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Issue Analysis <br />Phosphorus Reduction <br />Stubbs Bay has elevated phosphorus concentrations, leading to algae blooms and impairment of aquatic recreation. <br />In previous years, external phosphorus loading to the bay has been reduced through the following actions: <br />• Protection of upland wetlands; <br />• Enforcement of stormwater management regulations; <br />• Reduction of agricultural land in the upstream watershed; and <br />• Projects carried out by the City of Orono and the Minnehaha Creek Watershed District in the early 2000s <br />(e.g., Stubbs Bay Ravine Stabilization (https://www.legacy.mn.gov/projects/stubbs-bay-ravine- <br />stabilization)). <br />Because these projects have reduced the external phosphorus loading to the lake, it has been suggested that the <br />elevated phosphorus concentrations are at least partly due to internal loading. However, it appears that this <br />conclusion has not been verified by phosphorus budget models. About 21% of the catchment basin remains in <br />agricultural use, 10% is in developed -open space use, and an additional 24% is in developed low -high density use; <br />together, these represent a bit over half of the land use types in the catchment, which could contribute to runoff <br />and external loading of nutrients. The semi -ditched wetland complex is a particularly likely source of external <br />phosphorus loading, and should be investigated, in collaboration with the MPCA or MCWD. <br />The LID proposal does not include any specific program or project to reduce phosphorus concentrations in the bay, <br />nor does it include a firm commitment to study this problem and identify a feasible course of action to mitigate <br />phosphorus concentrations. The LID's first concern is to reduce AIS abundance in the bay, and this is appropriate: <br />the seasonal dynamics of CLP, which grows early in the year and dies back in late summer or fall, releasing nutrients <br />back into the water column as the plants decay, could have a significant impact on the water quality patterns in the <br />bay, which would be a factor in determining any feasible phosphorus mitigation strategy. <br />According to the MPCA Lakes and Streams Water Quality Dashboard, the Minnehaha Creek Watershed District <br />(MCWD) has been monitoring phosphorus concentrations on a monthly basis since 2007. A sampling frequency of <br />at least monthly is necessary to identify possible sources or causes of phosphorus loading to the bay, and therefore <br />DNR strongly recommends that the LID collaborate with the MCWD to maintain or enhance this water quality <br />monitoring program to determine seasonal patterns in phosphorus concentration, possible remaining external <br />sources of phosphorus loading (e.g., stormwater runoff, discharge from the semi -ditched wetland complex), and <br />possible impacts from CLP reduction. DNR also recommends conducting a sediment sampling program to assess the <br />extent to which internal loading is driving the phosphorus concentrations in the bay. This data would be necessary <br />to develop a phosphorus loading model for the bay and determine appropriate mitigation approaches (e.g., alum <br />treatment if internal loading is determined to be a problem, or nonpoint or stormwater capture and mitigation <br />projects if external loading remains a problem). <br />If the continued water quality monitoring program identifies continued external sources of phosphorus, then the LID <br />would need to collaborate with the MCWD, Lake Minnetonka Conservation District (LMCD), or the MPCA to <br />implement projects to reduce these loads, since the areas on the landscape where such projects would need to be <br />implemented would likely be outside the proposed LID boundaries. <br />280 <br />