, but has not been approved by BWSR or adopted by Ramsey County. Suggest labeling it as a draft. 4.0 Regulatory and Non - regulatory Framework • Pages 77 -79: while inclusion of purposes and general goals from earlier plans provides context, it also creates confusion with what the current purposes of are. We suggest revising the text to include only current priorities. • Page 82: suggest removing the summary of 2009 WCA changes; additional changes have been put in to place since 2009 and it is likely more changes will be made over the life of this plan. 5.0 Management Standards • Page 91, first paragraph: this section suggests the previous plan was not effective, but does not provide an assessment of what was achieved or analysis of why the plan was not effective nor