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The Minnesota Pollution Control Agency (MPCA) establishes water quality standards for <br />• all waters of the state, including surface water. These standards are contained in <br />Minnesota Rules Chapter 7050 and have statewide applicability. The MPCA's statutory <br />authority to adopt water quality standards and to classify waters of the state is found in <br />Minnesota Statutes Chapter 115. Water quality standards represent expectations for <br />how a stream or river could be used under natural conditions. We believe that this <br />authority formed the basis for the inclusion of Bald Eagle, Peltier, George Watch, <br />Marshan and Centerville Lakes in the US Environmental Protection Agency's July 8, <br />2002 proposed Total Maximum Daily Load (TMDL) list (under Section 303(d) of the <br />Clean Water Act) due to excess nutrients. In addition, Both Clearwater and Hardwood <br />Creeks are also included in TMDL list because of impaired biota. <br />The Rice Creek Watershed District (RCWD) Water Resource Management Plan states <br />that lakes such as George Watch, Reshanau, Rice and Marshan Lakes should be <br />considered Type 5 wetlands due to their shallow depths, organic bottom material and <br />emergent vegetation. As a result the City views George Watch and Marshan Lakes as <br />functioning properly within their wetland classification and believes they should be <br />removed from the TMDL list. In the case of Centerville lake, approximately 150 acres <br />are tributary to the 455 acre lake (see the enclosed Rice Creek Chain of Lakes Regional <br />Park Reserve Map). The City believes that a lake occupying 75% of its total drainage <br />area should not be on the TMDL list. <br />The RCWD Plan states that Bald Eagle and Peltier lakes have significant potential for <br />improvement. The City has little influence on the status of Bald Eagle Lake because the <br />City does not have control of a significant drainage area to or surface area of it. RCWD <br />has performed diagnostic /feasibility studies of Peltier Lake. This 465 acre lake sits <br />within a relatively small subwatershed within the Upper Rice Creek Watershed. All of its <br />shoreline in the City is also in the Chain of Lakes Regional Park. City activities <br />contribute drainage impacts to Randeau lake which, in turn, drains into Peltier lake. City <br />activities also contribute drainage impacts to Clearwater and Hardwood Creeks near <br />their discharge points into Peltier lake. However, these contributions are dwarfed by the <br />nearly 100 square miles of drainage contribution to Peltier Lake from the rest of the <br />