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GRASS LAKE WATER MANAGEMENT ORGANIZATION 2660 Civic Center Drive .Roseville, Minnesota .55113 Apri127, 2000 Howard D. Markus, Ph. D., P.E. TMDL Coordinator Environmental Outcomes Section Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4196 RE: Proposed Rules Regarding the Listing of Impaired Waters Dear Dr. Markus: The Grass Lake Watershed Management Organization (GLWMO) operates as a joint powers organization that manages water resources in a portion of the Cities of Shoreview and Roseville in Ramsey County. Our Board, at its March 23, 2000 meeting, discussed proposed changes to MPCA rules governing the listing of impaired waters as required by Section 303(d) of the Federal Clean Water Act. The following is a summary of the Board's comments and concerns. Determination of "Designated Use" We understand the federal law requiring the listing of water bodies that do not meet designated uses. We have concern regarding the MPCA's proposed designation of "Swimmable Use" as the designated use for all water bodies in Minnesota. The GLWMO, like most watershed organizations, classifies its water bodies by intended use. Not all water bodies are planned for full body contact. It is understood that some water bodies serve to collect nutrients upstream of higher classified water bodies and that some, because of their morphology, will never be able to maintain a "swimmable use" water quality. We feel that the "swimmable use" standard proposed is not only unrealistic but also unwise considering that individual water bodies function within a much more complex watershed district. The "Designated Use" should be selected based on a given watershed management organization's classification system and water quality goals. • Waterbodies included on list We understand that any water body, regardless of size or type, could potentially be included on the list if it's water quality does not meet the "swimmable use" criteria and if water quality samples have been taken. By this standard, any group wishing to improve a water body, be it a wetland, stormwater pond or lake, could collect a modest number of samples and force a large public expenditure to study and improve water quality -- even if such improvements are unrealistic or unwarranted. This potentially could hamper the public's ability to prioritize the scarce resources available for water resource management and drive