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The City is concerned about finding funding sources for implementation of this Storm <br />Water Pollution Prevention Program. All levels of government in Minnesota are under a <br />cloud of revenue shortfalls. Thus, new unfunded mandates such as the NPDES Phase <br />II program will be financially burdensome to implement. We urge you to consider this as <br />the NPDES Phase II program evolves. <br />The City also wishes to address Permit item C of Part IV (Section 303(d) listings and <br />Total Maximum Daily Load (TMDL) implementation plans). Implementation plans have <br />not been developed for the lakes (Bald Eagle, Peltier, George Watch, Marshan and <br />Centerville) and creeks (Clearwater and Hardwood) in the City that are included in the <br />US Environmental Protection Agency's July 8, 2002 proposed Total Maximum Daily <br />Load (TMDL) list (under Section 303(d) of the Clean Water Act). <br />In the remainder of this letter, the City will explain its reasoning for proposing TMDL de- <br />listings of George Watch, Marshan and Centerville Lakes and describe its minimal <br />contribution to the overall storm water allocation to the remainder of the TMDL listings of <br />in the City. <br />About 40 percent of the City's total land area is comprised of lakes and national <br />wetlands. The wetlands are widespread and these areas often help mitigate excess <br />storm water runoff peak flows. The City lakes generally fall into two categories; Natural <br />Environmental and Recreational. The Natural Environmental lakes are primarily located <br />in the Chain of Lakes Regional Park area and include Peltier, George Watch, Marshan, <br />Rice, Wards, Sherman, Cedar, Amelia, Randeau and Wilkinson Lakes. Recreational <br />lakes include Otter, Centerville, Reshanau, Baldwin and Bald Eagle lakes. They are <br />used for a variety of recreational uses such as swimming, boating, fishing and water <br />skiing. Centerville, Bald Eagle, Peltier and Reshanau are considered game fishing <br />lakes. Centerville and Bald Eagle Lakes are managed fisheries and stocked annually <br />with Walleye and Muskellunge. Each of these Lakes has significant rough fish <br />populations and Centerville Lake is aerated to prevent game fish winter kill. <br />