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small, shallow lakes, a study completed in 2004 to determine the quantity of phosphorus removed from Lake <br />Minnetonka by the LMCD's harvesting program, written by John Barton, at the time, the Natural Resource <br />Director of the Three River's Park District, found it only removes about 2-4 percent of the annual phosphorous <br />load into Lake Minnetonka. Since milfoil and other rooted aquatic plants get their nutrients from lake sediment, <br />the amount of nutrients removed by the harvesting program is negligible and has an infinitesimal impact, if any, <br />on the growth of blue green algae in Lake Minnetonka. <br />The LMCD's position that the harvesting program reduces the rate and amount of Eurasian water milfoil in <br />Lake Minnetonka is false. Scientific research indicates just the opposite. A study published in the Journal of <br />Aquatic Plant Management on the "Effects of Harvesting on Plant Communities Dominated by Eurasian <br />Watermilfoil in Lake Minnetonka, MY (attached) found that, "harvested plots had significantly higher relative <br />growth rates over the remaining field season than did reference areas. " Furthermore, one of the primary ways <br />Eurasian water milfoil and other aquatic invasive spread is through fragmentation. Since the harvesters are <br />unable to collect all of the plant fragments it creates, the LMCD harvesting program may unknowingly spread <br />starry stonewort, hydrilla, and other invasive species, many of which require trained aquatic plant specialist to <br />identify. The harvesting program may also be contributing to the spread of flowering rush in Lake Minnetonka, <br />an invasive plant that chokes out waterways and which is spreading across Lake Minnetonka. The Pelican <br />River Watershed District discontinued its weed harvesting program in 2000 and emphatically states, <br />"Mechanical harvesting WILL NOT WORK FOR CONTROL and CONTRIBUES TO THE SPREAD and <br />INCREASE IN PLANT DENSITY/POPULATIONS of flowering rush." (See attached). <br />Minnesota Rules Chapter 6280.0350, Chapter Subp. 3. Requires that "a person who mechanically controls aquatic plants <br />in a public water must immediately and permanently remove the vegetation from the water and dispose of it above the <br />ordinary high water level." While the LMCD disputes residents' concerns that plant fragments wash up on their shores <br />after harvesters have been in their bays, the LMCD has acknowledged publically the harvesters only pick up about 80 <br />percent of what they cut. The LMCD is knowingly in violation of state rules, has compromised their DNR permit, and <br />may be in danger of personal and class action lawsuits to recover damages from residents and businesses who have <br />spent thousands of dollars to clean their beaches and marinas after harvesters have been near their property. <br />The LMCD indicates it is partnering with other agencies researching AIS in Lake Minnetonka, yet the primary <br />agencies involved conducting (Minnehaha Creek Watershed District, University of Minnesota, and USGS) does <br />not list the LMCD as a partner (attached). It is not even clear if the LMCD is interested in AIS <br />research. Neither staff nor representatives from the LMCD were present on September 12, 2018 at the <br />Minnesota Aquatic Invasive Species Research Center's showcase of AIS research underway in Minnesota. <br />The LMCD's disregard for state law is inexcusable and their use of hyperbole, lack of sound scientific facts, <br />and misleading claims about the harvesting program and AIS research minimizes the work of our lake <br />communities, natural resource agencies, and residents who have invested millions of private and public funds to <br />protect Lake Minnetonka. I no longer feel the LMCD is a credible or trustworthy organization. The LMCD's <br />weed harvesting program has become unmanageable, and creates more problems than it solves, is a financial <br />liability to LMCD tax payers. <br />Sincerely, <br />Gabriel Jabbour, Tonka Bay Marina <br />CC. Jay Green, President LMCD Board <br />City of Orono <br />City of Shorewood <br />