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A WSB 701 Xenia Avenue South I Suite 3001 Minneapolis, MN U416 1(763) 5414600 October 16, 2017 Mr. Bryan Bear City Administrator City of Hugo 14669 Fitzgerald Ave. N. Hugo, MN 55038 Re: Advancing Safe and Sustainable Water Reuse in Minnesota Report Comments Dear Mr. Bear, We have reviewed the 2017 Report of the Interagency Workgroup on Water Reuse (Workgroup). As you are aware, in 2015 the Minnesota Legislature directed the Department of Health (MDH) to, "Prepare a comprehensive study of and recommendations for regulatory and non -regulatory approaches to water reuse in the development of state policy for water reuse in Minnesota.' In response, the Workgroup was formed and led by MDH with three main objectives: 1. Define successful implementation of water reuse in Minnesota 2. Identity current conditions that support successful water reuse and identify barriers and solutions to these barriers. 3. Develop recommendations for safe and sustainable water reuse practices and policies. The goal of the legislature was to promote water reuse, and identify conditions and barriers that can prevent successful water reuse implementation. As we review the report, we believe that the Workgroup's heavy focus on the third objective will actually create additional barriers that will hinder stonnwater reuse implementation. There are a few key items within the report that we would tike to call your attention to: 1. There is a strong focus on public health, which is certainly an important consideration. This focus will likely lead to additional. permitting requirements requiring added time and significant expense on what are already economically fragile practices. 2. Water reuse for irrigation purposes is viewed similarly to internal water reuse, gray water reuse, and other strategies that are regulated to a greater extent than stormwater reuse has been in the past. Due to lack of sufficient data on stormwater pathogens, the Workgroup has used waste water dilutions to represent stormwater's public health risk. They also recommended adopting standards similar to those used for drinking water for treatment practices for non -potable stormwater irrigation reuse. 3. The Minnesota Cities Stormwater Coalition (MCSC) has reviewed the report in great detail and offer a number of expanded comments related to the outcome of the report. We have reviewed the document, and will not reiterate the specific comments here but have attached the comments for reference. The general concern from MCSC is that the specific information contained in this report, while not intended to be regulatory, will become just that in the absence of other guidance. In conclusion, we believe that the Workgroup should remove specific regulatory treatment requirement language for irrigation reuse from the report until current ongoing stormwater reuse research is completed. We also recommend that the Workgroup focus on its original and central purpose of promoting water reuse. Building a legacy—yourlegacy. Equal Opportunity Ennplayxr I xsbeng.conn C i�acwmi w �oora17 dm