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Working for clean water, healthy ecosystems and lasting quality of life in the Flathead Watershed in Northwest Montana. | |||||||||||||||||||||||||
P.O. Box 70 | Polson, MT 59860 | 406-883-1346 | Email to Lakers | |||||||||||||||||||||||||
| Lakers' Comments on TMDL Plan November 29, 2001 Mark Holston, Public Information Officer Dear Mark: The Flathead Lakers strongly support adoption and implementation of Total Maximum Daily Loads and a Nutrient Management Plan for Flathead Lake. The October 30, 2001 draft does an excellent job of summarizing Flathead Lake and watershed characteristics and conditions, and explaining the justification for the proposed TMDLs. We strongly support the Water Quality Restoration Targets (5-1). The Flathead Lakers is a nonprofit, conservation organization, with over 1,000 members, working for clean water, healthy ecosystems and lasting quality of life in the Flathead Watershed. Founded in 1958, the organization is the largest lake protection group in the state and one of the oldest conservation groups. We work to protect and improve water quality in the Flathead Watershed through education, advocacy and stewardship projects. We hope our organization's ongoing efforts will contribute to success in achieving the water quality restoration targets. One project is especially significant in relation to nutrient loads in Flathead Lake. The "Critical Lands Project" is a collaborative initiative to identify and protect or restore those lands critical to maintaining and improving Flathead Lake quality. Our main comments on the draft concern funding for monitoring and restoration strategies, and the load reduction allocation. Funding Expansion of the existing long-term Flathead Basin Water Quality Monitoring Program is recommended in the draft, including adding monitoring sites for tributaries and the lake, conducting additional synoptic monitoring, and conducting "focused source assessment to locate specific agricultural and urban sources." The Flathead Lakers have long supported the existing monitoring program and support the proposed expansion. In fact, the proposed additional monitoring programs would provide valuable information for our Critical Lands Project to help make more direct connections between stream and river sections where nutrient loads are a concern and the source of those nutrients in order to guide protection and restoration work. However, over the past several years, funding for the existing monitoring program has declined. The Flathead Lakers have worked diligently to assure adequate funding for continued monitoring. But, unfortunately, insufficient funding continues to plague the program and this year the program has been drastically scaled back due to a funding shortfall. We strongly recommend adding a new section to the draft that explains the funding problems and outlines how both the long-term monitoring program and the recommended new monitoring programs can be funded. Otherwise, we fear, the draft is merely recommending a wish list rather than concrete objectives with some likelihood of being implemented. A similar additional section on funding sources is needed for recommended modeling, restoration strategies and additional studies. Load Reduction Target and Allocation: "A 25 percent reduction in nitrogen and phosphorus loads... is recommended as the TMDL" (5-4), which includes a 15 percent load reduction needed to achieve restoration targets plus 10 percent to account for future increases in nutrient loading related to population growth and development. How the 10 percent growth factor was derived should be clarified. What time period was used to estimate a growth factor? How do population growth projections translate into increased nutrient loads from nonpoint sources? We believe public acceptance of the 10 percent growth factor would be improved with a clearer understanding of it. More flexibility in allocating the 10 percent growth factor for nutrient reduction may be needed. For example, it may be easier and less costly to reduce, or in some cases even eliminate, nutrient contributions from new growth and development as it occurs rather than retrofit existing urban development. The draft clearly explains that excessive nutrient loads come from several sources (4-7 through 4-15). However, it appears that the draft recommends the entire 25 percent reduction come from either nonpoint urban and agricultural sources in the valley north of Flathead Lake, or a combination of the nonpoint and point sources (Figure 5-1 Proposed Allocation Scheme), at least in Phase I. Although we agree with the draft that the urban/agricultural area north of the lake is a top priority for restoration efforts, the area should not be required to shoulder the entire burden of this significant nutrient reduction percentage for the entire watershed. The draft clearly shows that managed forests contribute to nutrient loading, equaling the phosphorus load for the urban/ag source category and exceeding the nitrate/nitrite load for the urban/ag source area (Figures 4-7 and 4-8). And, the draft states that studies "clearly demonstrated that forestry practices can result in a statistically significant increase in nutrient loading" (5-7). Though data may not exist to precisely allocate loads to the various source categories, the information presented in the draft shows that forestry practices are contributing to nutrient loading. Therefore, Phase I restoration strategies should include recommendations for managed forest lands. Even with declining timber harvest levels and successful implementation of forestry BMPs, a legacy of past forestry practices continues to contribute to nutrient loading. And, even though there is uncertainty about how much of the nutrient loads "from forested lands in the headwaters of the basin are actually delivered to the lake..." (5-8), there are about 40 perennial and intermittent streams flowing through managed forest lands that are direct tributaries to the lake. The Flathead Lakers recommend including a managed forest lands allocation and including recommendations for nutrient reduction strategies for managed forest lands. As additional information becomes available, the allocation and strategies can be refined through adaptive management. Further, we recommend that Phase I include a recommendation for a study of the effectiveness of forestry BMPs in reducing nutrient loads from managed forest lands. Although compliance with the voluntary BMPs is very high (Table 5-4), no information is provided to explain what reductions in nutrient loads the BMPs are achieving. Additional Recommendations: The Flathead Lakers' board and staff greatly appreciate the efforts of the Flathead Basin Commission to initiate the development of a TMDL for Flathead Lake and appreciate the work of the Flathead Basin Commission and the Department of Environmental Quality to prepare the Draft Nutrient Management Plan and Total Maximum Daily Load for Flathead Lake, Montana. Thank you for the opportunity to comment. Sincerely, Robin Steinkraus, Executive Director cc: Ron Steg, Watershed Coordinator | ||||||||||||||||||||||||
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