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[204185/1] 19 106. With the transient model reports, the DNR concluded that reducing area use of groundwater to an average of 90 gallons per resident, per day, would be insufficient to maintain the elevation of White Bear Lake at 922 feet.106 107. Instead, the DNR projected that water use would need to be reduced to 55 gallons, per person, per day, to maintain the elevation of White Bear Lake at 922 feet.107 108. While average for daily water use in Minnesota is 55 gallons, per person, per day, the per capita averages in many of the suburban communities that ring White Bear Lake is much higher.108 109. Among the permitted water systems within five miles of White Bear Lake, the public and private water supply use during the 10-year period from 2011 through 2020, ranged between 73 and 108 gallons of water per person, per day.109 110. Moreover, even if one assumes that water usage could be slashed to 55 gallons per person, per day, there would not be any remaining water for any use other than household uses.110 111. Randall Doneen, the Manager of DNR’s Conservation Assistance and Regulations Section, maintains that a 55 gallon, per person, per day limit is simply too low to be achievable in the near term.111 112. Jason Moeckel, a limnologist with DNR, concurs with this assessment.112 As described below, the DNR proposes more modest conservation goals in the near term. 113. Another difficulty that complicates compliance with the District Court’s order, is that the range of persons included in the term “per capita” is not clear. For example, it is not clear from the text of the order whether the per capita limitation is calculated by tabulating the water usage of all residents within a particular community, or merely those residents who are receiving municipal water services. Put another way: Do the water usage limitations apply to residents who are drawing water from private wells?113 114. In September of 2023, the DNR declared its view as to the proper method of tabulating per capita water use. It explained: Population served can be different than the total population of a community. Population served does not include residences or other facilities within a community that are not connected to the water supply system 106 Tr. Vol. 3 at 12 (Champion). 107 Tr. Vol. 10 at 240-41, 266 (Doneen). 108 Tr. 2 at 144 (Bauer); Tr. Vol. 10 at 241 (Doneen); Tr. Vol. 9 at 137-38 (Griffin). 109 DNR Ex. 3 at 5 (Conclusion 1). 110 Tr. Vol. 10 at 241 (Doneen). 111 Id. at 299. 112 Tr. Vol. 19 at 269-70. Limnologists are scientists who study the physical, chemical and biological properties of lakes, rivers and streams. See WBL-Dist, at *29, n. 249. 113 Tr. Vol. 10 at 241 (Doneen).