To: Jeff Risberg (MPCA) From: Keith Hanson (Clean Water Council Member) Subject: Preliminary Draft of FY14/15 Budget Recommendation Date: Revised August 9, 2012 c: Marilyn Bernhardson; Scott Hoese

As requested by the BOC, I met with the business community yesterday to receive feedback on the

preliminary BOC budget recommendation.

Below is a summary of the feedback I received.

• There is agreement with the Council priorities for FY14/15 funding.

• There is agreement that the priority for funding should be; meeting the state’s watershed approach, direct funding towards implementation activities and to boot local capacity

• It was the opinion of those in attendance that funding groundwater quantity is a not a statutory requirement.

• There is agreement that building local capacity needs to be explored and funded.

• Monitoring and Assessment. There is agreement with the BOC recommendations. Funding for the DNR‘s Lake IBI assessment should be at the $2.9M.

• Watershed Restoration and Protection Strategies. Agreement with the BOC recommendations – fully funded.

• Groundwater and Drinking Water. Groundwater quantity funding should be eliminated as the feeling is quantity is not a Clean Water fund activity under the current statute (this will impact the DNR and MC budget requests). Agreement that DNR water appropriation electronic permitting and MDH Beach Monitoring should not be funded with Clean Water funds. Agreement that the CEC program should be scaled back.

• Nonpoint Source Implementation. Consideration should be given to combining the MPCA and BSWR Clean Water Partnership programs, likely into BWSR (a reduction in total expenditures may be possible through elimination of administrative costs. Consideration could be given to reducing the AgBMP Loan Program to $2M. Agreement that funding for the MN Ag WQ Certification Program is premature (details need to be further developed and federal funds are possible.). Consideration should be given to scaling back the BWSR programs.

• Education and Civic Engagement. Agree that civic engagement should be incorporated into other activities. Agree that manure applicator education should be incorporated into other activities.

• Applied Research and Tool Development. It was noted the BOC recommendations on each agency database improvements were not consistent, MPCA and MDA are funded and DNR was not funded (recommend to restore DNR funding). Recommendation is to fund the individual database requests and not fund the interagency water database and portal development. Portal should be funded through

other funding sources (e.g., LCCMR). Agree with the BOC recommendation that the MPCA application of water quality standards not be funded, this not part of the core agency responsibilities and other organizations are addressing this issue. County geologic atlas could be funded through LCCMR.

• Point Source Implementation. Agree with BOC recommendations.

• Clean Water Council Budget. Agree with BOC recommendations.

Keith

To: Jeff Risberg (MPCA) From: Keith Hanson (Clean Water Council Member) Subject: Preliminary Draft of FY14/15 Budget Recommendation Date: August 2, 2012 Project: AC030800.12 MCR 800

c: Marilyn Bernhardson; Scott Hoese

X:\Agency_Files\Water\Impaired Waters\Clean Water Council\Meetings\Committee Meetings\Budget & Outcomes Committee\2012\8-3-

2012\To be copied\Stakeholder comments\01_2012-08-02 Business Community on BOC

Recommendations.docx

AgBMP Loan Program to $2M. Agreement that funding for the MN Ag WQ Certification Program is premature (details need to be further developed and federal funds are possible.). Consideration should be given to scaling back the BWSR programs.

• Education and Civic Engagement. Agree that civic engagement should be incorporated into other activities. Agree that manure applicator education should be incorporated into other activities.

• Applied Research and Tool Development. It was noted the BOC recommendations on each agency database improvements were not consistent, MPCA and MDA are funded and DNR was not funded (recommend to restore DNR funding). Recommendation is to fund the individual database requests and not fund the interagency water database and portal development. Portal should be funded through other funding sources (e.g., LCCMR). Agree with the BOC recommendation that the MPCA application of water quality standards not be funded, this not part of the core agency responsibilities and other organizations are addressing this issue. County geologic atlas could be funded through LCCMR.

• Point Source Implementation. Agree with BOC recommendations.

• Clean Water Council Budget. Agree with BOC recommendations.

Local Water Government RoundtableStatement of Position and Support: Clean Water Fund

August 2012

The AMC/MAWD/MASWCD Local Water Government Roundtable is an affiliation of three of Minnesota’s keylocal government players in the planning and preservation of our state’s water resources. The threeorganizations have chosen to work together to improve communication and understanding of the roles andresponsibilities that we share in this vital task. Our shared vision is to manage water resources in such ways asto effectively balance the sometimes competing interests of water quality, water quantity and resourceutilization. Our organizations and our members are committed to collaborative efforts within the Roundtableand with those organizations that share these same goals, objectives and responsibilities.

Passage of the Clean Water Legacy Act and the Minnesota Outdoor Heritage, Clean Water, Parks and Trails, andArts and Cultural Heritage Constitutional Amendment has provided our state and its citizens with bothtremendous opportunity and accompanying challenges. As stewards of Minnesota’s natural resources, theRoundtable supports the efforts of Clean Water Council (CWC) to provide guidance to the Governor andLegislature on state programs to restore and protect Minnesota’s waters.

To that end, the Local Water Government Roundtable has indentified principles we believe are essential tomaximize available Clean Water Fund resources. They are:

1. Emphasis should be on water quality. The funds directed towards the Amendment’s Clean Water Fundare earmarked to protect, enhance, and restore water quality in lakes, rivers streams, and groundwaterwith at least five percent of the fund spent to protect drinking water sources. Consequently, fundsdirected at protecting drinking water should focus on their quality.

2. Getting the job done on-the-ground is critical to meeting our goals. The Local Water GovernmentRoundtable strongly supports that the majority of Clean Water Funds are used for on-the-groundprojects and practices to reduce point and non-point sources of pollution.

3. Balanced approach for monitoring and assessment. Monitoring and assessment are key componentsof understanding the status of water quality in Minnesota. The Roundtable recommends thatmonitoring and assessment activities not outpace non-point restoration and protection activities. TheLocal Government Water Roundtable supports the continued implementation of the MPCA’s ten-yearwatershed monitoring cycle strategies and recommends that other Clean Water Fund monitoring effortsbe limited and coordinated through MPCA’s ten-year strategy.

4. Programmatic funding strategy rather than project specific funding whenever possible. The continueduse of programmatic funding promotes prioritization of projects and avoids an ad hoc, patchwork ofprojects that may not maximize limited resources that are used to improve water quality. Aprogrammatic approach promotes flexibility and efficiency in administration, accountability for results,and use of science-based criteria for decision making. Local governments are well positioned to meetthese standards and, importantly, show our citizens the value they derive from projects funded by theClean Water Fund.

5. Coordinated relationship between local water plans and thComprehensive Local Water Managemenmanagement plans that are based on local priorities. Local governmentuse authorities, are uniquely positioned to link many landsurface and groundwater protection and management. Local water plans are prepared and coordinatedwith existing local, state and federal effortsand objectives, and measurable outcomesimplementation of projects and strategies already identified.

6. Coordinated relationship between local government entities and state agenciesapplication. Land use decisions are made at the local government level.water conservation districts, and watershed districtsagencies should not duplicate the role ofWater Fund projects to reduceshould provide assistance, resources, technology and services to the local deliverypossible.

Please feel free to contact us for any additional information or if you have any questions.

Thank you

Jeff SpartzExecutive Director, AMC

Coordinated relationship between local water plans and the use of Clean Water Funds.Comprehensive Local Water Management is the adoption and implementation of local watermanagement plans that are based on local priorities. Local governments, with their planning and land

are uniquely positioned to link many land-use decisions with water quality goals forurface and groundwater protection and management. Local water plans are prepared and coordinated

federal efforts. These local plans focus on priority concerns, defined goalsand objectives, and measurable outcomes. Used in tandem, Clean Water Fundsimplementation of projects and strategies already identified.

Coordinated relationship between local government entities and state agencies. Land use decisions are made at the local government level. County government, soil and

water conservation districts, and watershed districts interface with citizens on a daily basisagencies should not duplicate the role of local government and their work with the landowners on

to reduce point and non-point sources of pollution. Instead, the state agenciesshould provide assistance, resources, technology and services to the local delivery

Please feel free to contact us for any additional information or if you have any questions.

LeAnn Buck Ray BohnExecutive Director, MASWCD Coordinator, MAWD

e use of Clean Water Funds.t is the adoption and implementation of local water

, with their planning and land-use decisions with water quality goals for

urface and groundwater protection and management. Local water plans are prepared and coordinated. These local plans focus on priority concerns, defined goals

Clean Water Funds can accelerate

for Clean Water Fundounty government, soil and

interface with citizens on a daily basis. Statewith the landowners on Clean. Instead, the state agencies

should provide assistance, resources, technology and services to the local delivery system whenever

Coordinator, MAWD

Local Water Government Roundtable Members

The Association of Minnesota Counties (AMC) is a voluntary association of Minnesota’s eighty-seven counties.The association provides a broad range of services that include lobbying the Minnesota Legislature; working withstate departments and agencies; and providing training and information to Minnesota County officials.

Contacts: Jeff Spartz, Executive Director, 125 Charles Ave, St. Paul MN 55103 ph 651-789-4325Annalee Garletz, Policy Analyst, 125 Charles Ave, St. Paul MN 55103, ph 651-789-4322

The Minnesota Association Soil and Water Conservation Districts (MASWCD) is a nonprofit organization whichexists to provide leadership and a common voice for Minnesota’s soil and water conservation districts and tomaintain a positive, results-oriented relationship with rule making agencies, partners and legislators; expandingeducation opportunities for the districts so they may carry out effective conservation programs.

Contacts: Dr. Kathryn K. Kelly, MASWCD President, Renville SWCD Supervisor, ph 320-333-6002LeAnn Buck, MASWCD Executive Director, 790 Cleveland Ave. So., Suite 201, St. Paul, MN 55116,ph 651-690-9028

The Minnesota Association of Watershed Districts (MAWD) provides educational opportunities, informationand training for watershed district managers and staff through yearly tours, meetings, workshops andnewsletters. MAWD provides a statewide focus to water quality and quantity management for its members, keypartners and decision makers across the state.

Contacts: Jerome Deal, MAWD President, manager, Bose De Sioux Watershed District, ph 320-563-8377

Ray Bohn, Coordinator, 540 Diffley Road, St. Paul, MN 55123, ph 651-452-8506

Minnesota Association of Soil and Water Conservation Districts790 Cleveland Avenue South, Suite 201

OFFICERS

PresidentDr. KATHRYN K. KELLY302 South 4th StreetOlivia, MN 56277(320) 333-6002

Vice PresidentMARK ZABEL8464 Pine CourtVictoria, MN 55386(952) 443-3116

Secretary – TreasurerTOM SCHULZ27027 County Road 23Sebeka, MN 56477(218) 837-5728

Executive DirectorLEANN BUCKSuite 201790 Cleveland Avenue SSt. Paul, MN 55116(651) 690-9028

DIRECTORS

Northwest Area 1KENNETH PEDERSON11574 380th Street SEFertile, MN 56540(218) 574-2740

West Central Area 2MIKE JORGENSON33626 - 660th AvenueClinton, MN 56225(320) 325-5369

Northeast Area 3KURT BECKSTROM17466 60th AvenueMilaca, MN 56353(320) 556-3403

Metropolitan Area 4MARY WETTER180 Ibarra Avenue SEBuffalo, MN 55313(763) 477-5723

Southwest Area 5IAN CUNNINGHAM565 81st StreetPipestone, MN 56164(507) 825-4268

South Central Area 6LOYAL FISHERPO Box 222Renville, MN 56284(320) 329-3925

Southeast Area 7ED MCNAMARA37299 171st AvenueGoodhue, MN 55027(651) 923-4777

North Central Area 8TOM SCHULZ27027 County Road 23Sebeka, MN 56477(218) 837-5728

IMMEDIATEPAST PRESIDENTSTEVEN SUNDERLAND2030 20th Avenue SEMontevideo, MN 56265(320)-269-9618

STAFF

Assistant DirectorSHEILA VANNEY

Administrative AssistantSTEFANIE MARTINEZ

Date: August 1, 2012To: Jeff RisbergFrom: Sheila Vanney, MASWCD Assistant DirectorSubject: MASWCD Comments Regarding BOC’s Preliminary

On behalf of the Minnesota Association of Soil and Water Conservation Districts (MASWCD),please accept the following comments regarding the BOC’s preliminary budget proposal forFY2014-2015 Clean Water Funds.Budget and Outcomes Committee. We appreciate the opportunity to provide this input.

General comments

Balanced approach for monitoring and assessment.key to understanding the status of water quaand assessment activitiesactivities. We support continued implementation of MPCA’s tenframework and recommend that other Clean Water Fund moniand coordinated through

Emphasis should be on water qualityClean Water Fund are earmarked to protect, enhance, and restore water quality inlakes, rivers streams, and groundwater with at least five percent of the fund spent toprotect drinking water sources.water should focus on their

Local capacity critical for getting the job done on the ground.adjustments/reductechnical capacity at the local level

Coordinated relationship between local government entities and state agenciesuse decisions are made at the local levemake these decisions ordirected to state agenclocal government. Instead, state agencies should provide assistance, resources,technology and services to the local delivery system whenever possible.

Coordinated relationship between local water plans and the use of Clean WaterFunds. Local water plans are prepared and coordinated with existing local, state andfederal efforts.objectives, and measurable outcomes.water plans (and the implementation efforts outlined in them) and WatershedRestoration and Protection StrategiUsed in tandem, Clean Water Funds can accelerate implementation of projects andstrategies already identified

Civic engagementengagement, as we are

Minnesota Association of Soil and Water Conservation Districts790 Cleveland Avenue South, Suite 201, St. Paul, MN 55116 651-690-9028 www

August 1, 2012Jeff Risberg, Interim Administrator, Clean Water CouncilSheila Vanney, MASWCD Assistant DirectorMASWCD Comments Regarding BOC’s Preliminary Budget Proposal

On behalf of the Minnesota Association of Soil and Water Conservation Districts (MASWCD),please accept the following comments regarding the BOC’s preliminary budget proposal for

2015 Clean Water Funds. Thank you in advance for sharing our comments with theBudget and Outcomes Committee. We appreciate the opportunity to provide this input.

General comments:

Balanced approach for monitoring and assessment. Monitoring and assessment areunderstanding the status of water quality in Minnesota. However,

and assessment activities should not outpace non-point restoration and protectionsupport continued implementation of MPCA’s ten-year watershed

and recommend that other Clean Water Fund monitoring efforts be limitedand coordinated through this framework within MPCA.

Emphasis should be on water quality. The funds directed towards the Amendment’sClean Water Fund are earmarked to protect, enhance, and restore water quality in

reams, and groundwater with at least five percent of the fund spent toprotect drinking water sources. Consequently, funds directed at protecting drinkingwater should focus on their quality.

Local capacity critical for getting the job done on the ground. Overall,/reductions need to be made to allow for funds to go to

technical capacity at the local level.

Coordinated relationship between local government entities and state agenciesuse decisions are made at the local level. SWCDs interface daily with

these decisions or are being impacted by them. Clean Water Funds should not betate agency efforts that would duplicate the role of SWCDs or other units of

local government. Instead, state agencies should provide assistance, resources,technology and services to the local delivery system whenever possible.

Coordinated relationship between local water plans and the use of Clean WaterLocal water plans are prepared and coordinated with existing local, state and

federal efforts. These local plans focus on priority concerns, defined goals andobjectives, and measurable outcomes. A link needs to be established between localwater plans (and the implementation efforts outlined in them) and WatershedRestoration and Protection Strategies (WRAPS) funded through the Clean Water FundUsed in tandem, Clean Water Funds can accelerate implementation of projects andstrategies already identified.

engagement. We are intentionally silent right now on the issue of civicengagement, as we are not sure how to fit that in to the budget recommendations.

page 1 of 2

Minnesota Association of Soil and Water Conservation Districtswww.maswcd.org

Clean Water Council

Budget Proposal

On behalf of the Minnesota Association of Soil and Water Conservation Districts (MASWCD),please accept the following comments regarding the BOC’s preliminary budget proposal for

ring our comments with theBudget and Outcomes Committee. We appreciate the opportunity to provide this input.

Monitoring and assessment areHowever, monitoring

point restoration and protectionyear watershed

toring efforts be limited

. The funds directed towards the Amendment’sClean Water Fund are earmarked to protect, enhance, and restore water quality in

reams, and groundwater with at least five percent of the fund spent toConsequently, funds directed at protecting drinking

verall,to go toward enhancing

Coordinated relationship between local government entities and state agencies. Landwith the citizens who

Clean Water Funds should not beSWCDs or other units of

local government. Instead, state agencies should provide assistance, resources,technology and services to the local delivery system whenever possible.

Coordinated relationship between local water plans and the use of Clean WaterLocal water plans are prepared and coordinated with existing local, state and

ese local plans focus on priority concerns, defined goals andA link needs to be established between local

water plans (and the implementation efforts outlined in them) and Watershedes (WRAPS) funded through the Clean Water Fund.

Used in tandem, Clean Water Funds can accelerate implementation of projects and

are intentionally silent right now on the issue of civicbudget recommendations.

page 2 of 2

Specific comments by budget category:

Monitoring and Assessment

MPCA efforts to meet the ten year cycle should be priority of this category.

MPCA is obvious lead on monitoring and assessment, and all monitoring and assessment funds should run throughMPCA’s 10 year cycle to ensure accountability toward those goals.

Reduce funds for other work in this category (i.e., DNR assessment stream flow monitoring, lake IBI assessment, fishmercury assessment. If this work is needed for 10 year cycle, MPCA can subcontract/shift funds to DNR out of theirMPCA allocation.

Watershed Restoration/Protection Strategies

Again, MPCA is obvious lead on WRAPS at state level and all WRAPS funds should run through MPCA to ensureaccountability toward meeting the goals of the 10 year watershed approach framework.

Reduce funds for DNR TMDL development and implementation. If this work is needed for 10 year cycle, MPCA cansubcontract/shift funds to DNR out of their MPCA allocation.

Groundwater/Drinking Water

Remove items relating to water supply (quantity), as they do not fit the water quality mission of the Clean Water Fund.

BWSR wellhead protection easements going from 2.6M to 3.6M is a significant increase (almost 40%) – this may be anarea where reductions can be made.

MDH well sealing cost-share – It is unclear why this is a separate line-item through MDH, as this an eligible cost-shareitem through BWSR grants.

Nonpoint Source Implementation

MPCA Clean Water Partnership (CWP) is a supplant issue. In addition, it continues to be unclear how this is differentthan BWSR implementation programs. Remove this line item and shift the funds to BWSR or use the funds for the localtechnical capacity outlined below.

Funds for MDA AgBMP are too high (even though proposal decreases them significantly from last biennium). Interestrates in the private sector are low and provide adequate opportunities, along with the funds that continue to revolve inthe fund.

MDA technical assistance research. Technical assistance is the job of SWCDs. The research may be fundable throughLCCMR.

BWSR riparian buffers going from 12M to 16M is a significant jump (33% increase). We recognize that this is anextremely valuable program that combines LSOHC habitat and CWF water dollars on a practice that clearlyaccomplishes multiple benefits, but we question whether such an increase is warranted at this time.

BWSR community partners going from 3M to 5M is a significant jump (66% increase) to a program that has yet gottenoff the ground and shown marked success. Outreach to nonprofit organizations at the local level is valuable, but thiscould be an area to keep at level funding until it has shown a need for an increase, especially given that these activitiesare also eligible for BWSR clean water assistance grants.

ADD: $4.5M for local SWCD/LGU implementation of Wetland Restoration and Protections Strategies (WRAPS) asthey tie in to local water management plans. This would include:

Providing technical assistance on impaired waters issues.

Ensuring current and accurate technical information on conservation practices is provided to farmers and otherend users and promoting adoption of BMPs (targeting conservation to critical areas)

Providing support for targeting conservation efforts, designing and implementing projects, and buildingcommunity capacity to manage for healthy watersheds.

Please note: When setting up allocation criteria for such a program, consideration should be given to the factthat SWCDs are the only local government units in this arena that do not have an independent means of raisingtheir own revenue and therefore are more limited than others in the ability to fund technical capacity.

Applied Research and Tool Development

MDA academic research/evaluation. Could the research be funded through LCCMR?

DNR shoreland stewardship, biomonitoring database. This may be an area where reductions can be made. Workingwith landowners on shoreland stewardship is a task of SWCDs, and the monitoring belongs in category 1 under purviewof MPCA.

DNR county geologic atlases. It is unclear whether this might be a supplant issue.

Page 1 of 9

Minnesota Cities Stormwater Coalition Municipal stormwater professionals working together for clean water

Steering Committee:

2011 – 2014 Term:

Scott Anderson City of Bloomington

Matt Durand City of Owatonna

Jim Hafner (Chair) City of Blaine

John Paulson City of Hutchinson

Chris Kleist City of Duluth

2009 – 2012 Term:

Andy Bradshaw City of Moorhead

Rebecca Haug City of Elk River

Anne Weber (Vice Chair) City of St. Paul

2010 – 2013 Term:

Sharon Doucette City of Woodbury

Paul Drotos City of Red Wing

Cara Geheren City of Victoria

Staff:

Randy Neprash, P.E. Stantec 2335 West Highway 36 St. Paul, MN 55113 (651) 604-4703 randy.neprash@stantec.com

MCSC is an affiliate of the League of Minnesota Cities

Keith Hanson Chair, Clean Water Council

Marilyn Bernhardson

Co-Chair, Budget and Outcomes, Clean Water Council

Scott Hoese Co-Chair, Budget and Outcomes Committee, Clean Water Council

August 1, 2012

Ms. Bernhardson, Mr. Hoese, and Mr. Hanson: Thank you for your letter of June 4, 2012 requesting the top priorities of the Minnesota Cities Stormwater Coalition (MCSC) needed to address stormwater issues through the Clean Water Fund. We also wish to compliment the Clean Water Council on the memorandum dated July 17, 2012 from the Budget & Outcomes Committee. This memo is an excellent example of clarity and openness in the development of the CWC’s funding recommendations.

MCSC is comprised of approximately 100 cities that are regulated under the MS4 stormwater permitting program. Our top priorities for stormwater issues are as follows:

1. Complete the MIDS Project effectively - $400,000

Provide for outreach & training for local implementers

Complete the MIDS Project work related to linear and redevelopment projects

This work is not sufficiently funded under the MPCA’s proposal

2. Focus on the development of urban stormwater BMPs and quantifying their benefits - $2,100,000

This recommendation is based on similar funding for the MDA to address agricultural BMPs

The work to be done under this program should be organized and supervised by a consortium of state agencies and stormwater stakeholders (especially the Minnesota Stormwater Steering Committee)

This should address applied research, tool development, and technology transfer

3. Detailed performance/effectiveness monitoring for representative drainage areas throughout Minnesota – no immediate funding

MCSC Comments Page 2 of 9

Initiate the development of this program

In addition to and separate from assessment monitoring that is already funded under the MPCA’s proposal for “Continue monitoring & assessment efforts to meet the 10-year cycle”

Details 1. Complete the MIDS Project effectively - $400,000

The Minimal Impact Design Standards (MIDS) Project is an important next step in stormwater management and regulation in Minnesota. The regulated cities, along with a large number of other stakeholder organizations, have worked hard over the past two years to make progress on this project. As we evaluate the MPCA’s funding proposal to complete the MIDS Project, we find it deficient in two significant areas:

Insufficient support for outreach & training: Local governmental units, especially regulated cities, are the essential voluntary implementers of the MIDS Project work products. These products will be complex and challenging for the LGUs. A well-organized and comprehensive outreach and training component for the MIDS Project is vital to the success of the entire project. Without funding for this component, much of the work on the MIDS Project may be wasted.

Insufficient support for the completion of products for linear & redevelopment projects: There is currently a MIDS Project workgroup that has begun the development of the MIDS Project work products related to linear (road) and redevelopment projects. These types of projects are the most difficult to address in this context. It is expected that the regulatory pressure to address stormwater for these types of projects will increase with the issuance of the new Federal stormwater rule and the completion of additional TMDLs. This workgroup will require technical support in the form of work by contractors similar to the efforts for the rest of the MIDS Project.

2. Focus on the development of urban stormwater BMPs and quantifying their benefits -

$2,100,000

It appears that the CWC BOC is recommending funding the following item at $2,100,000: Academic Research/Evaluation: Projects focus on supporting the development of agricultural BMPs and quantifying agricultural contributions to impaired waters with a focus on gaining a better understanding of the processes that underlie these contributions. BMPs will be developed and evaluated to protect and restore water resources while maintaining productivity.

Similar work and funding is needed and appropriate in the context of urban stormwater. As we stated in the MCSC presentation to the CWC, the need for additional information and applier research related to urban stormwater BMPs is immense.

MCSC Comments Page 3 of 9

Compliance with TMDL Load Allocations remains voluntary for agricultural producers. For permitted cities, though, compliance with TMDL Waste Load Allocations (WLAs) is a legal requirement that is growing quickly. With just two recent draft TMDLs (S. Metro Mississippi River & Minnesota River TMDLs), the estimated cost for MS4 cities to achieve stormwater load reductions is more than $1 billion. This cost will increase significantly with:

the completion of more local and large-scale TMDLs

the issuance of the new Minnesota MS4 General Permit

the issuance of new Federal stormwater rules.

Three options should be considered when seeking available monies for this effort:

With the issuance of the two recent large-scale TMDLs, it has become apparent that adjustments are needed in the TMDL program, especially in the development of urban stormwater WLAs. Funding could be reallocated from TMDL development, resulting in an appropriate temporary slow-down in this program and allowing for a program evaluation and adjustment. Please see Comment B below.

Reallocate the funding recommended for the lake IBI assessment program.

If necessary, the allocation for agricultural BMPs could be split into equal agricultural and urban stormwater components.

Work on urban stormwater BMPs should include applied research, tool development, and technology transfer. This work should be done in conjunction with the stakeholders involved in urban stormwater, especially the Minnesota Stormwater Steering Committee.

3. Detailed performance/effectiveness monitoring for representative drainage areas

throughout Minnesota – no immediate funding

The MPCA is currently implementing a significant assessment monitoring program. This will evaluate the state of receiving water quality, but will not provide us with the information we need to better understand the performance and effectiveness of the billions of dollars’ worth of BMPs we are implementing in agricultural, rural, and urban settings. Performance/effectiveness monitoring is essential for the reasons listed below. We urge the CWC to initiate and support movement toward developing and implementing a state-wide performance/effectiveness monitoring program as soon as possible. Selection and detailed monitoring of a limited number of representative drainage areas statewide

not at the detail of evaluating individual BMPs

at the level where the impacts of types of BMPs can be evaluated

some drainage areas should be in the drainage areas of significant and challenging TMDLs

most drainage areas should include both urban and non-urban land

drainage areas must be selected carefully

this work will require considerable time and funding to do well

MCSC Comments Page 4 of 9

Reasons needed sector accountability

we must be able to determine whether different sectors are doing their share of the work toward improving water quality

without an approach like this, we will still be in a “finger pointing” anecdotal exercise after we reassess waters a decade from now

this monitoring will serve as the check or calibration for a credit system for urban and agricultural BMP implementation

this level of detailed monitoring is needed to establish appropriate levels of BMP implementation to make sufficient progress toward meeting WLA and LA goals and demonstrate their effectiveness

this level of monitoring is needed to determine which approaches and types of BMPs are most effective and cost-efficient, in urban and agricultural settings

this level of detailed monitoring is needed to implement phased, linked TMDL implementation plans

COMMENTS ON CWC BOC PRELIMINARY DRAFT FY14-15 BUDGET RECOMMENDATIONS SPECIFIC COMMENTS The BOC worksheet in the July 17 memo identified specific items for which “feedback is especially requested”. A. Lake IBI assessment: DNR and MPCA scientists are working together to develop an Index of

Biotic Integrity which requires data on aquatic plant and fish communities (especially nearshore nongame fish) across the state. This information will allow for a more holistic assessment of lake health, similar to the approach MPCA is now using for streams. ($2,900,000)

MCSC recommends that funding for this work be delayed. As noted, this work is similar to current work to develop and implement an IBI approach to assessing streams. We recently attended a stakeholder meeting for the stream IBI effort. The MPCA appears to making progress in this area, but there are currently many aspects of this program that are still unclear and need to be worked out. The stream IBI program should complete internal development, go through a stakeholder review process, and be piloted in several locations and used successfully in TMDLs. After that, the stream IBI program will be a valuable model for developing the lake IBI assessment program. We recommend that funding for the lake IBI effort be delayed until the stream IBI program is closer to completion and wide-spread implementation.

B. TMDL development: Fund TMDL projects and staff: Beginning in 2008, the MPCA launched a new “watershed approach” to systematically and comprehensively conduct the state’s water-quality monitoring, and restoration and protection planning needs on a 10-year cycle (10 percent of the state’s 81 major watersheds per year). As the assessment process is

MCSC Comments Page 5 of 9

completed in each watershed, TMDLs will be developed for impaired waters and protection strategies for unimpaired waters. These projects are called Watershed Restoration and Protection Strategies (WRAPs), and will set the reduction goals, milestones and measures to guide state and local government in their implementation efforts. Anticipated WRAP strategies will be underway in 45 of 81 watersheds by FY13. MPCA's work includes technical assistance to local government, review and preliminary approval of TMDLs and overall WRAPs , contract management, stressor identification, coordination with EPA and other state and federal agencies.

With the issuance of the two recent large-scale TMDLs, it has become apparent that adjustments are needed in the TMDL program, especially in the development of urban stormwater WLAs. Funding should be reallocated from TMDL development, resulting in an appropriate temporary slow-down in this program and allowing for a program evaluation and adjustment. TMDL WLAs create significant legal obligations for permitted MS4 cities. This is especially timely in light of new provisions in the draft MS4 general permit. MCSC recently approached MPCA with a request to discuss 26 items related to appropriate program changes TMDLs and stormwater permitting. We received a negative response to this request, while the issuance of the new draft MS4 permit and new draft TMDL reports have proceeded without any movement toward discussing or resolving any of our issues and concerns. TMDL development in Minnesota is faster than almost any other state in the country. This pace is probably more than sufficient to satisfy USEPA. In light of the legal obligations created by TMDLs for permitted MS4s, it is appropriate and necessary to temporarily slow down the production of new TMDLs and have some time for stakeholder engagement and program evaluation & adjustment.

C. Groundwater assessment: Continue to enhance ambient network, modeling to support TMDL stressor ID, continued effort to look for CECs in subset of monitoring wells.

MCSC supports this work and funding.

D. Enhanced county inspections / SSTS corrective actions: In state fiscal years 2014-15, the MPCA will continue to provide $1,500 per year/per county for SSTS funding, and requests that the Clean Water Fund supplement the County SSTS program implementation at $2.5 million per year, in addition to funding two MPCA SSTS staff positions.

MCSC supports SSTS work that directly addresses failing straight pipe systems and resolving the imminent danger they pose.

MCSC Comments Page 6 of 9

E. TMDL research and database development: Incrementally connect data management systems, and eventually develop a Watershed Portal that will interface with existing systems to provide staff with a central location for reporting, analysis, and data management of the watershed data.

Interagency water database and portal development: The Watershed Data Integration Project (WDIP) continues to improve the accessibility to a breadth of water-related data from multiple MPCA water programs. WDIP will continue for the next 2 biennia (state fiscal years 2014-17), at a cost of $2 million/biennium (plus inflationary increases). After state fiscal year 2017, WDIP will cease to operate as a stand-alone IT project, and will become incorporated into the overall MPCA IT budget for on-going maintenance. An interagency team has begun developing a watershed data portal concept. The portal would allow a user to access data from multiple agencies from one webpage, versus having to search multiple agencies’ websites. The project scope has been preliminarily narrowed to the ~30 highest priority data sources, but is still a very large undertaking. The creation of the portal is estimated at this time to be about $17 million over ten years. The initial request for state fiscal years 2014-15 would be $3 million of that total. It is remarkable that these proposed database development efforts are targeted only for staff and interagency use and access. The public and LGUs also need to be able to use and make actionable decisions based on this data. MCSC is also concerned that these needs extend beyond just the raw data. There is a great need for information on broad water quality trends over time.

F. Education and civic engagement total - Eliminate category and embed civic engagement into existing projects Commenting on public education and civic engagement is perilous these days. Recommendations are sometimes based on understandings and assumptions that we understand inadequately. MCSC’s first concerns are in the area of public education. A public that is well educated on the issues related to water quality protection and restoration is an absolutely essential requisite for progress in these areas. This concept has been expressed concretely in the fact that public education is one of the six Minimum Control Measures that must be addressed by every MS4 stormwater permittee, as per the MS4 General Permit. Stormwater public education is implemented by every permitted MS4 city but must also be supported at the state level. State support should take the form of funding support, technical support, development of educational resources and materials, and the support of state staff with specialized training and experience. As the permitting authority that imposes the requirements to address stormwater public education on MS4 cities, the State carries a significant responsibility to maintain this support. MCSC is disappointed to see that

MCSC Comments Page 7 of 9

water quality public education is not explicitly funded and supported in these CWC BOC recommendations. MCSC is also concerned about civic engagement, especially in the context of the TMDL program. We concur that civic engagement should be considered an essential element of and embedded in every TMDL and watershed project. We believe that the best work and most exciting innovations are the products of meaningful partnerships between TMDL & watershed project teams and local stakeholders. MCSC believes that the Clean Water Fund should help provide support for building and maintaining local stakeholder capacity. We also believe, though, that the State agencies have a significant role to play in this process. Rather than depending entirely on technical project staff to address civic engagement in TMDL & watershed projects, the State should maintain an institutional and inter-agency staff and program capacity for civic engagement. This capacity should include:

staff with specialized training and experience

maintain and communicate the institutional memory for civic engagement

establish and communicate project standards and protocols for civic engagement

establish and maintain project accountability and reporting systems for civic engagement

partner with stakeholder groups at the state level

develop a shared vision and strategies for civic engagement state-wide.

MCSC has seen the results of leaving civic engagement the responsibility of technical project staff on a project-by-project basis. Only considering public education and civic engagement as embedded elements in every project can lead to unfortunate and avoidable results, including:

Education and engagement functions are performed by technical project staff that are not trained, skilled, or interested in this work.

The agencies develop only extremely limited institutional knowledge and memory in these areas. Successes are not tracked. Lessons are not learned. Experience is not shared. Skills are not developed or valued.

Education and engagement become incidental functions with only very limited value. MCSC can provide multiple TMDL projects with education and engagement elements that are badly flawed and very inadequate. MCSC has commented on this in the past with no constructive response.

Education and engagement are approached at only the project level. No overarching strategies or programs are developed. Vital opportunities are lost.

MCSC strongly urges the CWC to reconsider the path set forth in these budget recommendations. The importance of public education and civic engagement cannot be overestimated. MCSC believes that the funding in this area should be at the high end of the $1.95 - $9.25 million range.

MCSC Comments Page 8 of 9

We urge the Clean Water Council to maintain and support institutional capacity within state agencies for public education and civic engagement. We recommend that the LGUs and other stakeholders be brought into this process in a more meaningful way. This is an essential element if the CWC is to meet its statutory goal under MN Statute 114D.35 Subd.3: “The Clean Water Council shall develop strategies for informing, educating, and encouraging the participation of citizens, stakeholders, and others regarding the identification of impaired waters, development of TMDL's, development of TMDL implementation plans, implementation of restoration for impaired waters, identification of degraded groundwater, and protection and restoration of groundwater resources.”

G. Clean Water Partnership: Provides grants to protect and improve the basins and watersheds of Minnesota; provides financial and technical assistance to study water bodies with non-point source pollution problems, develop action plans to address the problems, and plan implementation to fix the problems.

MCSC supports moving this program to BWSR.

GENERAL COMMENTS What should be the Council’s funding priorities in order to meet its budget targets?

Please see the Specific Comments above.

How can the Council’s budget help build local capacity to more effectively deliver existing programs?

MCSC commends the CWC for listing this as a key budget issues. MCSC agrees completely that local capacity is key to achieving real water quality protection and improvements. Please see our Specific Comments above for some of our thoughts in this area. MCSC believes that building local capacity is a more complex and long-term project than can be addressed in this funding allocation exercise. We urge the CWC to form a committee to address this issue. MCSC stands ready to work closely with this committee to identify the critical program elements and insufficiencies as well as strategies to address them.

H. Groundwater/drinking water total - $23,636,000 This funding recommendation is 42% above the high end of the recommended funding range. MCSC questions the value here. MCSC is also concerned that there is no stormwater-related work or programs in this category, despite the facts that

a substantial portion of Minnesota’s drinking water comes from surface water sources, and

MCSC Comments Page 9 of 9

there is increased regulatory pressure promoting stormwater infiltration on a wide-spread basis, with poorly understood possible impacts on groundwater.

I. Education and civic engagement - $200,000

MCSC is very concerned that this category is drastically underfunded. Please see Specific Comment F above.

J. Applied research and tool development

MCSC is concerned that this category is underfunded. MCSC is especially concerned that $5.55 million is recommended for non-urban work (Academic Research/Evaluation and Shoreland Stewardship) by the DNR while only $550,000 is recommended for urban stormwater work (Stormwater Research & Guidance) by MPCA. MCSC is concerned that the MPCA does not appear to be advocating for sufficient stormwater work. This is especially disturbing in light of new regulatory pressures being generated by TMDLs, permitting, and new Federal rules.

K. Point source implementation total

MCSC is concerned that this total is only 32% of the mid-point of the recommended funding range for this category. MCSC is also concerned that the existing grant programs are not working for city implementation projects. MCSC is interested in discussions with the CWC and the agencies to address this problem.

Thank you for the opportunity to comment on the CWC BOC Preliminary Draft FY14-15 Budget Recommendations. We wish you the best with your deliberations.

Jim Hafner Randy Neprash, P.E. Chair, Steering Committee Staff Minnesota Cities Stormwater Coalition Minnesota Cities Stormwater Coalition

Minnesota Stormwater Steering Committee top priority recommendation to the Clean Water Council: Approved 19 July 2012 1

1. Data and

Information

2. Evaluate

Performance

3. Refine Standards

4. Transfer & Implement

Systematically Develop BMP’s

Why?

Clean water requires imple-mentation of stormwater

Best Management Practices

(BMP’s).

We need the best and most cost effective BMP’s and get practitioners to apply them.

Minnesota Stormwater Steering Committee’s Recommendation to the Clean Water Council for ongoing annual investment of $600K 1. Enhance data and information management of stormwater

BMP’s

2. Evaluate BMP performance and effectiveness to support meeting TMDL’s

3. Develop standards and incorporate into state of the art guidance (e.g. Minnesota Stormwater Manual a “fabulous success story”), minimal impact design standards as the model.

4. Implement a knowledge and technology transfer system to more than 2,500 practitioners across LGU’s, Industry and Regulatory Sectors.

A science based process to inform decisions.

Minnesota Stormwater Steering Committee top priority recommendation to the Clean Water Council: Approved 19 July 2012 2

Data Evaluate

Refine Implement

Memorandum August 1, 2012 To: Clean Water Council Members From: Clean Water Fund (CWF) Interagency Coordination Team Members -

Linda Bruemmer, Minnesota Department of Health (MDH) Ali Elhassan, Metropolitan Council (Met Council) Rebecca Flood, Minnesota Pollution Control Agency (PCA) Jeff Freeman, Public Facilities Authority (PFA) Mary McConnell, Department of Natural Resources (DNR) Deb Swackhamer, University of Minnesota (U of M) Matt Wohlman, Minnesota Department of Agriculture (MDA) Steve Woods, Board of Water & Soil Resources (BWSR)

Subject: Draft FY2014-2015 Budget and Outcomes Committee (BOC) Budget Recommendations As you know, the Budget and Outcomes Committee (BOC) budget development process has taken place in advance of the state agencies’ budget submittal process to the Governor’s Office. We understand that the current BOC proposal will be altered through input from the entire Council, and through a public comment period. As the state agencies assemble their budgets for next biennium, some of our preliminary proposals submitted in May will likely change. We would like to propose that the Clean Water Fund (CWF) Interagency Coordination Team be given time on the August 19, 2012 agenda to present our budget priorities as a package. Additional information may be supplied for specific budget proposals where the BOC rationale stated that the information submitted was not sufficiently compelling. We will also provide supplemental information to address some misunderstandings about our proposals that appear to exist, based on our reading of the BOC rationale. Our intent is to identify the areas where we agree with the BOC recommendations, and identify areas where we think there needs to be more discussion to ensure a balanced approach in allocating $185 million of Clean Water Fund monies. A few examples of the areas that need more discussion are:

1. The challenge of lack of local capacity

· There is a need to look at how all efforts are being aligned to support implementation at the local level. How would the Clean Water Council propose to see that local capacity be sustained?

Clean Water Council Page 2 August 1, 2012

2. The 7/16/12 draft chart of Clean Water Fund-supported staffing (in FTE’s) by state agency · M.S. §114D.20, Subd. 3 states that the implementation policy is to “(2) maximize use of

available organizational, technical, and financial resources to perform sampling, monitoring, and other activities to identify degraded groundwater and impaired waters,”…

· The current work by the state agencies is consistent with maximizing use of available resources. The CWF was intended to accelerate the cleanup of our waters so additional work is being performed to support this effort and more staff are needed at all levels to do the work.

· The FTE chart may be misleading because it does not represent all of the work that is taking place. There are many hours of non-Clean Water funded work directed at projects to clean up our waters and deliver on-the-ground conservation more efficiently.

3. The Information Technology proposal for a portal. · The internet portal would give locals and the public access to water quality data in a central

location, making the data more accessible to everyone. We would like to discuss which direction the Council would like to pursue as an alternative to efficiently get information into the hands of the people working on projects in the field.

We appreciate the opportunity to discuss the BOC recommendations. We will continue to work collaboratively with the Council to help ensure we are closely aligned with and are supporting your goals as we move through the budget development process. CWFICTM:mkr

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Reilly, Mary (MPCA)

From: Deborah Swackhamer [dswack@umn.edu]Sent: Friday, July 13, 2012 2:22 PMTo: Lyman, Celine (MPCA)Cc: Bradley Kalk; Bruemmer, Linda (MDH); Dan Sparks; Debbie Orth; Frank Jewell1; Frank

Jewell2; Reetz, Gaylen (MPCA); Gene Merriam1; Gene Merriam2; John Harren; John Pederson; Keith Hanson; Kent Eken1; Kent Eken2; Leuthe, Dave P (DNR); Louis Smith; Marilyn Bernhardson; Mark Knoff; Mary Parrott; Michael McKay2; Pam Blixt (work); Pamela Blixt (home); Patrick Flowers; Blom, Patti R (DNR); Paul Torkelson; Peggy Anderson; Rummel, Sandy; Sandy Rummel; Scott Hoese; Woods, Steve (BWSR); Todd Renville; Toni Green; Victoria Reinhardt; Warren Formo; Wohlman, Matthew (MDA); Birr, Adam (MDA); Blackburn, Julie (BWSR); Bullert, Bernie; Buttleman, Keith; Buzicky, Greg (MDA); Davis, Brian; Dunn, Bill (MPCA); Elhassan, Ali; Ellingboe, Randy (MDH); Eshenaur, Tannie (MDH); Finley, Robert (MPCA); Flood, Rebecca (MPCA); Freeman, Jeff (DEED); Gary Pedersen; Haapala, William (MPCA); Hanson, Suzanne (MPCA); Hedman, Leah (AAG); Hilmoe, Cynthia (MPCA); Jaschke, John (BWSR); Johnson, Heather (MDA); Kolze, Lynne (MPCA); Kramer, Adam; Kuhlman, Terry (DEED); Larson, Reed (MPCA); Lotthammer, Shannon (MPCA); MacGregor, Molly (MPCA); Maleitzke, Jennifer (MPCA); McConnell, Mary (DNR); Patton, Bob (MDA); Reilly, Mary (MPCA); Rhees, Suzanne (DNR); Risberg, Jeff (MPCA); Schneider, Steve (CI-StPaul); Sigford, Kris; Sip, Rob (MDA); Sleeper, Faye; Stine, John (MPCA); Stoddard, Dan (MDA); Weirens, David (BWSR); Weisman, Barbara (MDA); Westerlund, Julie (DNR); Westrick, Marcey (BWSR); Wright, Dave I (DNR); Yearwood, Terri L (DNR)

Subject: Re: Clean Water Council Meeting 7/16/12

Dear Clean Water Council Colleagues, I regret that a long-standing commitment to the National Research Council/National Academy of Sciences will prevent me from attending Monday's meeting. I have reviewed all the materials, and while I am in agreement with the Priorities document, I am very dismayed at the implications of the BOC recommendations found in the last column of the Cumulative CWF Activities Spreadsheet. This column has the specific programmatic areas that BOC recommends should be cut from the agency 2014-15 requests, as indicated by double asterisks (**). Although a member of BOC, my schedule has not aligned with the one BOC set and so I have not been able to present my views to BOC. I am making my opinions and reasoning known here to inform the discussion at Monday's meeting. I disagree strongly with several of these recommendations for cuts, largely because they are in contrast the thoroughly vetted and widely accepted recommendations detailed in the Minnesota Water Sustainability Framework produced by the U of MN in response to the Legislature's request (see http://wrc.umn.edu/watersustainabilityframework/index.htm for full document; Exec Summary is attached). My specific comments are below (number refers to row in BOC spreadsheet): #24: MDA, Protect/restore groundwater from nitrates Nitrate polllution is a major driver of TMDLs, a major public health threat, and is the one major pollutant that is INCREASING and not decreasing in our waters. A greater investment is called for, not the current recommendation (equal to FY13). Consider a minimum of $3M. While it could be argued that this is a traditional responsibility, it is so critical to continue that if it takes CWF to do so, then so be it. #29: DNR, Electronic permitting The DNR's permitting system is antiquated and they are taking the recommendation of the Minnesota Water Sustainability Framework to move to an electronic platform, that will increase efficiency AND provide for a better process of screening for unreasonable permits. This is a modest request with big co-benefits, yet BOC has zeroed this out completely. Please do not be shortsighted, but invest in moving this minor but important program forward. A quantum jump in permit improvement is a supplemental, not supplanted investment.

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#33: MDH, Contaminants of emerging concern program This issue is considered one of the top 10 issues facing our state's water resources. The MDH has been recognized nationally for their remarkable science-based program of addressing CECs in drinking water. Expanding the investment in this important program is a major recommendation of the Framework, for protecting public health but especially newborn and young children's health. This is a prevention program, to get ahead of the curve, and will prevent illness and disease in the future through cleaner drinking water. It is clearly supplemental. The program should at the very least receive flat funding, but not a 50% cut! I strongly recommend the requested $2.5M. #44: MDA, Technical Assistance/Research I was impressed with the tremendous gains made in the efficacy of new ag BMPs, funded through their research program and articulated well by Adam Birr, Dave Mulla, and others. I was under the impression that the CWC shared my favorable response. The drastic cut to the requested expansion to this program seems surprising and ill-advised, especially since so many of our water resource problems are directly related to agricultural practice. This program owns this responsibility and addresses this issue head-on, giving the ag community really useful tools to restore and protect water in agricultural landscapes. I recommend a minimum of $4M. #60: MPCA on behalf of all agencies, Interagency water database and portal development I am dismayed that the BOC recommendation is to cut this completely, especially before hearing the presentation that will be made at Monday's meeting. I suspect that there may be confusion or misunderstanding about this request (again, a major recommendation from the Framework) and it is not a particularly sexy topic. But data management is ESSENTIAL, and each agency currently has different data management and even different management systems within each agency for different water programs. At the University I teach Data Management to faculty and staff, a requirement of the federal government for all federally-funded researchers. Without good data management, all the good data in the world cannot be used correctly if you want to understand the whole system - so our ambitious and laudable goal of a 10 year state water assessment plan (endorsed repeatedly by the Council) will be for naught if those data are not properly managed and combined with all the other Clean Water Fund efforts. There is NO SYSTEM for combining DNR, MDA, BWSR, and MDH data right now for either groundwater or surface water. If ever there was a proper and appropriate use of CWF investments, it is this. It is not research (would not be funded by LCCMR), it is not a legislative mandate (so does not fall under traditional funding) but is a way for us to move our water management to the next level with necessary data management - a perfect supplemental CWF investment. How many of you work for an organization that has invested funds in critical data systems (personnel, financial, etc) because you HAD TO to function - this is the same thing. It is necessary, essential, and although you hate to do it because it is not that visible or easily communicated, it must be done. I recommend the full request of $3M Some minor comments/questions: What are the implications to Met Council and the Twin Cities if #31: Metro Water Supply Plan is not fully funded? What are the implications to the MPCA and to the state if the #62: Application of Water Standards is not funded? What are the implications to the DNR and the state if #66: shoreland stewardship is not fully funded? Thank you for considering these comments. My best, Deb --

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Deborah L. Swackhamer, Ph.D. Professor and Charles M. Denny, Jr, Chair of Science, Technology, and Public Policy Hubert H. Humphrey School of Public Affairs http:/hhh.umn.edu Professor, Environmental Health Sciences http://enhs.umn.edu Co-Director, Water Resources Center http://wrc.umn.edu email: dswack@umn.edu mailing address: Water Resources Center 173 McNeal Hall 1985 Buford Avenue University of Minnesota, St Paul, MN, 55108 612-625-0279 WRC phone 612-626-3292 HHH phone 612-625-1263 fax

Comments to the Clean Water Council regarding proposed expenditures for the Clean Water Fund. Lawrence A. Baker, Ph.D., Research Professor, Department of Bioproducts and Biosystems Engineering, University of Minnesota I am responding to the Clean Water Council’s request for comments on the BOC ‘s Draft FY2014-15 Budget Recommendations. In particular, I am concerned about the relatively low level of research funding – only 6% to 8% of the proposed budget, or about $6-7 million per year. As a researcher who has focused much of my effort on water quality issues over the past 25 years, I think this is far too low of an investment, mainly because, contrary to what many legislators (and some agency staff) believe, I do not think we have sufficient knowledge to “protect, enhance, and restore” Minnesota’s waters in ways that are effective, efficient, and fair. One line of evidence for my position is that very few impaired water bodies have been restored, except for a handful that have benefited from reductions of point source pollution and a few more that have benefited from improved animal operations in their watersheds. From a personal perspective, in my work on urban stormwater, in which I have talked with dozens of staff members from cities, watershed districts, state agencies, and consultants, is that there is a real need for improved knowledge to guide water quality improvement. I understand the reluctance of many legislators regarding research. Some are concerned that research is too esoteric, and even when it is practical, the results are buried in peer-reviewed journals read only by other academics. Even when the research is “applied” in nature and the results are important, the translation of findings from the lab to practice is slow and cumbersome, and universities are not vested in this translation. To an extent, I agree. This certainly describes the historical record of many professors who started their research in an earlier era when research funds were abundant and the efficiency of translation was not especially an issue. Until recently, many university researchers did not envision translation of their research findings into practice as being an important issue. However, this culture is changing. One major catalyst for this change was the inclusion of a “broader impacts” review criterion for proposals submitted to the National Science Foundation, required since 2000. This criterion was developed in response to a demand by Congress that NSF-sponsored research have greater impact on society. For many of us, this has changed the way we think about how our research findings are used. Yet at the state level, there are many who seem to want to throw the baby out with the bath water. If the perceived problem is poor translation of research to application, the solution is to improve translation, not to skimp on research! I

therefore suggest that the Legislature increase the percentage of Clean Water Legacy funding that goes to research, to perhaps 15%-20% ($14-$18 million per year) of the total Clean Water Legacy budget. Over the 25-year lifetime of the Legacy Amendment, I believe this higher level of research would substantially improve our ability to “protect, enhance, and restore water quality” Minnesota’s waters by making subsequent implementation activities more effective, more efficient, and fairer. Because state dollars can be used to leverage federal dollars, the actual monetary impact of the boost in state funding would be far greater. However, simply raising the funding level for research would not be sufficient. To translate research findings to application on the ground, a substantial portion of the budget of each research project (perhaps up to one-third) would have to be allocated to translational activities. There is no one set of translational activities that would apply to all research, but for illustrative purposes, some examples – all based on research findings - might include: (1) development of educational outreach materials; (2) development of “user manuals” to facilitate use of research findings “on the ground”; (3) similarly, development of readily accessible models and other tools to aid implementation; (4) inclusion of stakeholder workshops to disseminate findings; and (5) development of research databases, so that data acquired in one project could be used by others. Of course, this is not an entirely new idea – translation of research has been the goal of the “Land Grant” function of universities for more than a century, but this idea has often not deeply ingrained in departments outside the traditional Land Grant departments. The new “broader impacts” thrust by NSF (discussed above) and locally, President Kale’s challenge to the University of Minnesota to find “new kinds of public engagement” indicate the academic community in Minnesota is ready to expand the idea of broader research translation. In summary, my intuition, based on 25 years of research on water quality, is that allocating substantially more funding for research, if accompanied by a major thrust towards translational activities to assure that research findings inform implementation projects – would be more effective at achieving the long-term goal of the Legacy Amendment to “protect, enhance, and restore” Minnesota’s waters than the current “research parsimonious” approach. These are my views only and not those of my department (Bioproducts and Biosystems Engineering) or the University of Minnesota.

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Reilly, Mary (MPCA)

From: John Gulliver [gulli003@umn.edu]Sent: Tuesday, July 24, 2012 10:43 AMTo: Risberg, Jeff (MPCA)Cc: Deb SwackhamerSubject: Recommendations for spending Clean Water Funds in FY-14-15

Categories: BOC Stakeholder responses

Jeff, Deborah Swackhamer asked the appropriate faculty from the University of Minnesota to comment on the above recommendations. I reviewed them, and was struck by one of the two key issues in the memorandum from the Budget and Outcomes Committee to the Clean Water Council: "How can the Council’s budget help build local capacity to more effectively deliver existing programs? “Local Capacity” is the ability of a local unit of government such as a city or soil and water conservation district to initiate, collaborate, and implement Clean Water Fund projects and practices. The intent of the Clean Water Fund is to accelerate and enhance the implementation of practices that reduce non-point source pollution and build a sustainable infrastructure. Therefore, a delivery system needs to exist within local units of government. This delivery system needs to include services for engineering, technical reporting, maintenance, and landowner engagement and planning at the local level." In my view, while the budget that I reviewed has a few programs, it seems as though it is more about funding individual projects. My opinion is that the money would be used more effectively if the CWC chose their recipients carefully and let them decide what needs to be done in a specific water area. Then, funding could be withheld if the recipients did not deliver quality, and the CWC is not evaluating individual projects where only one or none have expertise. One example of a program that deserves funding would be the Stormwater Steering Committee (SSC), who is doing good work on just a few dollars. The SSC is composed of individuals from various industries, cities, counties, watershed districts, and state agencies. It is a good example of the positive attributes of bringing all stakeholders together. They are dealing with Total Daily maximum Load and Non-degradation requirements that will be applied to many communities, trying to develop guidelines and support research to enable the communities to deal with these requirements. As a group, they are well prepared to spend CWC funds in a productive manner. Thanks for the opportunity to give my opinion. Yours, John Gulliver -- John S. Gulliver, Ph. D., P.E. Professor Department of Civil Engineering Minneapolis, MN 55455 University of Minnesota www.stormwater.safl.umn www.ce.umn.edu

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612-625-4080 Fax: 612-626-7750

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Reilly, Mary (MPCA)

From: Michael Sadowsky [sadowsky@umn.edu]Sent: Thursday, July 19, 2012 4:33 PMTo: Deborah Swackhamer; Risberg, Jeff (MPCA)Subject: Re: [WRSFACULTY-TC] recommendations for spending Clean Water Funds in FY-14-15

Categories: BOC Stakeholder responses

Hi Deb: Thanks much. I did cc'd Jeff on my email. Cutting the beach monitoring program is a major problem for public health. Right now MDH is supposed to monitor the beaches - at least the last I heard and I met with MDH to go over this need and to give them methods to use. I even offered to help do training. If you look at the beaches on park point you can see how many times they are closed. MPCA used to monitor the beaches until Heidi left. Someone needs to do this for public safety concerns. Mike

On Thu, Jul 19, 2012 at 4:25 PM, Deborah Swackhamer <dswack@umn.edu> wrote: I will bring that up, and feel free to send that comment on to Jeff. I would really appreciate you comments on the beach monitoring program for Lake Superior - it is slated to be cut from EPA's budget, and MPCA is proposing to pick it up - BOC is proposing not to - any thoughts? Deb

On Thu, Jul 19, 2012 at 1:15 PM, Michael Sadowsky <sadowsky@umn.edu> wrote: Hi Deb: I read through the documents and noticed a stark absence of microbiological assessment for water quality improvement or development of new tools to assess sources of microbial pollution for public health or TMDLs. This is one of the most often exceeded standards of water quality. Please let me know if you need more information. Mike

On Thu, Jul 19, 2012 at 12:37 PM, Deborah Swackhamer <dswack@umn.edu> wrote: Dear water faculty, researchers, and staff, as you may recall, I am a member of the Clean Water Council (representing Higher Education), and we advise the Governor and Legislature on the investment of the Clean Water Fund monies arising from the Clean Water Land and Legacy Amendment. We have a subcommittee of the Council (called the Budget and Outcomes Committee, or BOC) that has made the first pass at these recommendations, and this subcommittee is looking for feedback prior to the full Council's consideration and to inform the Council's discussion and final recommendations. The materials can be found at BOC Draft FY2014-15 Budget Recommendations. As some background, the Clean Water Fund is appropriated to the major state agencies, who use it on major water-

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related programs (rather than individual projects) such as water assessments, drinking water protection programs, agricultural BMP assessments, etc. A large amount of the funds do reach on-the-ground projects through the appropriation to the BWSR programs. The issue we will be debating in the coming months is that the agency's preliminary budgets total more than what will be available, so the CWC will need to recommend less than the agencies are requesting - so feedback on what reductions to the request are most appropriate should be the focus of your feedback. Please send your feedback to Jeff Risberg (Jeff.Risberg@state.mn.us), staff at the MPCA, and copy me if you are so inclined. We need your feedback by August 2, although please note that there will be another public comment period in September when you can respond to the full Council recommendations. thanks, Deb -- Deborah L. Swackhamer, Ph.D. Professor and Charles M. Denny, Jr, Chair of Science, Technology, and Public Policy Hubert H. Humphrey School of Public Affairs http:/hhh.umn.edu Professor, Environmental Health Sciences http://enhs.umn.edu Co-Director, Water Resources Center http://wrc.umn.edu email: dswack@umn.edu mailing address: Water Resources Center 173 McNeal Hall 1985 Buford Avenue University of Minnesota, St Paul, MN, 55108 612-625-0279 WRC phone 612-626-3292 HHH phone 612-625-1263 fax

-- Dr. Michael Sadowsky Director BioTechnology Institute Distinguished McKnight Professor BioTechnology Institute University of Minnesota 140 Gortner Lab 1479 Gortner Avenue St. Paul, MN 55108 Phone: (612) 624-2706 FAX: (612) 625-5780 Email: Sadowsky@umn.edu --

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Deborah L. Swackhamer, Ph.D. Professor and Charles M. Denny, Jr, Chair of Science, Technology, and Public Policy Hubert H. Humphrey School of Public Affairs http:/hhh.umn.edu Professor, Environmental Health Sciences http://enhs.umn.edu Co-Director, Water Resources Center http://wrc.umn.edu email: dswack@umn.edu mailing address: Water Resources Center 173 McNeal Hall 1985 Buford Avenue University of Minnesota, St Paul, MN, 55108 612-625-0279 WRC phone 612-626-3292 HHH phone 612-625-1263 fax

-- Dr. Michael Sadowsky Director BioTechnology Institute Distinguished McKnight Professor BioTechnology Institute University of Minnesota 140 Gortner Lab 1479 Gortner Avenue St. Paul, MN 55108 Phone: (612) 624-2706 FAX: (612) 625-5780 Email: Sadowsky@umn.edu