

Comment Info: =================

General Comment:Please include Chloride in consideration of stormwater priorities.  Attached please 
find a letter outlining lack of identified specific targets, schedules, or funding to 
address chloride TMDL issue in Brooklyn Park, Minnesota.



October 14, 2006

Walter J. Breckenridge Chapter 
Izaak Walton League of America
8816 West River Road
Brooklyn Park, MN 55444

Tim Larson
Minnesota Pollution Control Agency 
Shingle Creek Chloride Draft TMDL
520 Lafayette Road N. 
St. Paul, MN 55155-4194  
651 296-6300

Dear Mr. Larson, 

The Breckenridge Chapter of the Izaak Walton League has serious concerns that 
the Draft TMDL is not specific and is not complete with respect to the ?adaptive 
management? implementation plan.  Although the Breckenridge Chapter has 
serious concerns, we are pleased that this is a positive step forward in addressing 
Shingle Creek?s water quality and specifically chloride in Shingle Creek. Some 
specific improvements are required.  Specific plans and timelines should be 
specified in order to make the implementation plan viable and realistic.  Specific 
requirements for land use, such as requiring pervious paving surfaces, citizen and 
business created rain gardens, salt reduction, water treatment systems, 
agricultural run-off, storm water holding ponds, and natural shoreline buffers, use 
of fertilizers, and residential and business use of de-icing agents, should be 
defined, recommended, and prioritized. Their effectiveness quantified, and a ratio 
of chloride/pollutant reduction to costliness estimated.  The following issues have 
been identified by various members of the Breckenridge Chapter, after reviewing 
the plan: 

In addition to the implementation plan using one of many possible approaches, 
this plan lacks specific requirements, deadlines, and defined funding.  

To produce water quality improvement results, the implementation plan must have 
specific stakeholder targets and limits.  This draft plan has an imprecise percent 
use reduction target and alludes to a loose agreement of stakeholders to 
be ?outlined? in an undefined future ?implementation plan? to reach one overall 
target.  

To produce timely water quality improvement results the implementation plan 
must have a milestone and completion timetable.  This draft plan has no timetable 
for implementation.   

To produce water quality improvement results the implementation plan must 
identify stakeholder funding responsibilities and sources.  Cities, counties, and 
state agencies are struggling to maintain budgets due to reductions in state 
funding and aid.  The additional funds to address the TMDL should be negotiated 
and identified up front in order to realize the TMDL. The additional pollution control 
costs should be identified.  



We recommend that the plan include specific water quality results targets, 
specific timelines, specific stakeholder load allocation limits, and specific program 
funding sources. 

The federal law requiring action was passed in 1972.  Shingle Creek has been 
listed as a chloride impaired water since 1998.  Let us take realistic and effective 
action to improve Shingle Creek water quality and to reduce chloride in Shingle 
Creek.  There are many sensitive aquatic species such as amphibians, turtles, 
fish, and invertebrates that are indicators. Such species inform there is a problem 
when they are in decline and biodiversity in general declines.  This decline, acting 
like the parakeet in the coal mine, indicates our waters are impaired, can have 
serious health effects, especially for children and pregnant mothers, and 
negatively impacts ecosystem and their processes, and biodiversity. 

Many Cities and City Councils are in tight budgetary situations and reluctant to 
provide additional funding to the Shingle Creek & West Mississippi Watershed 
Commissions. However some City Council members and much of the public are 
supportive in funding and or mandating meaningful reductions of chloride an 
pollutant levels in Shingle Creek.  It is especially important to start taking positive, 
realistic steps along redeveloped portions of Shingle Creek.  These actions and 
reductions lay the ground work, set the backdrop, and the standard for the rapid 
growth now happening through-out undeveloped portions of the Northwest 
suburbs.   

Best Management Plan?s for the reduction of chloride on our freeways, highways, 
streets, roads, public parking areas, private parking areas, and storage areas in 
the Shingle Creek Watershed would be a positive step to reduce the chloride 
loading to Shingle Creek.  We must also make positive steps to actually reduce 
chloride/pollutant loading now by implementing at least those portions of the plans 
that are immediately realizable. A plan with an eight year schedule and very little 
initial implementation signals low prioritization and little positive impacts in the 
immediate future.  The MPCA lists 34 people who have been voluntarily certified to 
apply BMPs to reduce chloride impacts as of September 12, 2006 1.  Only 12 of 
these are employees of MNDOT, cities, and counties.  We question if and when 
implementation of BMPs will realistically be accomplished without established 
individual stakeholder targets, deadlines, and funding.  Are we to continue to 
accept pollution of our impaired waters while we continue to study the issue? Or 
are we going to take positive steps now to treat the water?

There are many additional efforts for cold climate surface water management2 that 
must be implemented to realize consistent and lasting positive effects on chloride 
loading of Shingle Creek and allow for future growth:

?	Consistent reductions from mandatory certification and permitting.
?	Consistent reductions from spill control regulations and violation 
penalties.
?	Land use regulation and programs to increase permeation for flow 
volume control.
?	Land use regulation and programs for reduction of impervious surfaces.
?	Land use regulation and programs to increase pervious paving.
?	Land use regulation and programs to increase use of grass drainage 
channels.
?	Infrastructure changes and programs that will modify transportation 
behaviors, such as highway miles driven, to maintain or reduce the amount of 
treatment with chloride that is necessary.
?	Design and sizing of existing and future infrastructure to provide a 
higher level of storm water chloride treatment.  There must be modifications to 
storm water treatment design and sizing criteria to address existing chloride 
loadings until they are reduced.  
?	Land use regulation and programs for better snow dump practices.  
?	Land use regulation and programs to require low impact development 
standards.

We understand there is complexity in the situation, but do believe that realistic 
positive first steps can be achieved in improving the water quality of Shingle Creek 
in the near term. If you would like to discuss further, either in person, or over the 
phone please do not hesitate to contact me.  My daytime number is 952-542-1440 
x214.  We are certainly willing to work together in the spirit of cooperation in 
achieving water quality improvements for Shingle Creek.  The Breckenridge 
Chapter is located in Brooklyn Park, and most of our 130 members live in 
Brooklyn Park and Brooklyn Center. 

Best Regards, 


John Rust
President
Walter J. Breckenridge Chapter
Izaak Walton League of America
763-424-7973
Imgahn2u@yahoo.com  



1)	 ?List of Individuals Certified? MPCA Road Salt Education Program, 
www.pca.state.mn.us/programs/roadsalt.html
2)	Minnesota Storm water Manual, Issue Paper G ? v.5. (final), Cold 
Climate Considerations For Surface Water Management, Table3 ?Applicability of 
Issue Paper ?A? BMP?s for Cold Climate Use? January 13, 2005

