1 STATE OF MINNESOTA OFFICE OF ADMINISTRATIVE …

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KIRBY A. KENNEDY & ASSOCIATES( 952 ) 922 - 1955

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STATE OF MINNESOTA

OFFICE OF ADMINISTRATIVE HEARINGS

FOR THE

MINNESOTA POLLUTION CONTROL AGENCY

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OAH DOCKET NO. 60-2200-30791Revisor's ID Number 4104

In Re:

Minnesota Pollution Control Agency Proposed Amendments to the Minnesota State Water Quality Rules,Chapters 7050 and 7053, River Eutrophication Standards, Total Suspended Solids Standards and Minor Revisions to Supporting Language.

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HEARING HELD BEFORE

JUDGE JAMES E. LaFAVE

JANUARY 8, 2014

6:00 P. M.

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HEARING HELD before Administrative Law

Judge James E. LaFave at 520 Lafayette Road North,

St. Paul, Minnesota, reported by Barbara J. Carey,

Registered Professional Reporter and Notary Public,

at approximately 6:00 p.m. on January 8, 2014.

wq-rule4-06r

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APPEARANCES :

COUNSEL FOR THE MPCA:

MS. JEAN COLEMAN, STAFF ATTORNEY

MINNESOTA POLLUTION CONTROL AGENCY

520 Lafayette Road North

St. Paul, Minnesota 55155

MPCA PANEL MEMBERS

CAROL NANKIVEL, Rules Coordinator.

STEVEN HEISKARY, Research Scientist III.

PHILIP MONSON, Research Scientist II.

WILL BOUCHARD, Research Scientist.

DAVID CHRISTOPHERSON, MPCA. * * *

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I N D E X

MINNESOTA POLLUTION CONTROL AGENCY PRESENTATIONS:

SPEAKER: PAGE:

Jean Coleman................................ 10

Steven Heiskary............................. 12

Philip Monson............................... 33

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THE COURT: Good evening. My name

is Jim LaFave. I'm an Administrative Law Judge with

the State Office of Administrative Hearings. This

office is independent of the Minnesota Pollution

Control Agency that is proposing to adopt rules

today and any of the groups that are participating

in this hearing. Our role -- the role of our office

is to provide hearings that are required by law in a

way that is fair to all the participants. Among the

other directions from the Legislature, specifically

Minnesota Statute 14.14 and 14.15, rulemaking

hearings are to be conducted so that members of the

public be treated fairly and impartially. I am here

as a part of a larger set of regulatory controls to

ensure this procedural fairness.

It is approximately 6:00 p.m. on

January 8th, 2014, and we are convened in Training

Room Number 2 of the Minnesota Pollution Control

Agency's St. Paul office, as well as by

videoconference to locations in Duluth, Brainerd,

Marshall, Rochester and Detroit Lakes for a public

hearing in the matter of the proposed rules of the

Pollution Control Agency for rule amendments

governing water quality standards, river

eutrophication, total suspended solids, and minor

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corrections and clarification to Minnesota Rule

Chapters 7050 and 7053. This is OAH Docket Number

60-2200-30791, and for those who are interested,

it's Revisor's ID Number -- make sure I get it right

this time -- 4104.

There's a handout on the table entitled,

"State of Minnesota, Office of Administrative

Hearing Rule and Procedures." If you don't have a

copy, please take a moment and pick one up from the

table. It describes the procedures set by the

legislature for hearings like this. While I will

touch upon the highlights, more detailed information

is included in the handout.

This hearing is part of a process by

which agency rules are adopted under the Minnesota

Administrative Procedure Act. The purpose of this

hearing is to develop and receive information on

three key issues under the Act; namely, whether the

Minnesota Pollution Control Agency has the legal

authority to adopt the proposed rules, whether they

have fulfilled all of the legal -- the relevant

legal and procedural requirements in order to

promulgate rules, and finally, whether the MPCA has

demonstrated that among the possible alternatives

for rulemaking that were available to the Agency,

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the rules the Agency proposed are needed and

reasonable.

We are glad to give anyone who will share

comments today a little leeway in developing the

context of their presentations and arguments. I

will simply say that it would be most helpful to me

and the best use of our time if both the Agency

panel members and the members of the public could

focus on the three issues I need to report on.

The agenda for today's hearing will be

that I will complete my explanation of the hearing

procedure. Then, the panel from the Agency will be

introduced. At a previous hearing earlier today,

the Agency entered -- submitted exhibits into the

hearing record. They will -- they will briefly

describe those exhibits for you. There will be a

brief presentation by the Agency, then we'll take a

brief break so folks will have an opportunity to

review the exhibits and digest some of the

information they heard, and finally, most of the

hearing time has been allotted for questions and

statements from members of the public.

In order to make sure that we have an

accurate record of the number of people attending

this hearing, everyone is requested to sign the

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hearing register located on the registration table.

If you wish to speak or submit a written comment

today, you must sign the register. If you wish to

speak, please place a checkmark in the appropriate

column on the hearing register. When you are called

on to speak, please come up to the table and please

make sure that when you begin speaking, please state

and spell your name and give your address and

identify the group or interest you represent, if

any.

A rule hearing like this one is similar

to a legislative hearing or a meeting of a local

board. You will have the opportunity to talk and

ask questions of other participants. This is not

like a court trial. Any speaker may ask questions

of the Agency Panel, and you may also be questioned

by the Agency Panel, the Administrative Law Judge,

or other persons present at the hearing.

Because this is not like a court hearing,

you do not need to make your points you wish by

asking questions. You can state what your own views

are and go directly to the point. It is also

helpful that if you have specific points as to

particular sections of the rule, that you identify

those sections. The record we make here today may

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be reviewed by others later, and we want to make

sure that it is clear about what matter your

addressing.

This hearing is being transcribed by a

court reporter. It is very important that we attain

an accurate record of this hearing. I, therefore,

would ask all speakers to remember the following:

That it is important that you speak

clearly and slowly and loud enough that we can hear

you; that all statements must be clearly spoken.

For example, we cannot record a nod of the head.

Please spell out all proper names and technical

terms the first time they are used, and I would ask

that only one person speak at a time.

I may interrupt a speaker from time to

time to ask for a spelling or remind you of these

other points. I hope you will not take offense. I

want to just ensure that we have an accurate record

of what you are saying.

If you have a copy -- a written copy of

your remarks that you can leave here as an exhibit,

please do so; that would be very helpful. You can

also submit your comments in writing after the

hearing. Comments should be submitted to my office

at the address indicated on the back of the handout.

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It is helpful if folks submitting comments to our

office reference the Docket Number in this case, and

again, that number is 60-2200-30791.

After the close of the hearing today, you

will have 20 calendar days, until 4:30 p.m. on

Tuesday, January 28th, 2014, to submit any written

comments. There will then be a five-working-day

rebuttal period will close at 4:30 p.m. on

February 4th, 2014.

The second period is not an opportunity

to submit your initial comments or evidence. As

Minnesota Statute 14.15 states, "Additional evidence

may not be submitted during this five-day rebuttal

period." Instead, it is an opportunity for you to

review and respond to comments already submitted by

the Agency or by others during the first comment

period.

After the second deadline passes, I will

prepare a report that will contain my decision about

whether the Agency has met the burdens I discussed

earlier; namely, whether the Agency has documented

its statutory authority; whether the Agency has

demonstrated that it has fulfil led all the necessary

legal and procedural requirements; and finally,

whether the Agency has demonstrated the need for and

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reasonableness of each portion of the proposed

rules.

If you want a copy of my report, please

put your name and address on one of the envelopes at

the sign-in table, and we will see that you get

notice when the report is available and you will be

informed on how to obtain a copy.

The handout goes into other details about

the process.

(Discussion off the record.)

THE COURT: The handout goes into

other details about the hearing process that occurs

after my report is issued. I'm not going to discuss

that part of the process. You can read about it at

your leisure.

Are there any questions about the hearing

procedures? If not, then we will begin with the

Agency's presentation.

Ms. Coleman?

JEAN COLEMAN: Thank you, Your

Honor. If we could perhaps have the microphone

moved over to the center.

THE COURT: Over to your side, even.

Thanks.

JEAN COLEMAN: As I introduced this

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morning, my name is Jean Coleman, and I'm a staff

attorney with the Minnesota Pollution Control

Agency, and I'm appearing in this rule hearing for

and on behalf of the Minnesota Pollution Control

Agency.

The hearing exhibits were entered into

the hearing record this morning, and so this evening

I will go over them briefly in a summary way. They

are available in the back of the room in a binder in

hard copy, and they are also available on the

Agency's website.

The exhibits, as stated, serve three

purposes: Hearing Exhibit 2 and Hearing Exhibit 3

are the rules and The Statement of Need and

Reasonableness, and they document the legal

authority of the Minnesota Pollution Control Agency

to adopt the proposed rules and demonstrate that

each portion of the Proposed Rule is needed and is

reasonable.

Many of the exhibits demonstrate that the

Agency has fulfilled all relevant legal and

procedural requirements, and then there are

additional hearing exhibits at the end of or at the

back of the binder that include minor corrections, a

new proposed definition for eutrophication

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standards, and two additional documents to support

the need for and reasonableness of the River

Nutrient Region Map.

I will introduce two MPCA staff who are

going to make a brief presentation this evening.

There are additional PCA staff who are here today to

be available to answer specific questions. I will

ask that they introduce themselves at the time that

they approach the front to answer any questions.

First, Steve Heiskary, to my immediate

right, will present on the proposed water quality

standards for river eutrophication, and

Philip Monson will present on the proposed water

quality standards for total suspended solids.

And at this point, I would like to move

into the presentation unless there are any

questions.

THE COURT: No questions. Please

proceed.

STEVEN HEISKARY: Might we dispatch

the little picture there?

Your Honor, we're pleased to be here

today to share with you a brief overview of our

proposed water quality -- water quality standards.

THE COURT: Before we begin, do we

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know are the -- just in case some folks have gone to

the remote sites, are the remote sites getting

the --

JEAN COLEMAN: Marshall is not, and

there are no people at Marshall yet.

THE COURT: Okay. Make sure you

have them buzz us if -- this is the really good part

so we don't want them to miss it.

Sorry, I don't want to build up --

anyway, continue. Please continue.

STEVEN HEISKARY: All right. So

what we intend to do here over the next few moments

is provide a brief introduction to the proposed

water quality standards.

TECHNICIAN: Steve, I interrupt for

just a moment? The regions can't see us right now,

so I'm going to have to restart this real quick.

THE COURT: Okay. We'll just take a

brief recess to restart the video connection.

(Whereupon, a recess was taken.)

THE COURT: We're back on the

record. Please proceed.

STEVEN HEISKARY: All right. As I

was saying, what we're going to do here over the

next few moments is provide a brief introduction to

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the proposed water quality standards; that is,

first, the river eutrophication standards and

site-specific standards for Lake Pepin and the

Mississippi River and navigational pools. We'll

follow up with the total suspended solids standards.

As we do this, we're going to make

specific reference to SONAR Book 2 on eutrophication

and Book 3 on full suspended solids for additional

information. So if anybody wants to drill down a

little bit into what we're saying or where there's

further information provided.

Okay. The need for standards. This

responds to the long-standing USEPA requirement that

states adopt nutrient standards.

Secondly, this addresses the impact of

excess phosphorus on rivers and streams and then

site-specific standards for Lake Pepin and the

Mississippi River Navigational Pools.

And thirdly, this complements or 2008

lake eutrophication standards.

Regions, please mute your -- mute your

line. You don't want us to hear what you're saying.

THE COURT: Thank you. Would the

folks at the remote location please --

STEVEN HEISKARY: Mute your lines.

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SPEAKER: We believe it's a training

room that there's somebody outside of -- not the

training room, the other room in St. Paul that's not

muted.

THE COURT: Thank you, very much.

SPEAKER: Yep.

STEVEN HEISKARY: Okay. One of the

terms that we're going to use a lot throughout the

presentation is "eutrophication," and this implies

the nutrient over-enrichment of waters and the

excessive growth of algae and plants that results

from that nutrient over-enrichment.

We've been often asked why not recommend

just a nutrient or phosphorus standard, and clearly,

we're responding to our stakeholders that have

indicated the need to determine or demonstrate the

impact of excess phosphorus on streams, and this is

very similar to what we did in the lake

eutrophication standards.

In some cases, the response to nutrient

over-enrichment is quite obvious. We see the

Blue Earth River, Watonwan, Minnesota and Pipestone

Creek here. These are very nutrient-rich systems,

and we can see the mats of algae at the surface of

them, so it's very obvious in these cases. However,

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in many cases, the impact of phosphorus on rivers is

much more subtle, and it can be difficult to make

that direct linkage between phosphorus and

biological condition. When I talk about biological

condition, I'm talking about the invertebrates that

live in the bottom of the stream. I'm talking about

the fish that live there. So -- and this -- making

this linkage is critical to us, and to do that, we

need to make these various linkages, and we have an

abbreviated conceptional model here to help

demonstrate that.

That is, as phosphorus in these systems

increase, we get increases in the suspended algae.

We'll also get increases in bacterial growth and

metabolism. Both of these can contribute to

increases in the biochemical oxygen demand,

abbreviated BOD, and can also influence the

fluctuation of dissolved oxygen over the course of

the day. A term we introduce is "daily DO flux,"

the maximum oxygen concentration during the day

minus the minimum. So that is our flux term that

we'll talk more about in a moment. And then

ultimately, impacts on biological condition, and

we'll demonstrate further how these linkages are

made through our data collections, and subsequently,

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through our statistical analysis.

We've been at this for a long time. Our

studies took place over the course of about 10

years. The early focus of our work was on medium to

large rivers, rivers you'd be quite familiar with;

things like the Crow River, the Mississippi River,

the Rum River. We tried to get rivers throughout

the various ecoregions across Minnesota. In total,

we have about 40 river sites where we have very

detailed information on the nutrients, the suspended

algae, biology; that is, the actual collection of

fish and invertebrates, and these continuous

dissolved oxygen measurements, which we'll talk a

little more about in a moment.

Then to augment this, we went to all the

data that's collected through our Biological

Monitoring Program, and we were able to add hundreds

of sites. So data from hundreds of sites were

brought into this process, also allowed us to get a

broader representation of stream sizes. So we've

got many of the smaller streams which were not

included in our earlier work.

This -- we take all this data together,

and it starts to demonstrate a variety of things.

One of the earlier things was this strong

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relationship between phosphorus and the suspended

algae or phosphorus and chlorophyll, is the term we

use. The graph we have here is log phosphorus on

the X axis and log for fillet on the Y axis. We see

dots in blue there. These represent the larger

non-wadeable streams, and the red triangles are the

shallower wadeable streams.

The regression we have here -- and it's

highly significant regression, 0.81, our score --

was drawn based on the non-wadeable sites, but we

see a couple of things relative to the wadeable

sites. In general, they produce less algae per unit

phosphorus. However, we do see that some of them

respond -- and I'm pointing right near the

regression line here, fairly close to the

non-wadeable systems, as well. So they do have the

capacity. Some of these streams do have the

capacity to produce excess algae when there is

excess nutrients in the system.

We offer up two examples here: The Crow

River, a very nutrient-rich river, 300 micrograms

per liter. Again, when we use this term,

"micrograms per liter," that's equivalent to parts

per billion. High TP; we get high amounts of algae

in that system. The Little Fork in Northern

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Minnesota, very low phosphorus; phosphorus averaging

about 20 micrograms per liter and very low amounts

of algae in that system.

We made mention of this cycling of

dissolved oxygen, and to help us understand that, we

instrumented, I think it was about 35 of those sites

with the kind of equipment that's here. We put

those -- we suspend those in the bottom of the

stream, and then they automatically take

measurements.

What we've got here are two examples

again. In the upper left, the Crow River, lower

right the Little Fork. Again, the Crow, high

phosphorus system. Across the X axis we see dates

from late July to early August in summer of 2006,

and what we see is very large fluctuations of oxygen

over the course of these days, and on average,

that's about 7 milligrams per liter. And we also

see in that system that we have some excursions

below the existing 5 milligrams per liter dissolved

oxygen water quality standard, so not only a very

large flux, but also we're actually violating the

existing water quality standard in that system.

In contrast, a system with low

phosphorus, low amounts of algae, we see that this

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flux term is very small. It 's about 2 milligrams

per liter. It's moving between about 7 to maybe up

to 9 milligrams per liter and never falling below

the dissolved oxygen standard.

THE COURT: Is there an amount of

dissolved oxygen that's preferable, or is there --

is there a number that's desirable?

STEVEN HEISKARY: For these -- these

are both -- these would be both classed 2B streams.

5 milligrams per liter would be the water quality

standard. So for fish and other aquatic life, it 's

basically saying that as long as oxygen is staying

above that level, we're -- that's an adequate level

to support fish. If these were cold-water streams,

they'd require a little more oxygen and that

standard's a little different.

So as this stays above 5 --

THE COURT: It's all good.

STEVEN HEISKARY: It's a good thing.

It's meeting standards.

THE COURT: Keep going. Thank you,

though.

STEVEN HEISKARY: Okay. In

addition, so now we've developed a lot of these -- a

lot of these data sets. We've brought in all this

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information that I've talked about. You'll see many

data points on these graphs. We made use of

EPA-recommended statistical approaches to relate

phosphorus, and actually we've related chlorophyll

and these other factors, as well, to biological

condition.

We have just a -- these are just -- just

examples here, but the two statistical approaches --

on the left is quantile regression. On that kind

of -- that kind of regression, that automatically --

it's helping us to determine where thresholds or

breakpoints are and we can see here there's an upper

breakpoint noted, and that's critical -- critical to

our process so the statistic is helping us to

identify where we have significant changes or where,

in this case, the percent sensitive fish individuals

seems to be responding to increases in phosphorus

creation.

The other technique we use, another

EPA-recommended technique, change-point analysis or

also referred to as regression-tree, takes a little

different approach, but again, it 's seeking out

thresholds, again, where, in this case, its

invertebrate taxa richness, we see things --

basically, things are doing real well. I'm pointing

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at the upper -- upper left of this -- this graph.

Then, as we get into for nutrient-enriched --

phosphorus-enriched conditions here, we start to see

a distinct decline where we're seeing a lot fewer

invertebrate taxa. The statistic here is picking it

up in this particular case, and there's not a whole

lot of cases like it. Your eye would find that --

that threshold, as does the statistic, but again,

these statistics are very important for detecting

these thresholds.

We've long known that the Minnesota

streams and lakes exhibit distinct regional patterns

in their water quality. The patterns are caused by

differences in land form, soil type, potential

natural vegetation and land use, which are the basis

of the EPA-mapped ecoregions. EPA, in their

guidance documents, we have several exhibits that

talk about that, recommends a regional approach when

developing nutrient standards. MPCA then developed

river nutrient regions based on the underlying EPA

ecoregion map, and then we accounted for rivers

basically moving from one region to the next and

perhaps the most straightforward example of that

might be here, I'm pointing to the map, the

Mississippi River. Let's see, we have staff sitting

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in the Brainerd office right now. It is a northern

river because it flows through Brainerd and even as

it flows down here, I would say, approaching

St. Cloud; at this point, though, more water is

draining in from watersheds that are in the central

portion. It is -- it is at that point we've

indicated a shift in where we're -- we're going to

call the Mississippi River a northern river versus a

central river for the purpose of the river

nutrient -- river nutrient regions here, and we

explain the process, include detail maps in SONAR

and also in Exhibit EU-5.

Okay. So we've done -- we've done this

work. We've pulled together this -- this data. We

use, then, these multiple lines of evidence to help

us derive our criteria. We start at the panel on

the lower left there. So we define relationships

using basic correlation and regression. Basically,

we're just plotting stuff up. We're trying to see

how -- how things relate. We move from there, after

we've -- we've got a sense of how these things start

to relate, we move onto the more sophisticated

approaches, looking for threshold concentrations for

the fish and invertebrates using the quantile

regression and change-point analysis.

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We've also used an approach where we look

at regional reference conditions, and we put a lot

of time into review of the literature and we

incorporate that as appropriate, as well. Bringing

that all together, we summarize the results, and we

recommend the numeric nutrient criteria, which we

bring to you today.

Here they are. The criteria are by

region, north, central and south, they have the

causative variable phosphorus and our three response

criteria, that is: Chlorophyll, the suspended

algae, dissolved oxygen flux and biochemical oxygen

demand. The numbers we have presented here, these

are -- these would be summer averages. When we

actually assess rivers to see if they meet the

standards, our -- our minimum requirements are going

to be that we have to monitor those rivers a minimum

of two summers. Many of the rivers that we'll

assess will have much more data than that, but a

minimum of two summers; and every summer that's

included, that needs six or more observations. So

we want a nice, robust dataset spread out over the

course of those summers to help us characterize

conditions and allow, then, for valid assessments to

take place, and if, then, the phosphorus criteria

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and one or more of the response variables is

exceeded, the water quality standard's violated and

that river reach is deemed impaired.

To provide some perspective here, we've

done -- the formal name for it is a cumulative

distribution function, but let's just call them

distributions of phosphorus values for the three

regions.

In blue, we have distributions for the

northern streams. Green central, and red is the

southern streams. On the bottom, that's phosphorus

concentration, and on the Y axis, that's a

proportion of sites. So a couple of things that

this -- that this -- this gives us; one, it clearly

demonstrates a distinct regional patterns,

abundantly clear from this -- this -- these

distributions. Secondly, it provides a basis just

to approximate -- approximate is a good term here

and the percent of river reaches that potentially

exceed the phosphorus standard. We look in blue

here, that the 50 -- the proposed 50-microgram

standard, bring that up, that's at about the 50th

percentile. So about half are lower, about half are

higher. Central, 100, it 's about 35th percentile,

meaning about 65 percent have a higher phosphorus

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concentration, and the south, 150, it 's at about 25,

so about 75 percent. And this is based on quite a

few river sites. Each one's based on about a 100 to

200 sites per region. So I think this is a fairly

robust and a reasonably accurate reflection of

phosphorus concentrations across those regions.

In addition to our actual numeric

standards, we've developed a -- what we're going to

call a numeric translator to help us address rivers

where there's excess periphyton. Periphyton being

the algae that grows on the bop of the stream.

Before, we were talking about the algae that's up in

the water column. Now, we're talking about the

stuff that gross on the bottom. We have some

pictures here that show different levels of that;

and we're basing this largely on the literature, and

there's abundant literature on this topic, and that

literature suggests that biomass concentrations of

about 150 milligrams of chlorophyll-A per square

meter or less protects the streams' beneficial uses

and higher biomass is considered polluted with the

loss of uses.

Again, it 's a numeric translator of the

narrative language that -- basically the narrative

language says something to the effect of not -- does

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not allow for noxious growth of algae. But as a

translator, there's no nutrient concentrations

associated with that biomass and what that will

require is when we -- we find river reaches that are

above that amount, we'll have to go into the

stressor ID process to figure out what's causing

those excessive amounts. So just because this

numeric translator is exceeded, it doesn't directly

go back in and require nutrient reductions, and

things like that, immediately. Rather, there's this

stressor ID process to work -- work through this and

fully understand why that site has such excessive

periphyton.

In addition to these river standards,

we're -- we've included site-specific standards for

the Mississippi River Navigational Pools and

Lake Pepin. The navigational pools are transitional

water bodies. They are not truly free-flowing

rivers, nor are they true reservoirs, developed to

move commerce, basically, on the river, barges up

and down the river. That's why they were put -- put

in place, but they support a variety of -- a variety

of uses, as you can see the pictures, here. People

are boating there, they're fishing there, they're

swimming there. These are important bodies of water

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and we need to protect them for that use. We've

highlighted a just a couple of examples here.

Upper left, red -- that -- in red there,

that's Pool 2, which is right outside our door here.

That extends all the way through Spring Lake.

Pool 4 is -- includes Lake Pepin, and

then there's four other pools below that that go on

down to the Iowa border. So site-specific standards

for these.

The need, if we look back at Lake Pepin

during the summer of 1988, very severe -- very

severe blooms and fish kills that resulted. But

even in more recent years, we see the continuation

of severe algal blooms in Pool 4.

The water quality standards we're

proposing seek to maintain the aquatic recreational

use, and our emphasis is going to be on minimizing

the frequency of algal blooms. We've done a lot of

work on this. We have a mechanistic model that was

development for this. This graph, here, is an

example of results from that model, and what that

has on the X axis, phosphorus concentration, and on

the Y axis, that's a number of days with chlorophyll

greater than 50 micrograms per liter. 50 micrograms

would represent severe nuisance blooms. Our

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emphasis here is we want to reduce the intensity and

frequency of those blooms, and what the modeling and

data tell us is that if we can get phosphorus

concentrations down to about 100, it 's this --

again, point 1 milligrams per liter or 100

micrograms per liter -- we could get the intensity

of those blooms, the frequency of those blooms, down

to less than about five days, so that's -- that's a

big emphasis for these systems.

Here, then, are the standards for the

pools. In Pepin, we have proposed phosphorus and

chlorophyll standards. We've also included the

Mississippi River that should be the central --

central nutrient region, southern nutrient region,

which would apply to the Minnesota River and Lake

St. Croix, which -- which has its own -- own

standard, there, just for comparison purposes.

So the -- the idea, here, and the

modeling has helped us understand that, is that

these systems all work together. The modeling is

demonstrated for us. If we can meet the standards

for the Mississippi where it comes into the Twin

Cities, the Minnesota River where it comes into the

Twin Cities area, Lake St. Croix will meet its

standard. We do that, we're going to be able to

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meet these standards which are going to protect the

health of the pools and Lake Pepin.

In addition, given that these are border

waters -- from Pool 3 on down, they're border waters

with the State of Wisconsin -- it was important that

we work with them, and that's exactly what we did,

and we took into account that their promulgated

phosphorus standard is 100 micrograms per liter. So

we've been in discussions, we've worked with them on

this, and we believe we are in agreement with them

for these waters.

THE COURT: I do have a couple this

time. Back on Slide 14, to be found in violation,

you have to exceed the total phosphorus. So let's

take the north region, for example.

STEVEN HEISKARY: Yes.

THE COURT: So if you're in excess

of 50, you have to violate that plus have -- violate

one of the response criteria.

STEVEN HEISKARY: Yes.

THE COURT: And it says that the

assessments require a minimum of two summer and then

six or more -- I'm not clear on what the 6 or more

observations by summer.

STEVEN HEISKARY: That means that

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the river would be sampled six or more times.

THE COURT: Is there -- is there

timeframe within which --

STEVEN HEISKARY: That is a very

good question. I wasn't clear enough on that.

Summer, in this case, is June through September. So

the sampling must take place --

THE COURT: So if you have one bad

sample in August of 2014 and then a bad sample in

June of 2015, that wouldn't qualify as two -- you

need to have them within the same calendar year.

STEVEN HEISKARY: What they are, the

way we're approaching -- again, a very good

question. The way we're approaching these

assessments is the same way we address lakes. What

we'll do is, those samples will be -- will be taken,

analyzed, and we will average those results. So in

the case of -- we have a river that's monitored over

the course of two summers. It has at least 12

observations collected over -- over that time

period. We'd average those results. We'd take

those average results, and we'd match -- match them

against the phosphorus and, in this case, we're

saying we're measuring chlorophyll and match them

against that to see if they meet standards. So it's

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used in a different fashion than the total suspended

solids which we're -- so it's a little -- it's

consistent with what we do on lakes -- lakes with a

very similar approach where we need to monitor them

a couple of summers and then we average the results

and compare to the lake eutrophication standards.

THE COURT: Okay. And then, moving

to Slide 20, so on this -- in this particular

example -- so if there was going to be a violation

in let's say Lake St. Croix, you'd have to have a

phosphorus reading of over 40, plus a

chlorophyll-A -- or is -- plus a chlorophyll-A, or

are there other response -- responses.

STEVEN HEISKARY: It would -- again,

it's a good question.

THE COURT: Response criteria.

STEVEN HEISKARY: Quickly,

Lake St. Croix -- Lake St. Croix was already

assessed using our lake eutrophication standards.

THE COURT: Okay.

STEVEN HEISKARY: The lake was

deemed impaired. These are the -- these are the

standard for -- that it needs to meet, and they are

-- between Minnesota and Wisconsin, efforts are

underway to already -- to meet these. So it's

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further along in the process. We're not talking

about assessing it at this -- we're talking about we

need to get it to here, we need to get it below here

and we need to meet this. We do that, then it's in

compliance with the standards.

THE COURT: If it's outside of one,

it's not in compliance.

STEVEN HEISKARY: That the pretty

much -- pretty much it.

THE COURT: It's a little bit of an

oversimplification.

STEVEN HEISKARY: Yeah, once we're

in -- when we're into the implementation, we --

we've done modeling, we've figured out how much has

to be reduced to meet the TMDL, our focus becomes on

this 40. We need to do the things out in the

watershed that bring the phosphorus concentration of

lake down to 40, and based on our understanding of

the relationships and our standards, we have every

reason to believe it's going to meet that 14 at that

time.

THE COURT: Okay. Got it. Thank

you, very much.

STEVEN HEISKARY: Thank you.

PHILIP MONSON: Your Honor, my name

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is Phil Monson. I'm a research scientist with the

Minnesota Pollution Control Agency working in our

standards unit. Today -- this evening, I'm here to

talk to you about our proposed total suspended

solids water quality standard.

The need for protection of aquatic

resources for suspended solids within aquatic

environments is pretty well established. Suspended

solids have direct effects -- physical effects on

aquatic animals, smothering gills, smothering eggs,

can actually be, you know, outright harmful in terms

of just in higher loads, hitting -- hitting

organisms and injuring them. The -- there is an

existing -- in our rules, we do have an existing

turbidity standard which accounts for some of that.

However, it's -- it 's -- it 's a non-quantifiable

amount. It's a unitless approach that's -- that's

used, and it also is -- is something that does not

have much biological base in terms of how those

numbers are set; and one more thing, it 's also a

state-wide value, and all of those pieces are going

to come into the approach that we use for developing

or revising our -- our proposed total suspended

solids water quality standard.

Part of it is because now we are working

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with a quantitative measurement of the suspended

solids, an actually laboratory measurement which, in

that case, a sample would be taken from a water

body, brought to a lab and a very consistent

methodology is always used in approach for measuring

that value for total suspended solids.

In our existing case, with using a

turbidity, we're using meters. It's a field

measurement. Yes, it might be a little bit --

little bit faster, however, there's a variety of

meters, there's a variety of methods for calibrating

them. There's different technicians using them.

There's a fair amount of potential for error.

Another aspect of the quantifiable in our

-- in our -- in our -- our proposed TSS standard is

that we can actually calculate loads which are very

important in terms of dealing with impairments, when

we are setting up total maximum daily loads to know

what are the levels that we need to achieve for --

to get into compliance with -- with our -- with this

new approach using total suspended solids.

Another aspect of our proposed total

suspended solids is using the same river nutrient

criteria that Steve covered across the state. We

felt this was reasonable to do because we

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recognize -- and it is recognized that there are

regional differences across the state in terms of

watershed, landscaped use, all the kinds of things

at that Steve outlined; soil types that were really

put into place for developing those river-nutrient

regions across the state.

And finally, with this proposed total

suspended solids standard, it is a strong biological

effects database. It was looked at and considered

and we'll go into that in a little more detail,

here, but really looking at what are the effects of

total suspended solids on fish, on invertebrate, on

a variety of different groupings of those that were

looked at, these metrics that we'll talk about.

So real briefly, here, we saw this

earlier, describing a river nutrient regions across

the state. Same -- exact same slide that Steve

covered. You know, really the same rationale in

terms of how it was developed, why it was developed.

A very strong EPA approach looking at those regional

patterns across the landscape and really provides a

sound basis for us to -- to be looking at the

different regions across our very diverse state.

Again, similar -- really, the same slide

at that Steve showed where we are using multiple

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lines of evidence for -- were used in terms of

developing this water quality standard. Certainly

in part looking at those relationships from

correlation regression, seeing where -- where two --

two variables compare, and then going into a little

more detail with both biological data. As you see

up here, in the corner -- upper corner -- upper-left

corner slide of -- of quantile regression and

change-point analysis. Again, Steve covered those

into pretty good depth, as well as an approach of

looking at regional reference conditions through --

through examining the data for really the period of

record, 20-plus years of information that's out

there, and again, we'll go into a little more

detail.

Finally, the literature review is also

important. There is a body of literature out there

that -- that details effects on biology and -- and

also comparisons to landscape and suspended solids,

quite a bit -- quite a -- pretty good literature --

literature review.

So to kind of go briefly on how

reference-stream approach was taken, the data were

looked at. Really they're all seasonal data, for

the most part. Most of our monitoring does occur in

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that kind of open water, April-through-September

time period.

Sites were considered within this

investigation had at least 15 data points. These

data points, and there were, again, about 168 sites

that were finally selected on this, we took up to

about the 90 percentile of those, and the reason for

that is that it 's recognized that over the years,

samples have been taken at a variety of times, and

we also recognized that some of these times might

have been fairly high flow, after storm events,

things like that. We didn't want to necessarily

bias those averages that where we actually come down

to in terms of developing a reference approach by

including all of those very -- fairly high numbers

and so up to about the 90th percentile values were

used. As I said, the data were averaged from the

sites within each stream.

The tributaries of large rivers were

separated out and looked at separately, and finally,

the value for the total suspended solids were based

on the regions for the reference condition within

those regions.

So here is a table that outlines the

final values, if you will, that after examining the

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data for the different river nutrient regions -- and

also I want to point out that the Red River main

stem was pulled out, as well, as a special case.

There's a different sort of approach that was --

that was used to examine the Red River. There is --

there does tend to be a little higher background

within that -- within that region, and so it was

selected out from --

THE COURT: What do you mean by

higher background?

PHILIP MONSON: Higher background in

terms of -- in terms of the watershed that's

carrying the water into the Red River. It 's a

siltier area and things like that. And so that was

recognized and it didn't seem to be appropriate to

necessarily lump it into one of the river nutrient

regions and it's -- it 's been -- it's been a

longstanding consideration out there.

The biological data, then, again looked

at using both quantile regression or QR and change-

point analysis that are lined up in this table for a

variety of different metrics. Again, you can see

these metrics are both for fish and invertebrates

and also cover the different regions, are the way --

that the -- that measured the effects of suspended

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solids on these different ways to look at different

groupings of fish, different kinds of invertebrates,

et cetera. There were about 200 -- 200 analyses,

statistical analyses that were done to -- to pull

all these data together when they're available. You

can see for some of these, it couldn't be done, so

there's certain blanks in there that we -- we

couldn't fil l in those data points, but that's fine.

We had a variety of different metrics that were

looked at, and we saw a similar slide that Steve

showed where -- where quantile regression and

change-point analysis really reflect what's going on

with the data. You can kind of eyeball and see,

well, there is a definite change based on

concentration of suspended solids which you see on

the X axis and the percent sensitive individuals

that decrease with increase in suspended solids.

But the -- really, the point is that both quantile

regression and change point are statistical

approaches. You have -- you have variables or you

have -- I'm trying to think of my terms, here. You

have an average, and that's the solid lines, there,

but then you have -- you have your variables or your

variability of the other two lines that are -- that

are shown on the map. It's just -- just an example

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where the statistical approach is much better

approach than -- than simply eyeballing, is really

my point of that.

Another component to that is regarding

the metrics, there are recognized that not all of

them will provide the most sensitive endpoint, if

you will, for either the fish or the invertebrates

that are being looked at, and so the approach taken

was using the 25th percentile. So weighing towards

more sensitive types of metrics and providing for a

little more protective values that were finally --

finally brought out, and as you see in this -- in

this table, circled in the -- in the red, for the

river-nutrient regions, and, in this case, as well,

the trout streams, or Class 2-A waters, were pulled

out as another -- a separate examination, which is

actually similar to what we have in our -- our

existing role where we actually do have a separate

turbidity value for trout streams, statewide, and so

we're really trying to -- to continue that with the

recognition that trout streams are very valuable and

typically are the higher quality streams, highest

quality streams across the state.

So I think, finally, then, our -- our

kind of summary slide of showing our tables,

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including both our reference data and the biology

data, and then, finally, the final water-quality

standards were a combination of that, again, where

we did have both -- both datasets available to us to

come up with our -- our -- to come up with our --

our total suspended solid water-quality standard.

Now, these will be concentrations that

would be implemented as those exceeded no more than

10 percent of the time, and also, there's that

period of April through September where -- where

it's the terms of implementation.

One last piece that we will include

within this rulemaking are site-specific standards

that were developed for lower Mississippi, Pools 2

through 4, and that includes that Lake Pepin area

that Steve described, and that was -- that has been

adopted by us as a site-specific standard, approved

by EPA and we're bringing it into this rulemaking

because it's administratively efficient. There's an

ease of access to pull it in now versus a separate

rulemaking, and it had already been adopted as a

site-specific standard, so it was -- it was an easy

one to bring into place.

We also are considering or proposing a

site-specific standard for the remainder of that

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lower Mississippi reach below Pool 4, and you see

the respective values for those for -- for -- for

total suspended solids.

Now, the difference between these

water-quality standards and the ones I've just been

describing is the main focus of protection is

submerged aquatic vegetation. Steve described it

well where these are kind of between rivers and

lakes, and the need and the necessity of maintaining

quality submerged aquatic vegetation is pretty well

documented. Suspended solids is something which

blocks out light, potentially smothers -- smothers

plants, et cetera. It is very important to these --

to these ecosystems in the Mississippi River.

Another piece to -- that's a little bit

different is the implementation of this will be

based on a summer average, so that's a

June-through-August time period or June through

September, I'm sorry, and it needs to be met in at

least half of the summers of the monitoring period

for -- for the dataset. So a little bit different

implementation schedule for those, but -- but based

in -- in -- in good science and -- and reasonable

approach for developing suspended solid standards

for these -- for this part of the Mississippi River.

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44

I think that's the end of it.

THE COURT: Thank you, very much.

PHILIP MONSON: You're welcome.

THE COURT: Right now, we'll take a

10-minute break to give you folks a chance to look

at the exhibits and then we'll come back and take

some public testimony. We're on 10-minute recess.

Thank you.

(Whereupon, a recess was taken.)

THE COURT: All right. We are back

on the record. I did check the signup sheet and I

noticed that at this point, there are no one -- no

one wants to make any public comments, but I' l l

give -- give the folks in the audience one more

chance. Going once. Going twice. All right.

Thank you all very much for attending this evening.

I very much appreciate it. It 's very, very helpful

to the process. This hearing is adjourned. And I

would remind you all, again, please submit written

comments. They're very much encouraged. Thank you,

again. Have a good evening. This hearing is

adjourned.

(Whereupon, at 7:15 p.m., on

Wednesday, January 8, 2014, the

Rulemaking Hearing was adjourned.)

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45

STATE OF MINNESOTA) )COUNTY OF ANOKA )

REPORTER'S CERTIFICATE

I, Barbara J. Carey, do hereby certify

that the above and foregoing transcript, consisting

of the preceding 44 pages is a correct transcript of

my stenograph notes, and is a full, true and

complete transcript of the proceedings to the best

of my ability.

Dated January 15, 2014

________________________________ Barbara J. Carey, RPR Court Reporter

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29:4, 29:5, 30:812 [2] - 3:9, 31:1914 [2] - 30:13, 33:2014.14 [1] - 4:1114.15 [2] - 4:11, 9:1215 [2] - 38:4, 45:14150 [2] - 26:1, 26:19168 [1] - 38:51988 [1] - 28:11

2

2 [6] - 4:18, 11:13, 14:7, 20:1, 28:4, 42:14

2-A [1] - 41:1520 [3] - 9:5, 19:2,

32:820-plus [1] - 37:13200 [3] - 26:4, 40:32006 [1] - 19:152008 [1] - 14:192014 [8] - 1:18, 1:25,

4:17, 9:6, 9:9, 31:9, 44:24, 45:14

2015 [1] - 31:1025 [1] - 26:125th [1] - 41:928th [1] - 9:62B [1] - 20:9

3

3 [3] - 11:13, 14:8, 30:4

300 [1] - 18:2133 [1] - 3:1035 [1] - 19:635th [1] - 25:24

4

4 [4] - 28:6, 28:14, 42:15, 43:1

40 [4] - 17:9, 32:11, 33:16, 33:18

4104 [2] - 1:8, 5:544 [1] - 45:94:30 [2] - 9:5, 9:84th [1] - 9:9

5

5 [3] - 19:20, 20:10, 20:17

50 [4] - 25:21, 28:24, 30:18

50-microgram [1] - 25:21

50th [1] - 25:22520 [2] - 1:22, 2:655155 [1] - 2:7

6

6 [1] - 30:2360-2200-30791 [3] -

1:7, 5:3, 9:365 [1] - 25:256:00 [3] - 1:19, 1:25,

4:16

7

7 [2] - 19:18, 20:27050 [2] - 1:12, 5:27053 [2] - 1:12, 5:275 [1] - 26:27:15 [1] - 44:23

8

8 [3] - 1:18, 1:25, 44:24

8th [1] - 4:17

9

9 [1] - 20:390 [1] - 38:790th [1] - 38:16

A

abbreviated [2] - 16:10, 16:17

ability [1] - 45:12able [2] - 17:17,

29:25abundant [1] - 26:17

abundantly [1] - 25:16

access [1] - 42:20account [1] - 30:7accounted [1] -

22:21accounts [1] - 34:15accurate [4] - 6:24,

8:6, 8:18, 26:5achieve [1] - 35:19Act [2] - 5:16, 5:18actual [2] - 17:11,

26:7add [1] - 17:17addition [4] - 20:24,

26:7, 27:14, 30:3additional [4] -

11:23, 12:1, 12:6, 14:8

Additional [1] - 9:12address [5] - 7:8,

8:25, 10:4, 26:9, 31:15

addresses [1] - 14:15

addressing [1] - 8:3adequate [1] - 20:13adjourned [3] -

44:18, 44:22, 44:25ADMINISTRATIVE

[1] - 1:3Administrative [6] -

1:21, 4:2, 4:3, 5:7, 5:16, 7:17

administratively [1] - 42:19

adopt [4] - 4:5, 5:20, 11:17, 14:14

adopted [3] - 5:15, 42:17, 42:21

AGENCY [3] - 1:5, 2:5, 3:4

agency [1] - 5:15Agency [22] - 1:10,

4:5, 4:23, 5:19, 5:25, 6:1, 6:7, 6:12, 6:14, 6:17, 7:16, 7:17, 9:16, 9:20, 9:21, 9:22, 9:25, 11:3, 11:5, 11:16, 11:21, 34:2

Agency's [3] - 4:19, 10:18, 11:11

agenda [1] - 6:10agreement [1] -

30:10algae [14] - 15:11,

15:24, 16:13, 17:11, 18:2, 18:12, 18:18, 18:24, 19:3, 19:25, 24:12, 26:11, 26:12,

27:1algal [2] - 28:14,

28:18allotted [1] - 6:21allow [2] - 24:24,

27:1allowed [1] - 17:19alternatives [1] -

5:24Amendments [1] -

1:11amendments [1] -

4:23amount [4] - 20:5,

27:5, 34:17, 35:13amounts [4] - 18:24,

19:2, 19:25, 27:7analyses [2] - 40:3,

40:4analysis [6] - 17:1,

21:20, 23:25, 37:9, 39:21, 40:12

analyzed [1] - 31:17animals [1] - 34:10ANOKA [1] - 45:2answer [2] - 12:7,

12:9anyway [1] - 13:10APPEARANCES [1] -

2:1appearing [1] - 11:3apply [1] - 29:15appreciate [1] -

44:17approach [18] - 12:9,

21:22, 22:18, 24:1, 32:4, 34:17, 34:22, 35:5, 35:21, 36:20, 37:10, 37:23, 38:14, 39:4, 41:1, 41:2, 41:8, 43:24

approaches [4] - 21:3, 21:8, 23:23, 40:20

approaching [3] - 23:3, 31:13, 31:14

appropriate [3] - 7:4, 24:4, 39:15

approved [1] - 42:17approximate [2] -

25:18April [2] - 38:1, 42:10April-through-

September [1] - 38:1aquatic [7] - 20:11,

28:16, 34:6, 34:7, 34:10, 43:7, 43:10

area [3] - 29:24, 39:14, 42:15

arguments [1] - 6:5KIRBY A. KENNEDY & ASSOCIATES

( 952 ) 922 - 1955

1

aspect [2] - 35:14, 35:22

assess [2] - 24:15, 24:19

assessed [1] - 32:19assessing [1] - 33:2assessments [3] -

24:24, 30:22, 31:15associated [1] - 27:3attain [1] - 8:5attending [2] - 6:24,

44:16ATTORNEY [1] - 2:4attorney [1] - 11:2audience [1] - 44:14augment [1] - 17:15August [3] - 19:15,

31:9, 43:18authority [3] - 5:20,

9:22, 11:16automatically [2] -

19:9, 21:10available [7] - 5:25,

10:6, 11:9, 11:10, 12:7, 40:5, 42:4

average [7] - 19:17, 31:17, 31:21, 31:22, 32:5, 40:22, 43:17

averaged [1] - 38:17averages [2] - 24:14,

38:13averaging [1] - 19:1axis [7] - 18:4, 19:14,

25:12, 28:22, 28:23, 40:16

B

background [3] - 39:6, 39:10, 39:11

bacterial [1] - 16:14bad [2] - 31:8, 31:9Barbara [3] - 1:23,

45:7, 45:18barges [1] - 27:20base [1] - 34:19based [9] - 18:10,

22:20, 26:2, 26:3, 33:18, 38:21, 40:14, 43:17, 43:22

basic [1] - 23:18basing [1] - 26:16basis [3] - 22:15,

25:17, 36:22becomes [1] - 33:15BEFORE [1] - 1:16begin [3] - 7:7,

10:17, 12:25behalf [1] - 11:4

below [5] - 19:20, 20:3, 28:7, 33:3, 43:1

beneficial [1] - 26:20best [2] - 6:7, 45:11better [1] - 41:1between [6] - 16:3,

18:1, 20:2, 32:24, 43:4, 43:8

bias [1] - 38:13big [1] - 29:9billion [1] - 18:24binder [2] - 11:9,

11:24biochemical [2] -

16:16, 24:12biological [8] - 16:4,

16:23, 21:5, 34:19, 36:8, 37:6, 39:19

Biological [1] - 17:16biology [3] - 17:11,

37:18, 42:1biomass [3] - 26:18,

26:21, 27:3bit [7] - 14:10, 33:10,

35:9, 35:10, 37:20, 43:15, 43:21

blanks [1] - 40:7blocks [1] - 43:12blooms [7] - 28:12,

28:14, 28:18, 28:25, 29:2, 29:7

Blue [1] - 15:22blue [3] - 18:5, 25:9,

25:20board [1] - 7:13boating [1] - 27:24BOD [1] - 16:17bodies [2] - 27:18,

27:25body [2] - 35:4,

37:17Book [2] - 14:7, 14:8bop [1] - 26:11border [3] - 28:8,

30:3, 30:4bottom [4] - 16:6,

19:8, 25:11, 26:14BOUCHARD [1] -

2:13Brainerd [3] - 4:20,

23:1, 23:2break [2] - 6:18, 44:5breakpoint [1] -

21:13breakpoints [1] -

21:12brief [7] - 6:17, 6:18,

12:5, 12:23, 13:13, 13:19, 13:25

briefly [4] - 6:15,

11:8, 36:15, 37:22bring [4] - 24:7,

25:22, 33:17, 42:23bringing [1] - 42:18Bringing [1] - 24:4broader [1] - 17:20brought [4] - 17:19,

20:25, 35:4, 41:12build [1] - 13:9burdens [1] - 9:20buzz [1] - 13:7

C

calculate [1] - 35:16calendar [2] - 9:5,

31:11calibrating [1] -

35:11cannot [1] - 8:11capacity [2] - 18:17,

18:18Carey [3] - 1:23,

45:7, 45:18CAROL [1] - 2:10carrying [1] - 39:13case [12] - 9:2, 13:1,

21:16, 21:23, 22:6, 31:6, 31:18, 31:23, 35:3, 35:7, 39:3, 41:14

cases [4] - 15:20, 15:25, 16:1, 22:7

causative [1] - 24:10caused [1] - 22:13causing [1] - 27:6center [1] - 10:22central [6] - 23:5,

23:9, 24:9, 25:10, 29:13, 29:14

Central [1] - 25:24certain [1] - 40:7Certainly [1] - 37:2CERTIFICATE [1] -

45:5certify [1] - 45:7cetera [2] - 40:3,

43:13chance [2] - 44:5,

44:15change [7] - 21:20,

23:25, 37:9, 39:20, 40:12, 40:14, 40:19

change-point [4] - 21:20, 23:25, 37:9, 40:12

changes [1] - 21:15Chapters [2] - 1:12,

5:2

characterize [1] - 24:23

check [1] - 44:11checkmark [1] - 7:4chlorophyll [8] -

18:2, 21:4, 26:19, 28:23, 29:12, 31:24, 32:12

Chlorophyll [1] - 24:11

chlorophyll-A [3] - 26:19, 32:12

CHRISTOPHERSON [1] - 2:14

circled [1] - 41:13Cities [2] - 29:23,

29:24clarification [1] - 5:1Class [1] - 41:15classed [1] - 20:9clear [4] - 8:2, 25:16,

30:23, 31:5clearly [4] - 8:9,

8:10, 15:14, 25:14close [3] - 9:4, 9:8,

18:15Cloud [1] - 23:4cold [1] - 20:14cold-water [1] -

20:14Coleman [2] - 10:19,

11:1COLEMAN [4] - 2:4,

10:20, 10:25, 13:4Coleman.................

.............. [1] - 3:8collected [2] - 17:16,

31:20collection [1] - 17:11collections [1] -

16:25column [2] - 7:5,

26:13combination [1] -

42:3comment [2] - 7:2,

9:16comments [8] - 6:4,

8:23, 9:1, 9:7, 9:11, 9:15, 44:13, 44:20

Comments [1] - 8:24commerce [1] -

27:20compare [2] - 32:6,

37:5comparison [1] -

29:17comparisons [1] -

37:19complements [1] -

14:19complete [2] - 6:11,

45:11compliance [3] -

33:5, 33:7, 35:20component [1] -

41:4concentration [6] -

16:20, 25:12, 26:1, 28:22, 33:17, 40:15

concentrations [6] - 23:23, 26:6, 26:18, 27:2, 29:4, 42:7

conceptional [1] - 16:10

condition [5] - 16:4, 16:5, 16:23, 21:6, 38:22

conditions [4] - 22:3, 24:2, 24:24, 37:11

conducted [1] - 4:12connection [1] -

13:19consideration [1] -

39:18considered [3] -

26:21, 36:9, 38:3considering [1] -

42:24consistent [2] - 32:3,

35:4consisting [1] - 45:8contain [1] - 9:19context [1] - 6:5continuation [1] -

28:13continue [3] - 13:10,

41:20continuous [1] -

17:12contrast [1] - 19:24contribute [1] -

16:15CONTROL [3] - 1:5,

2:5, 3:4Control [9] - 1:10,

4:5, 4:18, 4:23, 5:19, 11:2, 11:4, 11:16, 34:2

controls [1] - 4:14convened [1] - 4:17Coordinator [1] -

2:10copy [6] - 5:9, 8:20,

10:3, 10:7, 11:10corner [3] - 37:7,

37:8correct [1] - 45:9corrections [2] - 5:1,

11:24KIRBY A. KENNEDY & ASSOCIATES

( 952 ) 922 - 1955

2

correlation [2] - 23:18, 37:4

COUNSEL [1] - 2:3COUNTY [1] - 45:2couple [5] - 18:11,

25:13, 28:2, 30:12, 32:5

course [5] - 16:18, 17:3, 19:17, 24:23, 31:19

Court [1] - 45:19court [3] - 7:15, 7:19,

8:5COURT [28] - 4:1,

10:11, 10:23, 12:18, 12:25, 13:6, 13:18, 13:21, 14:23, 15:5, 20:5, 20:18, 20:21, 30:12, 30:17, 30:21, 31:2, 31:8, 32:7, 32:16, 32:20, 33:6, 33:10, 33:22, 39:9, 44:2, 44:4, 44:10

cover [1] - 39:24covered [3] - 35:24,

36:18, 37:9creation [1] - 21:18Creek [1] - 15:23criteria [8] - 23:16,

24:6, 24:8, 24:11, 24:25, 30:19, 32:16, 35:24

critical [3] - 16:8, 21:13

Croix [5] - 29:16, 29:24, 32:10, 32:18

Crow [4] - 17:6, 18:20, 19:12, 19:13

cumulative [1] - 25:5cycling [1] - 19:4

D

daily [2] - 16:19, 35:18

data [23] - 16:25, 17:16, 17:18, 17:23, 20:25, 21:2, 23:14, 24:19, 29:3, 37:6, 37:12, 37:23, 37:24, 38:4, 38:5, 38:17, 39:1, 39:19, 40:5, 40:8, 40:13, 42:1, 42:2

database [1] - 36:9dataset [2] - 24:22,

43:21datasets [1] - 42:4Dated [1] - 45:14

dates [1] - 19:14DAVID [1] - 2:14days [4] - 9:5, 19:17,

28:23, 29:8deadline [1] - 9:18dealing [1] - 35:17decision [1] - 9:19decline [1] - 22:4decrease [1] - 40:17deemed [2] - 25:3,

32:22define [1] - 23:17definite [1] - 40:14definition [1] - 11:25demand [2] - 16:16,

24:13demonstrate [6] -

11:17, 11:20, 15:16, 16:11, 16:24, 17:24

demonstrated [4] - 5:24, 9:23, 9:25, 29:21

demonstrates [1] - 25:15

depth [1] - 37:10derive [1] - 23:16describe [1] - 6:16described [2] -

42:16, 43:7describes [1] - 5:10describing [2] -

36:16, 43:6desirable [1] - 20:7detail [4] - 23:11,

36:10, 37:6, 37:15detailed [2] - 5:12,

17:10details [3] - 10:8,

10:12, 37:18detecting [1] - 22:9determine [2] -

15:16, 21:11Detroit [1] - 4:21develop [1] - 5:17developed [7] -

20:24, 22:19, 26:8, 27:19, 36:19, 42:14

developing [7] - 6:4, 22:19, 34:22, 36:5, 37:2, 38:14, 43:24

development [1] - 28:20

difference [1] - 43:4differences [2] -

22:14, 36:2different [17] - 20:16,

21:22, 26:15, 32:1, 35:12, 36:13, 36:23, 39:1, 39:4, 39:22, 39:24, 40:1, 40:2,

40:9, 43:16, 43:21difficult [1] - 16:2digest [1] - 6:19direct [2] - 16:3, 34:9directions [1] - 4:10directly [2] - 7:22,

27:8discuss [1] - 10:13discussed [1] - 9:20Discussion [1] -

10:10discussions [1] -

30:9dispatch [1] - 12:20dissolved [7] -

16:18, 17:13, 19:5, 19:20, 20:4, 20:6, 24:12

distinct [3] - 22:4, 22:12, 25:15

distribution [1] - 25:6

distributions [3] - 25:7, 25:9, 25:17

diverse [1] - 36:23DO [1] - 16:19Docket [2] - 5:2, 9:2DOCKET [1] - 1:7document [1] - 11:15documented [2] -

9:21, 43:11documents [2] -

12:1, 22:17done [7] - 23:13,

25:5, 28:18, 33:14, 40:4, 40:6

door [1] - 28:4dots [1] - 18:5down [9] - 14:9,

23:3, 27:21, 28:8, 29:4, 29:7, 30:4, 33:18, 38:13

draining [1] - 23:5drawn [1] - 18:10drill [1] - 14:9Duluth [1] - 4:20during [4] - 9:13,

9:16, 16:20, 28:11

E

early [2] - 17:4, 19:15Earth [1] - 15:22ease [1] - 42:20easy [1] - 42:22ecoregion [1] - 22:21ecoregions [2] -

17:8, 22:16ecosystems [1] -

43:14effect [1] - 26:25effects [6] - 34:9,

36:9, 36:11, 37:18, 39:25

efficient [1] - 42:19efforts [1] - 32:24eggs [1] - 34:10either [1] - 41:7emphasis [3] -

28:17, 29:1, 29:9encouraged [1] -

44:20end [2] - 11:23, 44:1endpoint [1] - 41:6enriched [2] - 22:2,

22:3enrichment [3] -

15:10, 15:12, 15:21ensure [2] - 4:15,

8:18entered [2] - 6:14,

11:6entitled [1] - 5:6envelopes [1] - 10:4environments [1] -

34:8EPA [7] - 21:3,

21:20, 22:16, 22:20, 36:20, 42:18

EPA-mapped [1] - 22:16

EPA-recommended

[2] - 21:3, 21:20equipment [1] - 19:7equivalent [1] -

18:23error [1] - 35:13established [1] -

34:8et [2] - 40:3, 43:13EU-5 [1] - 23:12Eutrophication [1] -

1:12eutrophication [10] -

4:25, 11:25, 12:12, 14:2, 14:7, 14:20, 15:9, 15:19, 32:6, 32:19

evening [6] - 4:1, 11:7, 12:5, 34:3, 44:16, 44:21

events [1] - 38:11evidence [4] - 9:11,

9:12, 23:15, 37:1exact [1] - 36:17exactly [1] - 30:6examination [1] -

41:16examine [1] - 39:5

examining [2] - 37:12, 38:25

example [6] - 8:11, 22:23, 28:21, 30:15, 32:9, 40:25

examples [4] - 18:20, 19:11, 21:8, 28:2

exceed [2] - 25:20, 30:14

exceeded [3] - 25:2, 27:8, 42:8

excess [6] - 14:16, 15:17, 18:18, 18:19, 26:10, 30:17

excessive [3] - 15:11, 27:7, 27:12

excursions [1] - 19:19

exhibit [2] - 8:21, 22:12

Exhibit [3] - 11:13, 23:12

exhibits [9] - 6:14, 6:16, 6:19, 11:6, 11:12, 11:20, 11:23, 22:17, 44:6

existing [6] - 19:20, 19:23, 34:14, 35:7, 41:18

explain [1] - 23:11explanation [1] -

6:11extends [1] - 28:5eye [1] - 22:7eyeball [1] - 40:13eyeballing [1] - 41:2

F

factors [1] - 21:5fair [2] - 4:9, 35:13fairly [5] - 4:13,

18:15, 26:4, 38:11, 38:15

fairness [1] - 4:15falling [1] - 20:3familiar [1] - 17:5fashion [1] - 32:1faster [1] - 35:10February [1] - 9:9felt [1] - 35:25few [3] - 13:12,

13:25, 26:3fewer [1] - 22:4field [1] - 35:8figure [1] - 27:6figured [1] - 33:14fill [1] - 40:8


3

fillet [1] - 18:4final [2] - 38:25, 42:2Finally [1] - 37:16finally [10] - 5:23,

6:20, 9:24, 36:7, 38:6, 38:20, 41:11, 41:12, 41:24, 42:2

fine [1] - 40:8First [1] - 12:10first [3] - 8:13, 9:16,

14:2fish [11] - 16:7,

17:12, 20:11, 20:14, 21:16, 23:24, 28:12, 36:12, 39:23, 40:2, 41:7

fishing [1] - 27:24five [3] - 9:7, 9:13,

29:8five-day [1] - 9:13five-working-day [1]

- 9:7flow [1] - 38:11flowing [1] - 27:18flows [2] - 23:2, 23:3fluctuation [1] -

16:18fluctuations [1] -

19:16flux [5] - 16:19,

16:21, 19:22, 20:1, 24:12

focus [4] - 6:9, 17:4, 33:15, 43:6

folks [6] - 6:18, 9:1, 13:1, 14:24, 44:5, 44:14

follow [1] - 14:5following [1] - 8:7FOR [2] - 1:4, 2:3foregoing [1] - 45:8Fork [2] - 18:25,

19:13form [1] - 22:14formal [1] - 25:5four [1] - 28:7free [1] - 27:18free-flowing [1] -

27:18frequency [3] -

28:18, 29:2, 29:7front [1] - 12:9fulfilled [3] - 5:21,

9:23, 11:21full [2] - 14:8, 45:10fully [1] - 27:12function [1] - 25:6

G

general [1] - 18:12gills [1] - 34:10given [1] - 30:3glad [1] - 6:3governing [1] - 4:24graph [3] - 18:3,

22:1, 28:20graphs [1] - 21:2greater [1] - 28:24Green [1] - 25:10gross [1] - 26:14group [1] - 7:9groupings [2] -

36:13, 40:2groups [1] - 4:6grows [1] - 26:11growth [3] - 15:11,

16:14, 27:1guidance [1] - 22:17

H

half [3] - 25:23, 43:20

handout [5] - 5:6, 5:13, 8:25, 10:8, 10:11

hard [1] - 11:10harmful [1] - 34:11head [1] - 8:11health [1] - 30:2hear [2] - 8:9, 14:22heard [1] - 6:20hearing [28] - 4:7,

4:22, 5:14, 5:17, 6:10, 6:11, 6:13, 6:15, 6:21, 6:25, 7:1, 7:5, 7:11, 7:12, 7:18, 7:19, 8:4, 8:6, 8:24, 9:4, 10:12, 10:16, 11:3, 11:6, 11:7, 11:23, 44:18, 44:21

HEARING [2] - 1:16, 1:21

Hearing [4] - 5:8, 11:13, 44:25

Hearings [1] - 4:3HEARINGS [1] - 1:3hearings [3] - 4:8,

4:12, 5:11Heiskary [1] - 12:10HEISKARY [20] -

2:11, 12:20, 13:11, 13:23, 14:25, 15:7, 20:8, 20:19, 20:23, 30:16, 30:20, 30:25,

31:4, 31:12, 32:14, 32:17, 32:21, 33:8, 33:12, 33:24

Heiskary............................ [1] - 3:9

HELD [2] - 1:16, 1:21help [5] - 16:10,

19:5, 23:15, 24:23, 26:9

helped [1] - 29:19helpful [5] - 6:6,

7:23, 8:22, 9:1, 44:17helping [2] - 21:11,

21:14hereby [1] - 45:7High [1] - 18:24high [4] - 18:24,

19:13, 38:11, 38:15higher [7] - 25:24,

25:25, 26:21, 34:12, 39:6, 39:10, 41:22

Higher [1] - 39:11highest [1] - 41:22highlighted [1] -

28:2highlights [1] - 5:12highly [1] - 18:9hitting [2] - 34:12Honor [3] - 10:21,

12:22, 33:25hope [1] - 8:17hundreds [2] -

17:17, 17:18

I

ID [4] - 1:8, 5:4, 27:6, 27:11

idea [1] - 29:18identify [3] - 7:9,

7:24, 21:15II [1] - 2:12III [1] - 2:11immediate [1] -

12:10immediately [1] -

27:10impact [3] - 14:15,

15:17, 16:1impacts [1] - 16:23impaired [2] - 25:3,

32:22impairments [1] -

35:17impartially [1] - 4:13implementation [4] -

33:13, 42:11, 43:16, 43:22

implemented [1] -

42:8implies [1] - 15:9important [8] - 8:5,

8:8, 22:9, 27:25, 30:5, 35:17, 37:17, 43:13

include [3] - 11:24, 23:11, 42:12

included [5] - 5:13, 17:22, 24:21, 27:15, 29:12

includes [2] - 28:6, 42:15

including [2] - 38:15, 42:1

incorporate [1] - 24:4

increase [2] - 16:13, 40:17

increases [4] - 16:13, 16:14, 16:16, 21:17

independent [1] - 4:4

indicated [3] - 8:25, 15:16, 23:7

individuals [2] - 21:16, 40:16

influence [1] - 16:17information [8] -

5:12, 5:17, 6:20, 14:9, 14:11, 17:10, 21:1, 37:13

informed [1] - 10:7initial [1] - 9:11injuring [1] - 34:13Instead [1] - 9:14instrumented [1] -

19:6intend [1] - 13:12intensity [2] - 29:1,

29:6interest [1] - 7:9interested [1] - 5:3interrupt [2] - 8:15,

13:15introduce [3] - 12:4,

12:8, 16:19introduced [2] -

6:13, 10:25introduction [2] -

13:13, 13:25invertebrate [3] -

21:24, 22:5, 36:12invertebrates [6] -

16:5, 17:12, 23:24, 39:23, 40:2, 41:7

investigation [1] - 38:4

Iowa [1] - 28:8issued [1] - 10:13

issues [2] - 5:18, 6:9

J

JAMES [1] - 1:17James [1] - 1:22January [5] - 1:25,

4:17, 9:6, 44:24, 45:14

JANUARY [1] - 1:18JEAN [4] - 2:4,

10:20, 10:25, 13:4Jean [2] - 3:8, 11:1Jim [1] - 4:2JUDGE [1] - 1:17Judge [3] - 1:22, 4:2,

7:17July [1] - 19:15June [4] - 31:6,

31:10, 43:18June-through-

August [1] - 43:18

K

Keep [1] - 20:21key [1] - 5:18kills [1] - 28:12kind [8] - 19:7, 21:9,

21:10, 37:22, 38:1, 40:13, 41:25, 43:8

kinds [2] - 36:3, 40:2known [1] - 22:11

L

lab [1] - 35:4laboratory [1] - 35:2LaFave [3] - 1:17,

1:22, 4:2Lafayette [2] - 1:22,

2:6Lake [13] - 14:3,

14:17, 27:17, 28:5, 28:6, 28:10, 29:15, 29:24, 30:2, 32:10, 32:18, 42:15

lake [6] - 14:20, 15:18, 32:6, 32:19, 32:21, 33:18

Lakes [1] - 4:21lakes [5] - 22:12,

31:15, 32:3, 43:9land [2] - 22:14,

22:15landscape [2] -

36:21, 37:19landscaped [1] -


4

36:3Language [1] - 1:13language [2] - 26:24,

26:25large [4] - 17:5,

19:16, 19:22, 38:19largely [1] - 26:16larger [2] - 4:14, 18:5last [1] - 42:12late [1] - 19:15law [1] - 4:8Law [3] - 1:21, 4:2,

7:17least [3] - 31:19,

38:4, 43:20leave [1] - 8:21leeway [1] - 6:4left [6] - 19:12, 21:9,

22:1, 23:17, 28:3, 37:7

legal [6] - 5:19, 5:21, 5:22, 9:24, 11:15, 11:21

legislative [1] - 7:12legislature [1] - 5:11Legislature [1] - 4:10leisure [1] - 10:15less [3] - 18:12,

26:20, 29:8level [2] - 20:13levels [2] - 26:15,

35:19life [1] - 20:11light [1] - 43:12line [2] - 14:22, 18:15lined [1] - 39:21lines [5] - 14:25,

23:15, 37:1, 40:22, 40:24

linkage [2] - 16:3, 16:8

linkages [2] - 16:9, 16:24

liter [12] - 18:22, 18:23, 19:2, 19:18, 19:20, 20:2, 20:3, 20:10, 28:24, 29:5, 29:6, 30:8

literature [8] - 24:3, 26:16, 26:17, 26:18, 37:16, 37:17, 37:20, 37:21

live [2] - 16:6, 16:7loads [3] - 34:12,

35:16, 35:18local [1] - 7:12located [1] - 7:1location [1] - 14:24locations [1] - 4:20log [2] - 18:3, 18:4

long-standing [1] - 14:13

longstanding [1] - 39:18

look [5] - 24:1, 25:20, 28:10, 40:1, 44:5

looked [7] - 36:9, 36:14, 37:24, 38:20, 39:19, 40:10, 41:8

looking [6] - 23:23, 36:11, 36:20, 36:22, 37:3, 37:11

loss [1] - 26:22loud [1] - 8:9low [4] - 19:1, 19:2,

19:24, 19:25lower [5] - 19:12,

23:17, 25:23, 42:14, 43:1

lump [1] - 39:16

M

main [2] - 39:2, 43:6maintain [1] - 28:16maintaining [1] -

43:9Map [1] - 12:3map [3] - 22:21,

22:24, 40:25mapped [1] - 22:16maps [1] - 23:11Marshall [3] - 4:21,

13:4, 13:5match [3] - 31:22,

31:24mats [1] - 15:24matter [2] - 4:22, 8:2maximum [2] -

16:20, 35:18mean [1] - 39:9meaning [1] - 25:25means [1] - 30:25measured [1] - 39:25measurement [3] -

35:1, 35:2, 35:9measurements [2] -

17:13, 19:10measuring [2] -

31:24, 35:5mechanistic [1] -

28:19medium [1] - 17:4meet [10] - 24:15,

29:21, 29:24, 30:1, 31:25, 32:23, 32:25, 33:4, 33:15, 33:20

meeting [2] - 7:12,

20:20MEMBERS [1] - 2:9members [4] - 4:12,

6:8, 6:22mention [1] - 19:4met [2] - 9:20, 43:19metabolism [1] -

16:15meter [1] - 26:20meters [2] - 35:8,

35:11methodology [1] -

35:5methods [1] - 35:11metrics [6] - 36:14,

39:22, 39:23, 40:9, 41:5, 41:10

micrograms [7] - 18:21, 18:23, 19:2, 28:24, 29:6, 30:8

microphone [1] - 10:21

might [3] - 22:24, 35:9, 38:10

Might [1] - 12:20milligrams [7] -

19:18, 19:20, 20:1, 20:3, 20:10, 26:19, 29:5

minimizing [1] - 28:17

minimum [5] - 16:21, 24:16, 24:17, 24:20, 30:22

MINNESOTA [5] - 1:2, 1:5, 2:5, 3:4, 45:1

Minnesota [23] - 1:10, 1:11, 1:23, 2:7, 4:4, 4:11, 4:18, 5:1, 5:7, 5:15, 5:19, 9:12, 11:2, 11:4, 11:16, 15:22, 17:8, 19:1, 22:11, 29:15, 29:23, 32:24, 34:2

minor [2] - 4:25, 11:24

Minor [1] - 1:13minus [1] - 16:21miss [1] - 13:8Mississippi [12] -

14:4, 14:18, 17:6, 22:25, 23:8, 27:16, 29:13, 29:22, 42:14, 43:1, 43:14, 43:25

model [3] - 16:10, 28:19, 28:21

modeling [4] - 29:2, 29:19, 29:20, 33:14

moment [4] - 5:9, 13:16, 16:22, 17:14

moments [2] - 13:12, 13:25

monitor [2] - 24:17, 32:4

monitored [1] - 31:18

Monitoring [1] - 17:17

monitoring [2] - 37:25, 43:20

Monson [2] - 12:13, 34:1

MONSON [4] - 2:12, 33:25, 39:11, 44:3

Monson.............................. [1] - 3:10

morning [2] - 11:1, 11:7

most [5] - 6:6, 6:20, 22:23, 37:25, 41:6

Most [1] - 37:25move [4] - 12:15,

23:20, 23:22, 27:20moved [1] - 10:22moving [3] - 20:2,

22:22, 32:7MPCA [6] - 2:3, 2:9,

2:14, 5:23, 12:4, 22:19

MS [1] - 2:4multiple [2] - 23:15,

36:25must [3] - 7:3, 8:10,

31:7mute [2] - 14:21Mute [1] - 14:25muted [1] - 15:4

N

name [6] - 4:1, 7:8, 10:4, 11:1, 25:5, 33:25

namely [2] - 5:18, 9:21

names [1] - 8:12NANKIVEL [1] - 2:10narrative [2] - 26:24natural [1] - 22:15navigational [2] -

14:4, 27:17Navigational [2] -

14:18, 27:16near [1] - 18:14necessarily [2] -

38:12, 39:16necessary [1] - 9:23necessity [1] - 43:9need [18] - 6:9, 7:20,

9:25, 12:2, 14:12, 15:16, 16:9, 28:1, 28:10, 31:11, 32:4, 33:3, 33:4, 33:16, 34:6, 35:19, 43:9

Need [1] - 11:14needed [2] - 6:1,

11:18needs [3] - 24:21,

32:23, 43:19never [1] - 20:3new [2] - 11:25,

35:21next [3] - 13:12,

13:25, 22:22nice [1] - 24:22NO [1] - 1:7non [4] - 18:6, 18:10,

18:16, 34:16non-quantifiable [1]

- 34:16non-wadeable [3] -

18:6, 18:10, 18:16North [2] - 1:22, 2:6north [2] - 24:9,

30:15northern [3] - 23:1,

23:8, 25:10Northern [1] - 18:25Notary [1] - 1:24noted [1] - 21:13notes [1] - 45:10notice [1] - 10:6noticed [1] - 44:12noxious [1] - 27:1nuisance [1] - 28:25number [4] - 6:24,

9:3, 20:7, 28:23Number [5] - 1:8,

4:18, 5:2, 5:4, 9:2numbers [3] - 24:13,

34:20, 38:15numeric [5] - 24:6,

26:7, 26:9, 26:23, 27:8

nutrient [23] - 14:14, 15:10, 15:12, 15:14, 15:20, 15:23, 18:21, 22:2, 22:19, 22:20, 23:10, 24:6, 27:2, 27:9, 29:14, 35:23, 36:5, 36:16, 39:1, 39:16, 41:14

Nutrient [1] - 12:3nutrient-enriched

[1] - 22:2nutrient-rich [2] -

15:23, 18:21nutrients [2] - 17:10,

18:19KIRBY A. KENNEDY & ASSOCIATES

( 952 ) 922 - 1955

5

O

OAH [2] - 1:7, 5:2observations [3] -

24:21, 30:24, 31:20obtain [1] - 10:7obvious [2] - 15:21,

15:25occur [1] - 37:25occurs [1] - 10:12OF [4] - 1:2, 1:3,

45:1, 45:2offense [1] - 8:17offer [1] - 18:20OFFICE [1] - 1:3Office [2] - 4:3, 5:7office [6] - 4:4, 4:7,

4:19, 8:24, 9:2, 23:1often [1] - 15:13once [2] - 33:12,

44:15one [16] - 5:9, 7:11,

8:14, 10:4, 22:22, 25:1, 25:14, 30:19, 31:8, 33:6, 34:20, 39:16, 42:23, 44:12, 44:13, 44:14

One [3] - 15:7, 17:25, 42:12

one's [1] - 26:3ones [1] - 43:5open [1] - 38:1opportunity [4] -

6:18, 7:13, 9:10, 9:14order [2] - 5:22, 6:23organisms [1] -

34:13outlined [1] - 36:4outlines [1] - 38:24outright [1] - 34:11outside [3] - 15:2,

28:4, 33:6over-enrichment [3]

- 15:10, 15:12, 15:21oversimplification

[1] - 33:11overview [1] - 12:23own [3] - 7:21, 29:16oxygen [13] - 16:16,

16:18, 16:20, 17:13, 19:5, 19:16, 19:21, 20:4, 20:6, 20:12, 20:15, 24:12

P

P.M [1] - 1:19p.m [5] - 1:25, 4:16,

9:5, 9:8, 44:23PAGE [1] - 3:6pages [1] - 45:9Panel [2] - 7:16, 7:17panel [3] - 6:8, 6:12,

23:16PANEL [1] - 2:9part [7] - 4:14, 5:14,

10:14, 13:7, 37:3, 37:25, 43:25

Part [1] - 34:25participants [2] -

4:9, 7:14participating [1] -

4:6particular [3] - 7:24,

22:6, 32:8parts [1] - 18:23passes [1] - 9:18patterns [4] - 22:12,

22:13, 25:15, 36:21Paul [4] - 1:23, 2:7,

4:19, 15:3PCA [1] - 12:6People [1] - 27:23people [2] - 6:24,

13:5Pepin [8] - 14:3,

14:17, 27:17, 28:6, 28:10, 29:11, 30:2, 42:15

per [16] - 18:12, 18:22, 18:23, 18:24, 19:2, 19:18, 19:20, 20:2, 20:3, 20:10, 26:4, 26:19, 28:24, 29:5, 29:6, 30:8

percent [6] - 21:16, 25:19, 25:25, 26:2, 40:16, 42:9

percentile [5] - 25:23, 25:24, 38:7, 38:16, 41:9

perhaps [2] - 10:21, 22:23

period [10] - 9:8, 9:10, 9:14, 9:17, 31:21, 37:12, 38:2, 42:10, 43:18, 43:20

periphyton [2] - 26:10, 27:13

Periphyton [1] - 26:10

person [1] - 8:14persons [1] - 7:18perspective [1] -

25:4Phil [1] - 34:1PHILIP [4] - 2:12,

33:25, 39:11, 44:3

Philip [2] - 3:10, 12:13

phosphorus [32] - 14:16, 15:14, 15:17, 16:1, 16:3, 16:12, 18:1, 18:2, 18:3, 18:13, 19:1, 19:14, 19:25, 21:4, 21:17, 22:3, 24:10, 24:25, 25:7, 25:11, 25:20, 25:25, 26:6, 28:22, 29:3, 29:11, 30:8, 30:14, 31:23, 32:11, 33:17

phosphorus-enriched [1] - 22:3

physical [1] - 34:9pick [1] - 5:9picking [1] - 22:5picture [1] - 12:21pictures [2] - 26:15,

27:23piece [2] - 42:12,

43:15pieces [1] - 34:21Pipestone [1] - 15:22place [7] - 7:4, 17:3,

24:25, 27:22, 31:7, 36:5, 42:23

plants [2] - 15:11, 43:13

pleased [1] - 12:22plotting [1] - 23:19plus [3] - 30:18,

32:11, 32:12point [15] - 7:22,

12:15, 21:20, 23:4, 23:6, 23:25, 29:5, 37:9, 39:2, 39:21, 40:12, 40:18, 40:19, 41:3, 44:12

pointing [3] - 18:14, 21:25, 22:24

points [7] - 7:20, 7:23, 8:17, 21:2, 38:4, 38:5, 40:8

polluted [1] - 26:21POLLUTION [3] -

1:5, 2:5, 3:4Pollution [9] - 1:10,

4:4, 4:18, 4:23, 5:19, 11:2, 11:4, 11:16, 34:2

Pool [5] - 28:4, 28:6, 28:14, 30:4, 43:1

Pools [3] - 14:18, 27:16, 42:14

pools [5] - 14:4, 27:17, 28:7, 29:11, 30:2

portion [3] - 10:1, 11:18, 23:6

possible [1] - 5:24potential [2] - 22:14,

35:13potentially [2] -

25:19, 43:12preceding [1] - 45:9preferable [1] - 20:6prepare [1] - 9:19present [3] - 7:18,

12:11, 12:13presentation [5] -

6:17, 10:18, 12:5, 12:16, 15:9

presentations [1] - 6:5

PRESENTATIONS

[1] - 3:4presented [1] - 24:13pretty [6] - 33:8,

33:9, 34:8, 37:10, 37:20, 43:10

previous [1] - 6:13procedural [4] -

4:15, 5:22, 9:24, 11:22

Procedure [1] - 5:16procedure [1] - 6:12Procedures [1] - 5:8procedures [2] -

5:10, 10:17proceed [2] - 12:19,

13:22proceedings [1] -

45:11process [11] - 5:14,

10:9, 10:12, 10:14, 17:19, 21:14, 23:11, 27:6, 27:11, 33:1, 44:18

produce [2] - 18:12, 18:18

Professional [1] - 1:24

Program [1] - 17:17promulgate [1] -

5:23promulgated [1] -

30:7proper [1] - 8:12proportion [1] -

25:13proposed [18] - 4:22,

5:20, 6:1, 10:1, 11:17, 11:25, 12:11, 12:13, 12:24, 13:13, 14:1, 25:21, 29:11, 34:4, 34:23, 35:15, 35:22, 36:7

Proposed [2] - 1:11, 11:18

proposing [3] - 4:5, 28:16, 42:24

protect [2] - 28:1, 30:1

protection [2] - 34:6, 43:6

protective [1] - 41:11protects [1] - 26:20provide [5] - 4:8,

13:13, 13:25, 25:4, 41:6

provided [1] - 14:11provides [2] - 25:17,

36:21providing [1] - 41:10Public [1] - 1:24public [6] - 4:13,

4:21, 6:8, 6:22, 44:7, 44:13

pull [2] - 40:4, 42:20pulled [3] - 23:14,

39:3, 41:15purpose [2] - 5:16,

23:9purposes [2] - 11:13,

29:17put [6] - 10:4, 19:7,

24:2, 27:21, 36:5

Q

QR [1] - 39:20qualify [1] - 31:10Quality [1] - 1:11quality [22] - 4:24,

12:11, 12:14, 12:24, 13:14, 14:1, 19:21, 19:23, 20:10, 22:13, 25:2, 28:15, 34:5, 34:24, 37:2, 41:22, 41:23, 42:2, 42:6, 43:5, 43:10

quantifiable [2] - 34:16, 35:14

quantile [6] - 21:9, 23:24, 37:8, 39:20, 40:11, 40:18

quantitative [1] - 35:1

questioned [1] - 7:16questions [9] - 6:21,

7:14, 7:15, 7:21, 10:16, 12:7, 12:9, 12:17, 12:18

quick [1] - 13:17Quickly [1] - 32:17quite [5] - 15:21,


6

17:5, 26:2, 37:20

R

Rather [1] - 27:10rationale [1] - 36:18Re [1] - 1:9reach [2] - 25:3, 43:1reaches [2] - 25:19,

27:4read [1] - 10:14reading [1] - 32:11real [3] - 13:17,

21:25, 36:15Really [1] - 37:24really [11] - 13:7,

36:4, 36:11, 36:18, 36:21, 36:24, 37:12, 40:12, 40:18, 41:2, 41:20

reason [2] - 33:20, 38:7

reasonable [4] - 6:2, 11:19, 35:25, 43:23

reasonableness [2] - 10:1, 12:2

Reasonableness [1] - 11:15

reasonably [1] - 26:5rebuttal [2] - 9:8,

9:13receive [1] - 5:17recent [1] - 28:13recess [4] - 13:19,

13:20, 44:7, 44:9recognition [1] -

41:21recognize [1] - 36:1recognized [5] -

36:1, 38:8, 38:10, 39:15, 41:5

recommend [2] - 15:13, 24:6

recommended [2] - 21:3, 21:20

recommends [1] - 22:18

record [11] - 6:15, 6:24, 7:25, 8:6, 8:11, 8:18, 10:10, 11:7, 13:22, 37:13, 44:11

recreational [1] - 28:16

red [5] - 18:6, 25:10, 28:3, 41:13

Red [3] - 39:2, 39:5, 39:13

reduce [1] - 29:1reduced [1] - 33:15

reductions [1] - 27:9reference [8] - 9:2,

14:7, 24:2, 37:11, 37:23, 38:14, 38:22, 42:1

reference-stream [1] - 37:23

referred [1] - 21:21reflect [1] - 40:12reflection [1] - 26:5regarding [1] - 41:4Region [1] - 12:3region [7] - 22:22,

24:9, 26:4, 29:14, 30:15, 39:7

regional [7] - 22:12, 22:18, 24:2, 25:15, 36:2, 36:20, 37:11

regions [14] - 13:16, 22:20, 23:10, 25:8, 26:6, 36:6, 36:16, 36:23, 38:22, 38:23, 39:1, 39:17, 39:24, 41:14

Regions [1] - 14:21register [3] - 7:1, 7:3,

7:5Registered [1] - 1:24registration [1] - 7:1regression [13] -

18:8, 18:9, 18:15, 21:9, 21:10, 21:21, 23:18, 23:25, 37:4, 37:8, 39:20, 40:11, 40:19

regression-tree [1] - 21:21

regulatory [1] - 4:14relate [3] - 21:3,

23:20, 23:22related [1] - 21:4relationship [1] -

18:1relationships [3] -

23:17, 33:19, 37:3relative [1] - 18:11relevant [2] - 5:21,

11:21remainder [1] -

42:25remarks [1] - 8:21remember [1] - 8:7remind [2] - 8:16,

44:19remote [3] - 13:2,

14:24report [5] - 6:9, 9:19,

10:3, 10:6, 10:13reported [1] - 1:23reporter [1] - 8:5

Reporter [2] - 1:24, 45:19

REPORTER'S [1] - 45:5

represent [3] - 7:9, 18:5, 28:25

representation [1] - 17:20

requested [1] - 6:25require [4] - 20:15,

27:4, 27:9, 30:22required [1] - 4:8requirement [1] -

14:13requirements [4] -

5:22, 9:24, 11:22, 24:16

research [1] - 34:1Research [3] - 2:11,

2:12, 2:13reservoirs [1] - 27:19resources [1] - 34:7respective [1] - 43:2respond [2] - 9:15,

18:14responding [2] -

15:15, 21:17responds [1] - 14:13Response [1] - 32:16response [5] - 15:20,

24:10, 25:1, 30:19, 32:13

responses [1] - 32:13

restart [2] - 13:17, 13:19

resulted [1] - 28:12results [7] - 15:11,

24:5, 28:21, 31:17, 31:21, 31:22, 32:5

review [5] - 6:19, 9:15, 24:3, 37:16, 37:21

reviewed [1] - 8:1revising [1] - 34:23Revisions [1] - 1:13Revisor's [2] - 1:8,

5:4rich [2] - 15:23,

18:21richness [1] - 21:24River [21] - 1:12,

12:2, 14:4, 14:18, 15:22, 17:6, 17:7, 18:21, 19:12, 22:25, 23:8, 27:16, 29:13, 29:15, 29:23, 39:2, 39:5, 39:13, 43:14, 43:25

river [26] - 4:24,

12:12, 14:2, 17:9, 18:21, 22:20, 23:2, 23:8, 23:9, 23:10, 25:3, 25:19, 26:3, 27:4, 27:14, 27:20, 27:21, 31:1, 31:18, 35:23, 36:5, 36:16, 39:1, 39:16, 41:14

river-nutrient [2] - 36:5, 41:14

rivers [13] - 14:16, 16:1, 17:5, 17:7, 22:21, 24:15, 24:17, 24:18, 26:9, 27:19, 38:19, 43:8

Road [2] - 1:22, 2:6robust [2] - 24:22,

26:5Rochester [1] - 4:21role [3] - 4:7, 41:18room [4] - 11:9, 15:2,

15:3Room [1] - 4:18RPR [1] - 45:18rule [4] - 4:23, 7:11,

7:24, 11:3Rule [3] - 5:1, 5:8,

11:18Rulemaking [1] -

44:25rulemaking [5] -

4:11, 5:25, 42:13, 42:18, 42:21

rules [10] - 4:5, 4:22, 5:15, 5:20, 5:23, 6:1, 10:2, 11:14, 11:17, 34:14

Rules [2] - 1:11, 2:10Rum [1] - 17:7

S

sample [3] - 31:9, 35:3

sampled [1] - 31:1samples [2] - 31:16,

38:9sampling [1] - 31:7saw [2] - 36:15,

40:10schedule [1] - 43:22science [1] - 43:23Scientist [3] - 2:11,

2:12, 2:13scientist [1] - 34:1score [1] - 18:9seasonal [1] - 37:24second [2] - 9:10,

9:18

Secondly [2] - 14:15, 25:17

sections [2] - 7:24, 7:25

see [28] - 10:5, 13:16, 15:21, 15:24, 18:4, 18:11, 18:13, 19:14, 19:16, 19:19, 19:25, 21:1, 21:12, 21:24, 22:3, 22:25, 23:19, 24:15, 27:23, 28:13, 31:25, 37:6, 39:22, 40:6, 40:13, 40:15, 41:12, 43:1

seeing [2] - 22:4, 37:4

seek [1] - 28:16seeking [1] - 21:22seem [1] - 39:15selected [2] - 38:6,

39:8sense [1] - 23:21sensitive [4] - 21:16,

40:16, 41:6, 41:10separate [3] - 41:16,

41:18, 42:20separated [1] - 38:20separately [1] -

38:20September [4] -

31:6, 38:1, 42:10, 43:19

serve [1] - 11:12set [3] - 4:14, 5:10,

34:20sets [1] - 20:25setting [1] - 35:18several [1] - 22:17severe [4] - 28:11,

28:12, 28:14, 28:25shallower [1] - 18:7share [2] - 6:3, 12:23sheet [1] - 44:11shift [1] - 23:7show [1] - 26:15showed [2] - 36:25,

40:11showing [1] - 41:25shown [1] - 40:25side [1] - 10:23sign [3] - 6:25, 7:3,

10:5sign-in [1] - 10:5significant [2] - 18:9,

21:15signup [1] - 44:11siltier [1] - 39:14similar [6] - 7:11,

15:18, 32:4, 36:24, 40:10, 41:17


7

simply [2] - 6:6, 41:2site [9] - 14:3, 14:17,

27:12, 27:15, 28:8, 42:13, 42:17, 42:22, 42:25

site-specific [8] - 14:3, 14:17, 27:15, 28:8, 42:13, 42:17, 42:22, 42:25

Sites [1] - 38:3sites [13] - 13:2,

17:9, 17:18, 18:10, 18:12, 19:6, 25:13, 26:3, 26:4, 38:5, 38:18

sitting [1] - 22:25six [3] - 24:21, 30:23,

31:1sizes [1] - 17:20slide [5] - 36:17,

36:24, 37:8, 40:10, 41:25

Slide [2] - 30:13, 32:8

slowly [1] - 8:9small [1] - 20:1smaller [1] - 17:21smothering [2] -

34:10smothers [2] - 43:12soil [2] - 22:14, 36:4solid [3] - 40:22,

42:6, 43:24solids [22] - 4:25,

12:14, 14:5, 14:8, 32:2, 34:5, 34:7, 34:9, 34:24, 35:2, 35:6, 35:21, 35:23, 36:8, 36:12, 37:19, 38:21, 40:1, 40:15, 40:17, 43:3, 43:11

Solids [1] - 1:13SONAR [2] - 14:7,

23:11sophisticated [1] -

23:22sorry [1] - 43:19Sorry [1] - 13:9sort [1] - 39:4sound [1] - 36:22south [2] - 24:9, 26:1southern [2] - 25:11,

29:14SPEAKER [3] - 3:6,

15:1, 15:6speaker [2] - 7:15,

8:15speakers [1] - 8:7speaking [1] - 7:7special [1] - 39:3

specific [11] - 7:23, 12:7, 14:3, 14:7, 14:17, 27:15, 28:8, 42:13, 42:17, 42:22, 42:25

specifically [1] - 4:10

spell [2] - 7:8, 8:12spelling [1] - 8:16spoken [1] - 8:10spread [1] - 24:22Spring [1] - 28:5square [1] - 26:19St [10] - 1:23, 2:7,

4:19, 15:3, 23:4, 29:16, 29:24, 32:10, 32:18

STAFF [1] - 2:4staff [4] - 11:1, 12:4,

12:6, 22:25stakeholders [1] -

15:15standard [21] -

15:14, 19:21, 19:23, 20:4, 20:11, 25:20, 25:22, 29:17, 29:25, 30:8, 32:23, 34:5, 34:15, 34:24, 35:15, 36:8, 37:2, 42:6, 42:17, 42:22, 42:25

standard's [2] - 20:16, 25:2

standards [37] - 4:24, 12:1, 12:12, 12:14, 12:24, 13:14, 14:1, 14:2, 14:3, 14:5, 14:12, 14:14, 14:17, 14:20, 15:19, 20:20, 22:19, 24:16, 26:8, 27:14, 27:15, 28:8, 28:15, 29:10, 29:12, 29:21, 30:1, 31:25, 32:6, 32:19, 33:5, 33:19, 34:3, 42:3, 42:13, 43:5, 43:24

Standards [2] - 1:12, 1:13

standing [1] - 14:13start [3] - 22:3,

23:16, 23:21starts [1] - 17:24state [9] - 7:7, 7:21,

34:21, 35:24, 36:2, 36:6, 36:17, 36:23, 41:23

STATE [2] - 1:2, 45:1State [4] - 1:11, 4:3,

5:7, 30:5state-wide [1] -

34:21

Statement [1] - 11:14

statements [2] - 6:22, 8:10

states [2] - 9:12, 14:14

statewide [1] - 41:19statistic [3] - 21:14,

22:5, 22:8statistical [6] - 17:1,

21:3, 21:8, 40:4, 40:19, 41:1

statistics [1] - 22:9Statute [2] - 4:11,

9:12statutory [1] - 9:22staying [1] - 20:12stays [1] - 20:17stem [1] - 39:3stenograph [1] -

45:10Steve [10] - 12:10,

13:15, 35:24, 36:4, 36:17, 36:25, 37:9, 40:10, 42:16, 43:7

STEVEN [20] - 2:11, 12:20, 13:11, 13:23, 14:25, 15:7, 20:8, 20:19, 20:23, 30:16, 30:20, 30:25, 31:4, 31:12, 32:14, 32:17, 32:21, 33:8, 33:12, 33:24

Steven [1] - 3:9storm [1] - 38:11straightforward [1] -

22:23stream [6] - 16:6,

17:20, 19:9, 26:11, 37:23, 38:18

streams [16] - 14:16, 15:17, 17:21, 18:6, 18:7, 18:17, 20:9, 20:14, 22:12, 25:10, 25:11, 41:15, 41:19, 41:21, 41:22, 41:23

streams' [1] - 26:20stressor [2] - 27:6,

27:11strong [3] - 17:25,

36:8, 36:20studies [1] - 17:3stuff [2] - 23:19,

26:14submerged [2] -

43:7, 43:10submit [5] - 7:2,

8:23, 9:6, 9:11, 44:19submitted [4] - 6:14,

8:24, 9:13, 9:15

submitting [1] - 9:1subsequently [1] -

16:25subtle [1] - 16:2suggests [1] - 26:18summarize [1] - 24:5summary [2] - 11:8,

41:25Summer [1] - 31:6summer [7] - 19:15,

24:14, 24:20, 28:11, 30:22, 30:24, 43:17

summers [6] - 24:18, 24:20, 24:23, 31:19, 32:5, 43:20

support [3] - 12:1, 20:14, 27:22

Supporting [1] - 1:13surface [1] - 15:24suspend [1] - 19:8suspended [26] -

4:25, 12:14, 14:5, 14:8, 16:13, 17:10, 18:1, 24:11, 32:1, 34:4, 34:7, 34:23, 35:1, 35:6, 35:21, 35:23, 36:8, 36:12, 37:19, 38:21, 39:25, 40:15, 40:17, 42:6, 43:3, 43:24

Suspended [3] - 1:12, 34:8, 43:11

swimming [1] - 27:25

system [7] - 18:19, 18:25, 19:3, 19:14, 19:19, 19:23, 19:24

systems [5] - 15:23, 16:12, 18:16, 29:9, 29:20

T

table [8] - 5:6, 5:10, 7:1, 7:6, 10:5, 38:24, 39:21, 41:13

tables [1] - 41:25taxa [2] - 21:24, 22:5technical [1] - 8:12TECHNICIAN [1] -

13:15technicians [1] -

35:12technique [2] -

21:19, 21:20tend [1] - 39:6term [6] - 16:19,

16:21, 18:2, 18:22, 20:1, 25:18

terms [13] - 8:13, 15:8, 34:11, 34:19, 35:17, 36:2, 36:19, 37:1, 38:14, 39:12, 40:21, 42:11

testimony [1] - 44:7THE [30] - 1:4, 2:3,

4:1, 10:11, 10:23, 12:18, 12:25, 13:6, 13:18, 13:21, 14:23, 15:5, 20:5, 20:18, 20:21, 30:12, 30:17, 30:21, 31:2, 31:8, 32:7, 32:16, 32:20, 33:6, 33:10, 33:22, 39:9, 44:2, 44:4, 44:10

themselves [1] - 12:8

therefore [1] - 8:6thirdly [1] - 14:19three [5] - 5:18, 6:9,

11:12, 24:10, 25:7threshold [2] - 22:8,

23:23thresholds [3] -

21:11, 21:23, 22:10throughout [2] -

15:8, 17:7timeframe [1] - 31:3TMDL [1] - 33:15today [9] - 4:6, 6:4,

6:13, 7:3, 7:25, 9:4, 12:6, 12:23, 24:7

Today [1] - 34:3today's [1] - 6:10together [5] - 17:23,

23:14, 24:5, 29:20, 40:5

took [3] - 17:3, 30:7, 38:6

topic [1] - 26:17total [17] - 4:25,

12:14, 14:5, 17:8, 30:14, 32:1, 34:4, 34:23, 35:6, 35:18, 35:21, 35:22, 36:7, 36:12, 38:21, 42:6, 43:3

Total [1] - 1:12touch [1] - 5:12towards [1] - 41:9TP [1] - 18:24Training [1] - 4:17training [2] - 15:1,

15:3transcribed [1] - 8:4transcript [3] - 45:8,

45:9, 45:11transitional [1] -


8

27:17translator [4] - 26:9,

26:23, 27:2, 27:8treated [1] - 4:13tree [1] - 21:21trial [1] - 7:15triangles [1] - 18:6tributaries [1] -

38:19tried [1] - 17:7trout [3] - 41:15,

41:19, 41:21true [2] - 27:19,

45:10truly [1] - 27:18trying [3] - 23:19,

40:21, 41:20TSS [1] - 35:15Tuesday [1] - 9:6turbidity [3] - 34:15,

35:8, 41:19twice [1] - 44:15Twin [2] - 29:22,

29:24two [13] - 12:1, 12:4,

18:20, 19:11, 21:8, 24:18, 24:20, 30:22, 31:10, 31:19, 37:4, 37:5, 40:24

type [1] - 22:14types [2] - 36:4,

41:10typically [1] - 41:22

U

ultimately [1] - 16:23under [2] - 5:15, 5:18underlying [1] -

22:20underway [1] - 32:25unit [2] - 18:12, 34:3unitless [1] - 34:17unless [1] - 12:16up [18] - 5:9, 7:6,

13:9, 14:5, 18:20, 20:2, 22:6, 23:19, 25:22, 26:12, 27:20, 35:18, 37:7, 38:6, 38:16, 39:21, 42:5

Upper [1] - 28:3upper [6] - 19:12,

21:12, 22:1, 37:7upper-left [1] - 37:7USEPA [1] - 14:13uses [3] - 26:20,

26:22, 27:23

V

valid [1] - 24:24valuable [1] - 41:21value [4] - 34:21,

35:6, 38:21, 41:19values [5] - 25:7,

38:16, 38:25, 41:11, 43:2

variability [1] - 40:24variable [1] - 24:10variables [4] - 25:1,

37:5, 40:20, 40:23variety [9] - 17:24,

27:22, 35:10, 35:11, 36:13, 38:9, 39:22, 40:9

various [2] - 16:9, 17:8

vegetation [3] - 22:15, 43:7, 43:10

versus [2] - 23:8, 42:20

video [1] - 13:19videoconference [1]

- 4:20views [1] - 7:21violate [2] - 30:18violated [1] - 25:2violating [1] - 19:22violation [2] - 30:13,

32:9

W

wadeable [5] - 18:6, 18:7, 18:10, 18:11, 18:16

wants [2] - 14:9, 44:13

Water [1] - 1:11water [27] - 4:24,

12:11, 12:13, 12:24, 13:14, 14:1, 19:21, 19:23, 20:10, 20:14, 22:13, 23:4, 25:2, 26:13, 27:18, 27:25, 28:15, 34:5, 34:24, 35:3, 37:2, 38:1, 39:13, 42:2, 42:6, 43:5

water-quality [3] - 42:2, 42:6, 43:5

waters [5] - 15:10, 30:4, 30:11, 41:15

watershed [3] - 33:17, 36:3, 39:12

watersheds [1] -


9

23:5Watonwan [1] -

15:22ways [1] - 40:1website [1] - 11:11Wednesday [1] -

44:24weighing [1] - 41:9welcome [1] - 44:3whole [1] - 22:6wide [1] - 34:21WILL [1] - 2:13Wisconsin [2] - 30:5,

32:24wish [3] - 7:2, 7:3,

7:20writing [1] - 8:23written [4] - 7:2,

8:20, 9:6, 44:19

Y

year [1] - 31:11years [4] - 17:4,

28:13, 37:13, 38:8

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