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r~ -. _ ~~, =_ May 31, 2000 Mr. Karl P. Keel, P.E. Grass Lake WMO Technical Staff 2660 Civic Center Drive Roseville, MN 55113 RE: Draft 2000 TMDL List Comments Dear Mr. Keel: k r ~S ~ ~,~~ Thank you for your letter, which we received Apri127, 2000, regarding the 2000 draft Total Maximum Daily Load (TMDL) list. Your letter contained three main concerns: appropriate designated uses; where data could come from; and inconsistent listings. Although your letter was dated after the comment period ended, it was similar to several other letters we received. We are glad to be able to clear up some areas of confusion regarding our lakes and wetlands. A number of people wrote in questioning the appropriateness of having swimming as a designated use for lakes and wetlands. Firstly, all lakes and wetlands are `waters of the state'. Minn. R. Ch. 7050.0430 can be paraphrased as follows: All surface waters of the state that are not listed and that are not wetlands are classified as Class 2B, 3B, 4A, 4B, 5, and 6 waters. Similarly, Minn. R. Ch. 7050.0425 can be paraphrased as follows: Those waters of the state that are wetlands and that are not listed are classified as Class 2D, 3D, 4C, 5, and 6 waters. Minn. R. Ch. 7050.0222, subp. 4 defines Class 2B waters as follows: "The quality of Class 2B surface waters shall be such as to permit the propagation and maintenance of a healthy community of cool or warm water sport or commercial fish and associated aquatic life, and their habitats. These waters shall be suitable for aquatic recreation of all kinds, including bathing, for which the waters may be usable. This class of surface water is not protected as a source of drinking water...." In addition to this narrative, water quality standards (`vVQS), there is a numeric WQS for fecal coliform which further protects this resource for swimming. Minn. R. Ch. 7050.0222, subp. 6 defines Class 2D wetlands as follows: "The quality of Class 2D wetlands shall be such as to permit the propagation and maintenance of a healthy community of aquatic and terrestrial species indigenous to wetlands, and their habitats. Wetlands also add to the biological diversity of the landscape. These waters shall be suitable for boating and other forms of aquatic recreation for which the wetland may be usable...." In addition to this narrative WQS, there is a numeric WQS for fecal coliform which further protects this resource for swimming, through the linkage to Class 2B also specified in the narrative WQS. All of the lakes and wetlands listed in the 2000 draft TMDL list fit into these categories and thus protected for swimming. Please note that restoring lakes to "fishable" and "swimmable" are also major goals of the Clean Water Act. That said, however, we fully understand that multiple uses of urban lakes and that shallow urban lakes may not be representative of most lakes in the North Central Hardwood Forest (NCHF) ecoregion. We recognize that the NCHF goal of 40 micrograms TP/L may not be 520 Lafayette Rd. N.; St. Paul, MN 55155-4194; (651 } 296-6300 (Voice); (651 } 292-5332 (TTY) St. Paula Brainerd =Detroit Lakes Duluth Mankato Marshall a Rochester e Willmar; www.pca.state.mn.us Equal Opportunity Employer ~ Printed on recycled paper containing at least 20% fibers from paper recycled by consumers.