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Chapter 2 Introduction 2.1 Purpose of the Watershed Restoration Plan The primary purpose of this Kinnickinnic River Watershed Restoration Plan (WRP) is to develop an adaptive plan with stakeholders that works towards cost-effective water quality and habitat improvement in the watershed. Recognizing the need to work towards meeting water quality standards, and that stakeholders would like to see improvements (particularly to habitat) that may go beyond meeting water quality standards, the WRP provides specific actions that can be implemented in the short term (3 to 5 years) and lays out a more general plan for the long term to meet these objectives. The WRP will utilize the Southeastern Wisconsin Watersheds Trust (SWWT) as the stakeholder group for development of the plans and the vehicle for the Plan implementation. 2.2 Pathway to the Watershed Restoration Plans 2.2.1 The RWQMPU and MMSD 2020 Facilities Planning Process (2002-2007) The United States Environmental Protection Agencys (EPAs) watershed approach to facilities planning has been completed in southeastern Wisconsin by the Milwaukee Metropolitan Sewerage District (MMSD or District), in partnership with the Southeastern Wisconsin Regional Planning Commission (SEWRPC), the regions 208 planning agency. This combined, innovative planning project called the Water Quality Initiative (WQI) consisted of the MMSDs 2020 Facilities Plan (2020 FP) and SEWRPCs Regional Water Quality Management Plan Update (RWQMPU). The WQI was completed and the 2020 FP was approved by the Wisconsin Department of Natural Resources (WDNR) in 2007 and concluded: 1) Nonpoint pollution (i.e. stormwater runoff) is the largest source of fecal coliform bacteria, a primary pollutant of concern. The annual bacteria load percentages by source category to the six Greater Milwaukee Watersheds (GMW) are shown in Figure 2.1. 2) Eliminating the combined sewer overflows (CSOs) that occur 2 to 3 times per year and the very infrequent sanitary sewer overflows (SSOs) that still may occur during extreme wet weather conditions accompanied by widespread flooding will result in little or no water quality improvement on an annual basis. 3) Significant improvements to water quality can only be achieved through regional implementation of extensive measures to reduce pollution from nonpoint sources. 4) The MMSDs primary focus of the 2020 FP must be to develop a Recommended Plan that meets the regulatory requirements regarding MMSDs point sources. 5) Recommendations for nonpoint control measures are presented in the RWQMPU because MMSD lacks authority to implement regional nonpoint control measures. 6) There is no real framework for implementation of the recommendations of the RWQMPU regarding the reduction of nonpoint stormwater pollution (considered to be nonpoint runoff to a watershed including storm sewer and other discharges).

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Rural Nonpoint Stormw ater < 0.1%

Industrial < 0.1%

SSOs 20%

CSOs 11% Urban Nonpoint Stormw ater 69%

Figure 2.1: Annual Bacteria Load Percentages by Source Category to the Kinnickinnic River Watershed Existing Situation Year 2000 Conditions 2.2.2 Forging a New Path As the WQI was being completed, many stakeholders in the Milwaukee area began to realize that a means of implementing the broader recommendations of the RWQMPU was needed. This is conceptually illustrated in Figure 2.2 which was an attempt to address the question - what next? This question was often accompanied by the question - why cant we forge a new path?

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Note that on this figure an organization is shown called the Milwaukee Regional Partnership Initiative. This has been renamed the Southeast Wisconsin Watersheds Trust. Figure 2.2 What Pathways Exist for Progress? The EPA encourages and supports watershed area planning intended to achieve needed water quality improvements in the most cost effective manner. The RWQMPU recommends a holistic set of pollution abatement actions that will ultimately lead to significantly improved water quality in the greater Milwaukee area. These actions will address regulatory goals in terms of water quality improvement, and must be implemented by a variety of governmental agencies and individual property owners. The question for the Milwaukee area was how to start this process? 2.3 Plan Implementation Considerations 2.3.1 Consideration of Total Maximum Daily Load (TMDL) Analyses A workshop on Integrated Watershed Implementation Planning was held in March 2007 and was attended by EPA, WDNR, SEWRPC, MMSD and technical consultant staff, and other local and national 23

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leaders in watershed planning. The purpose was to form the foundation for the WQI implementation plan, and more specifically, consider the next steps for water quality improvement in the Milwaukee area. The agenda for this meeting is shown in Appendix 2A. Input received at the workshop was intended to result in the formation of a technically- and sociallyfeasible, integrated watershed implementation plan that has the support of key stakeholders, employing innovative implementation approaches (e.g., water quality trading, watershed-based permitting, phased TMDLs, wet weather water quality standards) intended to effectively and efficiently attain water quality standards in the GMW. As a result of this workshop and many subsequent meetings in 2007, the MMSD, working in concert with the EPA and the WDNR, considered the initiation of a third party TMDL effort. The drivers for the third party TMDL were that the WDNR was not planning to initiate any TMDL work in the GMW for many years, and the implementation of NR 151, a State of Wisconsin nonpoint pollution regulation with compliance deadlines in 2008 and 2013. An additional concern was that the water quality improvement efforts begun under the WQI should continue given the work already accomplished and the momentum established in the community. This momentum was exemplified by the formation of a new collaborative organization, the Southeast Wisconsin Watersheds Trust (SWWT) in the spring of 2008. 2.3.2 Third Party TMDL and NR151 In October, 2007, the MMSD Commission approved a contract with the 2020 Facilities Plan technical team to conduct third party TMDLs for the major watersheds in Milwaukee the Milwaukee River, Menomonee River, Kinnickinnic River and Estuary/Lake Michigan watersheds. Once this effort was approved, preliminary negotiations began with the WDNR staff to enlist their input into the process and to begin technical discussions on the existing 303(d) listed pollutants and other matters. In other words, MMSD, its technical team and the WDNR began in depth technical discussions regarding the scope of the third party TMDL. Typically, a TMDL is the framework for assessing load allocations in a watershed and is one of the first steps in identifying the actions needed in a watershed to meet applicable water quality standards. In the case of the Greater Milwaukee Watersheds, the States regulatory program, which is based on performance standards contained in NR 151, has already been implemented. The performance standards contained in NR 151 require permitted municipalities with separate storm sewer systems (MS4s) to reduce total suspended solid (TSS) loads by 20% by 2008 and 40% by 2013 from areas of existing development. New development must implement stormwater management practices to reduce the TSS load from the site by 80%. Technical standards have been developed by the State to implement the prescribed performance standards. Other provisions of the regulations prescribe performance standards and prohibitions for agricultural facilities and agricultural practices that are nonpoint sources and require implementation of agricultural best management practices (BMPs) when and if the Wisconsin legislature provides funding for these facilities. The MMSD and its technical team included in its discussions with the WDNR the relationship between the third party TMDL effort and the NR 151 regulatory requirements, which are essentially technology24

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based requirements. Discussions between MMSD and the WDNR regarding application of NR 151 requirements independent of TMDL findings changed the course and form of the Greater Milwaukee Watersheds TMDL program. 2.3.3 TMDLs and the Clean Water Act The discussion between the MMSDs technical team and the WDNR related to some fundamental assumptions of the 1972 Clean Water Act (CWA). Specifically, MMSDs technical team and the WDNR analyzed the relative merits of building nonpoint/stormwater water quality improvement actions from the top down using a uniform technology program, or from the bottom up starting with existing water quality data and building programs specifically to meet water quality objectives. The similarity between the NR 151 regulatory requirement and the CWA is that application of a uniform technology program is fundamentally assumed to be the minimum effort needed to meet water quality standards. An additional effort was assumed to be required when this minimum initial activity did not result in meeting water quality standards. The original CWA envisioned that nonpoint/stormwater improvement would be based solely on water quality, not on uniform, minimum technology requirements. As outlined in a recent publication from the University of Texas1: TMDL stands for Total Maximum Daily Load and is the maximum amount of a pollutant that a water body can receive from all of its sources and still meet water quality standards set by the state for designated uses. Though TMDLs have only recently been thrust into the spotlight, they are not a new idea. The TMDL program is simply the enforcement of rules provided in the Clean Water Act of 1972 (CWA). Sections 303 (a), 303 (b), and 303 (c) of the CWA mandate that states develop water quality standards for water bodies within their boundaries based on the designated uses of these water bodies. These sections also provide guidelines for development and review of these standards. The provisions in the CWA that called for non-point source pollution control and TMDLs were largely ignored for 20 years following the passage of the CWA partly due to our lack of knowledge concerning non-point source pollution and its control. Instead, efforts to control water pollution were focused on implementing best available technology to clean up point-source pollution. Many challenges exist in the implementation of the TMDL program. Non-point source pollution, which is basically stormwater runoff that has been polluted by land use, is still not well understood. It is difficult to quantify loadings produced by non-point source pollution and to predict the water quality responses of water bodies due to these loadings. Also, the connection of non-point source pollution to land use means that it must be controlled through land use practices, or the implementation of Best Management Practices (BMPs). For the same reasons we do not understand non-point source pollution, we do not fully understand the effectiveness of BMPs. Furthermore, many landowners are affected by the TMDL program and must be involved in the planning process. Considering that 21,000 water bodies were reported that did not meet

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water quality standards, and that the resources of most state environmental agencies are limited, the challenges facing the TMDL program are obviously substantial. 2.3.4 Wisconsin DNR Nonpoint Pollution Program NR 151 WDNR, believing that the top down technology-based regulatory program of NR 151 would result in the most cost effective and equitable area-wide water quality improvement, believes that a third party TMDL effort would only add to the requirements of NR 151. NR 151 has the following purpose: NR 151.001 Purpose. This chapter establishes runoff pollution performance standards for nonagricultural facilities and transportation facilities and performance standards and prohibitions for agricultural facilities and practices designed to achieve water quality standards as required by s. 281.16 (2) and (3), Stats. This chapter also specifies a process for the development and dissemination of department technical standards to implement the nonagricultural performance standards as required by s. 281.16 (2) (b), Stats. If these performance standards and prohibitions do not achieve water quality standards, this chapter specifies how the department may develop targeted performance standards in conformance with s. NR 151.004. As noted in the above excerpt of the NR 151 rule, the rule makes the assumption that if these standards and prohibitions do not meet water quality standards, the chapter specifies how the department may develop targeted performance standards in conformance with s. NR 151.004. The language of NR 151.004 is as follows: NR 151.004 State targeted performance standards. For some areas, implementation of the statewide performance standards and prohibitions in this chapter may not be sufficient to achieve water quality standards. In those cases, the department shall determine if a specific waterbody will not attain water quality standards after substantial implementation of the performance standards and prohibitions in this chapter, using actual or predicted modeling or monitoring. If the department finds that water quality standards will not be attained using statewide performance standards and prohibitions but the implementation of targeted performance standards would attain water quality standards, the department shall promulgate the targeted performance standards by rule. Note: Pursuant to s. 281.16 (2) (a) and (3) (a), Stats., the performance standards shall be designed to meet state water quality standards. The position of the WDNR is that imposition of the NR 151 performance standards will be required in all cases in the state, and should the performance standards not result in the attainment of water quality standards, then the WDNR would promulgate targeted performance standards as noted in NR 151.004. NR 151 never contemplated that water quality standards could be attained without the imposition of the

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uniform technology standards of NR 151, only that NR 151 was an essential starting point or minimum level of technology that would need to be applied to achieve water quality standards. 2.4 Pathway Decision The MMSDs technical team thought that there was a possibility that the outcome of the third party TMDL may result in a different technology plan and a different water quality improvement than the NR 151 performance standards, based on the results of the WQI planning project. The technical team understood the WDNRs assertion that the TMDL could result in additional requirements over and above NR 151. The technical team suggested using scientific analysis to contribute to a bottom up approach. The technical team based its idea on the analysis of existing water quality data in the watersheds studied in the WQI. Also, the detailed water quality models developed during the WQI planning project were used to assess the impact of NR 151 on water quality. Two model runs were developed with identical assumptions except one model run assumed full implementation (urban measures only) of NR151, and the second run assumed no implementation of NR 151. A further concern existed with regard to the lack of a water quality standard for TSS in Wisconsin. The closest proxy that can be found is the United States Geological Service (USGS) reference concentration for TSS. This estimate was used by the WDNR as the basis for TSS TMDLs in other parts of the state. The reference concentration for TSS, based upon the USGS analysis of watersheds in the southeastern part of Wisconsin, was expressed as a median concentration of 17.2 mg/l. (USGS. Present and Reference Concentrations and Yields of Suspended Sediment in Streams in the Great Lakes Region and Adjacent Areas, Scientific Investigations Report 20065066, 2006.) The existing model run, as summarized in the RWQMPU - SEWRPC Planning Report No. 502 (Appendix N WATER QUALITY SUMMARY STATISTICS FOR THE RECOMMENDED PLAN TABLES) showed the following with regard to the existing condition model output: For the Kinnickinnic River the RWQMPU assessment model looked at 10 assessment points in the Kinnickinnic River Watershed. None of the assessment points had median TSS concentrations which exceeded the USGS Reference concentration TSS level of 17.2 mg/l. The average of all the medians was 4.9 mg/l TSS with a range of median values of 3.8 to 6.5 mg/l TSS. The means averaged 11.7 mg/l TSS with a range of 7.7 to 20.1 mg/l TSS.

One significant result of these water quality model runs was that the TSS concentrations in both the Menomonee and Kinnickinnic River Watersheds, under existing (year 2000) conditions, were below the USGS reference concentration of 17.2 mg/l TSS as a median value. Appendix N of the RWQMPU also shows other water quality parameters studied, as well as the RWQMPU revised year 2020 baseline, the revised baseline with the MMSD action of a five year level of protection (LOP) for SSO, and the two RWQMPU plans one, the recommended plan and the other, the extreme measures condition. This analysis shows that even with the extreme measures condition (implementation of many water quality improvement actions above and beyond NR 151 requirements), the concentration of TSS is not materially changed.

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The data on the existing water quality runs as well as the revised 2020 baseline with and without NR 151 is shown in Appendix 2B. The model runs shown are only for the MMSD assessment points, which are a subset of the RWQMPU assessment points and consist of two assessment points in the Kinnickinnic River. For the Kinnickinnic River, Table 2.1 the following shows the impact of NR 151 on TSS: (Note that the no NR 151 data column is the revised baseline without simulated NR 151 impact, while the next column revised baseline is the same condition with NR 151 simulated impact.)

Total Suspended Solids (TSS) Watershed Assessment Location Measure Units / Criteria No NR 151 4.7 13.0 343 4.7 11.8 347 Revised Baseline 3.8 11.4 344 3.8 10.4 348 Difference -0.9 -1.6 1 -0.9 -1.5 1 NR 151 Impact -18.9% -12.0% 0.2% -19.2% -12.4% 0.2%

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Median mg / L Mean mg / L TSS Guidline Days met (100 mg/L) Median mg / L Mean mg / L TSS Guidline Days met (100 mg/L)

Table 2.1 Impact of NR 151 on Modeled TSS for the Kinnickinnic River

Note that in both tables a TSS guideline is shown. This was developed in the WQI as a measure to assess how many days the watersheds met the guideline to allow for comparison of alternatives since no TSS water quality standard exists. 1) The data show that NR 151 does improve TSS concentrations in a range from about 12% to 20%, in the Kinnickinnic River watershed but the median TSS concentrations are already well below the reference concentration of 17.2 mg/l. 2) The impact of NR 151 on fecal coliform levels, as shown in Appendix B data, is insignificant as the improvement in the percent of time the standard is met in the typical year is no greater than 1% at any of the assessment points in the Kinnickinnic River watershed. . The most frequently exceeded water quality parameter analyzed for the WQI in the GMW was compliance with the existing fecal coliform water quality standards. Thus, based upon the data produced in the RWQMPU, the imposition of NR 151 will have essentially no impact on fecal coliform compliance. Given this complex situation, including the fact that the WDNR was in the process of evaluating the NR 151 rule, and that the timetable for implementation of the rule may be lengthened, the MMSD and the technical team decided to pursue a different path for the development of the detailed implementation

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plan for the WQI. This path, illustrated in Figure 3, was to develop Watershed Restoration Plans (WRPs) instead of third party TMDLs. This effort will be based upon the nine elements of the Clean Water Act section 319 guidelines for developing effective watershed plans for threatened and impaired waters (United States Environmental Protection Agency [USEPA], 2005). The effort mirrors the TMDL concept, but will not result in an actual TMDL or have the regulatory impact of a TMDL. This effort began in July of 2008. The MMSD chose this route because: The steps are basically the same whether doing a TMDL or a Section 319 program (watershed plan). Many grant programs exist to facilitate the development of a 319 program. The 319 based plan produces estimates of load reductions and end points similar to what a TMDL would produce The work product of the 319 Plan can eventually be revised and used as the basis for a TMDL The 319 Plans do not have the regulatory impact of a TMDL, thus they offer different pathways to get to watershed permits, trading, etc. Finally, as shown in Figure 2.3, the Wisconsin DNR has developed an innovative approach to watershed planning that does not require a TMDL. This approach results in Environmental Accountability Plans (EAPs). WDNR and EPA Region 5 have developed this approach which avoids the need for a TMDL and the listing of stream segments on the State 303(d) list, and affords the ability to use the EAP as the route to a watershed permit and eventually watershedbased trading.

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SWWT

Figure 2.3: Framework for the Watershed Restoration Plans The WRP based upon the EPA 319 Plan also affords the ability to develop a watershed plan bottom up versus top down in that the planning effort can assess the water quality based needs of the watershed including the impacts of the NR 151 rule. The WRP will focus on the bottom up versus top down needs and provide all concerned parties (the watershed Communities, concerned citizens and citizen groups, WDNR, USEPA and MMSD) a plan that will look at all water quality impacts including the implementation of NR 151. 2.5 Development of the Watershed Restoration Plan
2.5.1 Overview The WRP represents the next step in the implementation of a truly science-based watershed improvement effort. This work effort will produce an adaptive, phased WRP for the Kinnickinnic River Watershed. The WRP will contain the following: An implementation plan focused on activities that should take place in the near term to meet long-term water quality goals

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A collaborative stakeholder involvement effort that will be based upon interaction with a newly formed partnership called the Southeastern Wisconsin Watersheds Trust (SWWT). This partnership is a voluntary, non-taxing partnership of independent units of government, special purpose districts, agencies, organizations and members at large that share common goals. These entities have agreed to work collaboratively to achieve healthy and sustainable water resources throughout the GMW. Potential additional targeted efforts on green infrastructure, pollutant trading, and social science measures Consideration of sustainability in the development of the WRP

This effort builds upon the sound science, extensive data and alternatives analysis of the WQI. Important issues to be addressed during the development of the WRP will be how to best integrate other ongoing watershed management efforts (e.g., recommendations in the RWQMPU and the MMSD 2020 Facilities Plan, various nonpoint water quality improvements as a result of the Phase 2 stormwater requirements, and the impact of NR 151) with this effort. The technical team expects an approach that incorporates phases and interim milestones will be recommended in the final WRP to address incremental progress toward achieving water quality standards and consistency with the related ongoing projects. An illustration of a potential phasing strategy for implementation of the WRP could be as follows: Phase 1: The first phase of the WRP could include a recommendation to implement already committed projects and programs. As such, the technical analysis underpinning the WRP will start with the existing year 2000 WQI water quality model and add in all the committed projects as of January 1, 2008 using the same approach taken for the WQI. Other known water quality improvement projects that have been finished since the completion of the WQI will also be factored into the analysis. Various pilot projects could then be carried out during Phase 1 implementation activities to address certain key issues (e.g., determine full extent of illicit discharges, implement and evaluate additional green infrastructure projects, and identify and test various agricultural BMPs). This Phase could represent progress in the years 2010 to about 2015. Phase 2: The second phase of the WRP adaptive implementation could include the consideration of Watershed Permits and/or Water Quality Trading, based upon the Watershed Restoration Plans or based upon utilizing the EAP concept. This Phase could represent progress in the years 2013 to about 2018. Phase 3: The third phase of the WRP adaptive implementation could consist of an enhanced level of controls to further improve water quality and would likely include most of the same elements contained in the RWQMPU recommended alternative. An emphasis would be placed on the controls determined to be most successful (technically, socially, and financially) during Phase 1. The development of the initiatives noted in Phase 2 will facilitate this effort. This Phase could represent progress in the years 2016 to about 2020. Phase 4: The final phase of this effort could be the adoption of all controls necessary to fully meet achievable water quality standards, whether those are the existing standards, site-specific standards or future changes in water quality standards. This Phase could occur after 2020.

2.5.2 Detailed Tasks

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The tasks listed below are intended to serve as the technical basis for developing a WRP to meet water quality standards and protect water resources in the Kinnickinnic River watershed. The tasks are organized according to the nine elements of the Clean Water Act section 319 guidelines for developing effective watershed plans for threatened and impaired waters. 1) Identify causes of impairment and pollutant sources that need to be controlled to achieve needed load reductions, and any other goals identified in the watershed plan. This information will be used to develop conceptual plans for the two WRP. 2) Estimate the load reductions expected from management measures. 3) Describe the management measures that will need to be implemented to achieve load reductions, including a description of the critical areas in which those measures will be needed. 4) Estimate the amount of technical and financial assistance needed, associated costs, and/or the sources and authorities that will be relied upon to implement the plan 5) Develop an information and education component to enhance public understanding of the project and encourage early and continued participation. 6) Develop schedule for implementing the identified management measures. 7) Describe interim measurable milestones for determining whether the management measures or other control actions are being implemented. 8) Develop a set of criteria that can be used to determine whether loading reductions are being achieved over time and substantial progress is being made toward attaining water quality standards. 9) Develop a monitoring component to evaluate the effectiveness of the implementation efforts over time. To support development of the WRP, the innovative watershed planning effort will include: A series of workshops with various local organizations to obtain their input on the scope of the WRP effort (to finalize the pollutants to be assessed and to confirm the water quality targets to be used for pollutants without numeric criteria). A series of technical meetings with representatives of WDNR and EPA to obtain their concurrence with the scope of the WRP effort. Some negotiation is assumed in this process between the local organizations and the regulatory agencies until collaborative consensus is reached. An adaptive management and adaptive implementation approach that will allow proposed controls to be implemented, monitored, refined and revisited so that effective implementation of the WRP can be achieved. FPOPs (technologies consisting of Facilities, Programs, Operational improvements and Policies FPOPs) that will be prioritized and organized according to sub-watershed. Prioritization will be based on a cost/benefit approach where costs reflect capital and operational expenditures and benefits reflect the expected reductions in pollutant loadings and progress toward attaining water quality standards. An implementation plan that will include guidance regarding the use of green infrastructure (through pilot projects), social science tools (to obtain agricultural and non-agricultural citizen input), potential watershed permitting options, and identification of opportunities for trading among the various stakeholders in the watershed(s).

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2.6 Summary Plans to improve water quality in the greater Milwaukee watersheds include non-point source controls and managing polluted stormwater runoff. Efforts build upon initiatives over the past thirty years that were directed primarily at controlling point source pollution through the implementation of the Milwaukee Water Pollution Abatement Program and MMSDs Overflow Reduction Plan, which will be completed by 2010. The WRP will be a bottom-up approach, including the regulatory actions required under NR 151 and recognizing the importance of addressing many potential nonpoint pollution sources and working across political or jurisdictional lines. The desired result is to develop actions that will improve water quality in the most cost effective way. It is anticipated that all regulatory and technical issues will be resolved over time through the collaborative efforts of all parties involved in the Kinnickinnic River Watershed Restoration Planning effort.

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APPENDIX 2A

INTEGRATED WATERSHED IMPLEMENTATION PLANNING MEETING AGENDA

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APPENDIX 2B WATER QUALITY DATA EXISTING 2000 AND REVISED 2020 BASELINE WITH AND WITHOUT NR 151

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New Future No NR151 Water Quality (from LSPC Model results) Fecal Coliform Watershed Assessment Location Measure Units / Criteria Existing (For Reference Only) 654 5,785 319 254 214 74% 343 3,360 140 146 110 87% 842 5,859 413 229 214 74% 498 3,401 242 131 110 86% No NR 151 608 4,999 306 261 215 75% 322 3,012 137 148 110 87% 750 5,049 368 244 216 75% 444 3,031 213 138 111 87% Revised Baseline (With NR 151) 560 4,885 295 266 215 75% 295 2,978 116 148 109 86% 702 4,942 361 250 215 75% 416 2,999 195 140 110 86% Difference -48 -114 -11 5 0 0% -26 -34 -21 1 -1 -1% -48 -107 -7 6 -1 0% -27 -32 -19 2 -1 -1% NR 151 Impact -7.9% -2.3% -3.5% 1.8% -0.2% -8.2% -1.1% -15.6% 0.3% -0.8% -6.4% -2.1% -2.0% 2.6% -0.5% -6.2% -1.1% -8.7% 1.7% -0.9%

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Longterm Geometric Mean Counts / 100 ml Mean Counts / 100 ml Median Counts / 100 ml Variance standard - Geomean not to exceed Days met (1,000 counts / 100 m Variance standard - Less than 10% of all samples / month Days met (2,000 counts / 100 m Variance standard - Less than 10% of all samples / month % of time standard is met Longterm Geometric Mean (Swimming season) Counts / 100 ml Mean (Swimming season) Counts / 100 ml Median (Swimming season) Counts / 100 ml Variance standard - Geomean not to exceed (Swimming season) Days met (1,000 counts / 100 m Variance standard - Less than 10% of all samples / month (SwimminDays met (2,000 counts / 100 m Variance standard - Less than 10% of all samples / month (Swimmin% of time standard is met Longterm Geometric Mean Counts / 100 ml Mean Counts / 100 ml Median Counts / 100 ml Variance standard - Geomean not to exceed Days met (1,000 counts / 100 m Variance standard - Less than 10% of all samples / month Days met (2,000 counts / 100 m Variance standard - Less than 10% of all samples / month % of time standard is met Longterm Geometric Mean (Swimming season) Counts / 100 ml Mean (Swimming season) Counts / 100 ml Median (Swimming season) Counts / 100 ml Variance standard - Geomean not to exceed (Swimming season) Days met (1,000 counts / 100 m Variance standard - Less than 10% of all samples / month (SwimminDays met (2,000 counts / 100 m Variance standard - Less than 10% of all samples / month (Swimmin% of time standard is met

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Dissolved Oxygen (DO) Watershed Assessment Location Median Mean Variance standard Variance standard Median Mean Variance standard Variance standard Measure Units / Criteria mg / L mg / L Days met (2 mg/L) % of time standard is met mg / L mg / L Days met (2 mg/L) % of time standard is met Total Suspended Solids (TSS) Watershed Assessment Location Median Mean TSS Guidline Median Mean TSS Guidline Measure Units / Criteria mg / L mg / L Days met (100 mg/L) mg / L mg / L Days met (100 mg/L) Total Nitrogen (TN) Watershed Kinnickinnic River Kinnickinnic River Assessment Location RI-12 RI-13 Median Mean Median Mean Measure mg / L mg / L mg / L mg / L Total Phosphorus (TP) Watershed Assessment Location Median Mean TP Planning Guideline TP Planning Guideline Median Mean TP Planning Guideline TP Planning Guideline Measure Units mg / L mg / L Days TP met (0.1 mg / L) % of time standard is met mg / L mg / L Days TP met (0.1 mg / L) % of time standard is met Copper Watershed Kinnickinnic River Kinnickinnic River Assessment Location RI-12 RI-13 Median Mean Median Mean Measure mg / L mg / L mg / L mg / L Units Existing (For Reference Only) 0.0019 0.0047 0.0019 0.0048 No NR 151 0.0020 0.0043 0.0020 0.0044 Revised Baseline (With NR 151) 0.0017 0.0040 0.0017 0.0040 Difference 0.000 0.000 0.000 0.000 NR 151 Impact -13.6% -7.6% -13.2% -7.4% Existing (For Reference Only) 0.171 0.206 34 24% 0.165 0.196 46 27% No NR 151 0.167 0.201 33 24% 0.160 0.191 45 27% Revised Baseline (With NR 151) 0.164 0.198 37 25% 0.157 0.188 50 27% Difference -0.003 -0.003 4 1% -0.003 -0.003 5 1% NR 151 Impact -1.9% -1.7% 12.8% -2.0% -1.7% 12.0% Units / Criteria Existing (For Reference Only) 1.22 1.39 1.21 1.36 No NR 151 1.19 1.36 1.18 1.32 Revised Baseline (With NR 151) 1.13 1.30 1.12 1.26 Difference -0.07 -0.06 -0.07 -0.06 NR 151 Impact -5.7% -4.2% -5.6% -4.3% Existing (For Reference Only) 4.8 14.5 336 4.7 13.2 341 No NR 151 4.7 13.0 343 4.7 11.8 347 Revised Baseline (With NR 151) 3.8 11.4 344 3.8 10.4 348 Difference -0.9 -1.6 1 -0.9 -1.5 1 NR 151 Impact -18.9% -12.0% 0.2% -19.2% -12.4% 0.2% Existing (For Reference Only) 11.4 11.3 365 100% 11.5 11.4 365 100% No NR 151 11.4 11.3 365 100% 11.5 11.4 365 100% Revised Baseline (With NR 151) 11.4 11.3 365 100% 11.5 11.4 365 100% Difference 0.0 0.0 0 0% 0.0 0.0 0 0% NR 151 Impact 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

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