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implementation based on political participation rather than sound technical judgement. Inconsistent Listin Two water bodies in the GLWMO aze proposed to be added to the list -- Lake Owasso and Bennett Lake. Lake Owasso is a major resource in our community and supports a full range of recreational uses. It is proposed to be classified as a Category I Lake (supports direct contact recreational activities) in our second-generation plan. Bennett Lake, on the other hand, is a small, very shallow water body that will be classified as a Category II Water Body (supports indirect contact recreational activities). Our data shows significant improvement in the water quality of Lake Owasso over the past decade. In 1999, the average summer phosphorus concentration was 32 ug/L -- rather good when compared to other lakes and water bodies in our community. In fact, a quick scan of the "1999 Study of the Water Quality of 113 Metropolitan Area Lakes" published by the Metropolitan Council identifies numerous water bodies with significantly worse water quality than Lake Owasso that are not included on the proposed list. The purpose of this comment is not to suggest that Lake Owasso should not receive additional attention. Rather, it is to recognize that other similar or more degraded water bodies aze not listed. Overall, the GLWMO supports the MPCA's proposal to expand the criteria used to develop the List of Impacted waters to include excess nutrients. We aze concerned, however, that the proposed criteria may result in a list that is overly large and inconsistent when compared to all water bodies in Minnesota. Such an expanded list could unrealistically raise public expectations and cause already scarce resources to be further diluted. Thank you for the opportunity to comment on the proposed rules. Please contact me at (651) 490-2220 if you would like to discuss these comments or the proposed rules in more detail. Sinc rely, Karl P. Keel, P.E. GLWMO Technical Staff