Response to comments

In an attempt to provide feedback to comments we receive and to encourage greater use of the Comment box found at the bottom of each page, we provide responses to many of the comments we receive. This page will be updated about once a week or as we receive comments.

Comment: We have received comments requesting having an author and date on certain pages in the Stormwater Manual.

Response: Unless otherwise noted, all material in the Manual is owned by the Minnesota Pollution Control Agency (MPCA). Work developed by contractors for the MPCA is owned by the MPCA. Dates for pages can be found in two locations on a given page. Scroll to the bottom of a page to find when the page was last updated. Also, in the left toolbar, click on Page information to get more information about the page, including the date of creation, date of last edit, number of downloads, edit history, and page creator. If you wish to cite the page, in the left toolbar click on Site this page and you will be taken to a page with multiple options for citing the page.

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Comment: Regarding this table - Make this grid printable with grid lines and offer Print as an option.

Response: We added the option of downloading the table either as a Word document or Excel spreadsheet.

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Comment: They typical dry swale profiles and sections sheet is too low resolution to read text even when trying to view the original file. Thanks! https://stormwater.pca.state.mn.us/images/7/7c/Typical_dry_swale_profile_section_with_check_dams_and_draintile.png

Response: The original detail sheets are in .pdf format and therefore cannot be converted to images with appropriate resolution. We therefore removed the .png image and added an alert box notifying users that they must open the pdf links to obtain higher resolution images. see here.

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Comment: Regarding Winter Road Materials BMPs - Please provide the link for this referenced document "see the appropriate Hazardous Material Storage and Handling fact sheet."

Response: We have added links to material safety data sheets for several deicing compounds

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Comment: Regarding this page - Make this simple

Response: We added an information box at the top of the page that provides a simple explanation of how deicers work and a link to a table with more information.

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Comment: Regarding this page - I live in N MPLS and want to reduce my monthly "Storm sewer fee". Watching the installation of a "High End" pavement system in an EXPENSIVE neighborhood does NOTHING to encourage me. Get real, I can't afford the garage that was seen in the video much less the pavers that "are architecturally compatible with the house". What is a CHEAP on a BUDGET way of doing it? I sure didn't learn anything from the video.

Response: This manual focuses on design, construction, and maintenance aspects of stormwater management. The video is intended to show these aspects of permeable pavements. We have added some additional information that may be useful for homeowners and more applicable for the person submitting this comment.

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Comment: Regarding the annual report submittal - “Grossly cut the size! There is no reason for 22 pages. Also cut the size of the Annual Report, most is duplicative.”

Response:

• The MS4 annual report is available via Snap Surveys, which may cause the report to appear longer to a respondent when filling it out than it actually is. Please note, the survey is coded so that depending on a response, subsequent questions may or may not appear. A better example of the true length of the report is the complete list of questions, which totals nine pages in a formatted Word document (found near the bottom of the page)
• It would be helpful to us if the commenter identified specific instances of duplicity. Thanks.

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Comment: Referring to this section - The "Calculate water quality volume achieved" section needs some addtional parentheses to calculate correctly. Would be helpful to have output units since input units are given.

Response: Resolved

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Comment: Please add the category "Green Roof Professional" to the table above labeled: Potential roles in green roof design. This is a certification administered by Green Roofs for Healthy Cities.

Response: We added Green Roof Professional to the table.

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Comment: It would be nice if we could get a copy of all previous versions of this permit on the page. It helps with comments for new draft permits. It is nice to be able to look back and see how long something has been a requirement and the subtle changes that have occurred over time. I think this can only be in the PCA's best interest as you can point to the fact that certain requirements have been in place for a specified amount of time when responding to comments. The 2006 permit is shown here https://www.pca.state.mn.us/water/municipal-stormwater-ms4#permit-d50fce22, but there was a permit issued before that. Might be good to include the history with that earlier permit on this page too.

Response - link here for 2006 permit. The MPCA issued the original MS4 General Permit in June 2002. In July 2002, Minnesota Center for Environmental Advocacy (MCEA) filed an appeal of the permit. On May 6, 2003, the Minnesota Court of Appeals ruled that the use of general permits and best management practices was appropriate, and that the monitoring required in the permit was adequate. The court also called for the opportunity for public comment and public hearing on each permittee’s proposed stormwater pollution prevention program, required the MPCA to determine if additional control measures are necessary if the permittee has new or expanded discharges, and ruled that the language of Minnesota’s permit must follow federal language and require permittees to “reduce” (instead of “minimize”) pollutants. Revisions were made to the permit to address the courts’ ruling. The first reissuance of the permit became effective June 1, 2006. link here for more information on the 2002 permit.

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Comment: It would be nice if we could get a copy of all previous versions of this permit (Construction Stormwater) on the page. It helps with both enforcement (for MS4s) and comments for new draft permits. It is nice to be able to look back and see how long something has been a requirement.

Response: Done - link here

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Comment: Referring to What is stormwater and why does it need to be managed?, "Hey, I am a high schooler, this page has helped me with so much with my assignment about nutrient run off"

Response: Normally we would not respond to a comment such as this, even though it is appreciated. But it does call to mind that the wiki technology has allowed us to expand the traditional information in a stormwater manual to include information that can be used by a wider variety of audiences. For example, check out the education section of the manual.

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Comment: Regarding this page - potassium acetate has little information

Response: There is little information in the literature on potassium acetate, particularly effects on soil and vegetation. This article discusses sodium acetate and the authors conclude that sodium acetate in relatively non-toxic. More research is needed before we can include information on the environmental effects of potassium acetate.

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Comment: Regarding this page - Has civil 3D's storm and sanitary analysis been evaluated so that it can be included in this list?

Response: We added the model and included a short description, a link, and a row in the table. If the submitter would like to provide more information, please feel free to do so.

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Comment: Regarding this table - How about a table that lists percentage by weight? Salt on ice is used by a few knowledgeable people to transport frozen foods and to provide thermal mass in a freezer when a power loss is expected. I used to put 5 pounds of salt on 20 pounds of ice in a large cooler and to keep large baits frozen when fishing in the Bahamas. (Ice comes in 10 pound bags and salt in 1 pound containers. Later of ice, layer of salt is how this is done.

Response: Our intended audience is winter maintenance professionals and that is who we worked with to develop the recommendations. We do not at this point have the expertise to make recommendations for this particular use of salt. If the submitter could provide more information on the applicability for winter maintenance, we could incorporate it into a table.

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Comment: Regarding the page "MS4 General Permit" - It's annoying that you cant read the entire permit in one go and you have to go back a page to get to the links for each section. Have the whole permit and a list of each section

Response: The above page linked to the 2013 MS4 General Permit. We renamed the page (2013 MS4 General Permit), redirected from the old site to the new site, and created a single document that contains the entire permit, as requested (Entire 2013 MS4 General Permit as a single document)

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Comment: Regarding this page - Example 1 notes that H=10', Y=8', and Z=6.83'. Example 1 then states that the pervious length is Y+Z; but it shows 8'+10'... Shouldn't it show 8'+6.83'?

Response: In this example the 8 feet vegetated access area between panels is assuming that the 10 foot panels are horizontal. This would result in an 18 foot pervious length from one dripline to the next dripline.

Calculating the pervious length as 8’+6.83’ does not account for the entire pervious area. The pervious length between panels in adjacent rows (Y) is not 8 feet when the panels are rotated at an angle between 30 and 60 degrees. Y is calculated as the vegetated access (8 feet) plus the difference between the horizontal and average lengths of the solar panels (10 feet minus 6.83 feet, or 3.17 feet) for a length of 11.17 feet. Using a Z of 6.83 feet and Y of 11.17 feet will result in a pervious length of 18 feet.

The pervious length can be calculated in two ways:

• as the length of each panel (10 feet) plus the distance between panels when horizontal (8 feet)
• as the average horizontal distance below the rotated panels (Z) plus the pervious length between panels in adjacent rows (Y) for the rotated panels

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Comment: Regarding this page - Keep the units consistent. Disk anchoring should also be in SY ($0.02/SY) or all the blankets be in cost per acre (Cat3 = $7,260/acre).

Response: Resolved

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Comment: Regarding this table - Effectiveness table lists "Water Quantity" twice

Response: Resolved

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Comment: On the Karst page - The following links don't seem to work anymore: The Characterization and Remediation of Sinkholes; and repair the practice following guidance above.

Response: We have updated all links on this page.

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Comment: There were several comments/suggestions for improving the Case studies for pretreatment page.

Response: We believe these comments have been addressed.

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Comment: Many of the equations [display the coding rather than the equation]. It appears that there is a coding error. Should it start with </math> to display the text properly?

Response: This is a display issue with the Mediawiki math extension. Refresh the page and the equations should display correctly. Sorry for the inconvenience. Unfortunately, there isn't a satisfactory work around at this time.

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Comment: I cannot find anything in the Manual that has to do with logging activity and how to maintain BMP's for clear cutting. I would like to see a section on this in the Manual (comment submitted from the page on Erosion prevention practices.

Response: We weren't sure if this was a question relating to silviculture practices or typical stormwater practices that our program deals with. Silvicultural activity is exempt from stormwater permit coverage. Some websites that may be useful are Sustaining Minnesota Forest Resources:Voluntary Site-Level Forest Management Guidelines for Landowners, Loggers and Resource Managers; Minnesota's Forest Management Guidelines; Erosion Control Best Management Practices for Logging and Forestry; and Field practices - Silviculture Program (Minnesota DNR). If these do not address the comment, feel free to contact us: (Mike Trojan or Todd Smith).

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Comment: When used in a filtration basin, Mix E, filter topsoil borrow, probably only sheds phosphorus for a short time, such as one season. I would expect that by season three, the basin no longer sheds phosphorous, maybe sometimes stopping in season two. The recommendations in the stormwater manual are sometimes taken as fact, with some regulators wanting to reject filter topsoil borrow. I believe sometimes we lost the benefits of a vegetated basin to the complete ecosystem when we are forced to switch to a plantless iron-enhanced sand basin to guarantee phosphorus reduction from the start. Please continue to promote testing beyond a season so that we can find the long-term effects of filter topsoil borrow in filtration basins. Please link or cite research supporting the opinions of compost in filtration basins and if possible, include the duration of the research.

Response: The MPCA is working with U of M researchers to identify engineered bioretention materials that do not leach phosphorus or that can be used as amendments to retain phosphorus. This includes a comprehensive literature review, conducted through an MPCA work order, and mesocosm studies conducted by the University of Minnesota. In developing a phosphorus credit for bioretention and green roofs in 2013, which utilize similar media, our contractor conducted a literature review of phosphorus export from media with high organic matter content. Nearly all studies showed that phosphorus leached from the media, but the extent of and duration (years) of phosphorus export varied. Additional work has been conducted since this 2013 literature review; thus the on-going work.

Note that MPCA recommendations to avoid bioretention mixes A, B, E, and F are for underdrained BMPs. Use of these mixes is not a concern for infiltration practices, except possibly when these practices are located immediately adjacent to receiving waters impaired for phosphorus.

We will also be reorganizing the information on engineered media in the manual. Currently this information resides on a single page that addresses design criteria for bioretention. We believe information on engineered media warrants its own section in the manual and anticipate organizing this information accordingly in the next few months.

To see the 2013 literature review, link here for green roofs and here for bioretention. The on-going literature review will likely be completed this year and the manual will be updated. The U of M research ends in spring, 2020 and results of that research will be incorporated into the manual.

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Comment: This comment refers to this page - This seems drastically wrong. Concrete weighs somewhere between 5 and 10% more than that at 150 pcf). Glacial till around here weighs something like +35%, and sand is about +57%... quartzite is right, though spelled wrong. I would point out that glacial sandy soil transitions to tillite progressively in glacial regions. Are these values extremely conservative in some particular regard, or is there a problem with transcription? I doubt that these materials would have these physical properties even if oven dried.

Response: The values are generally correct. There may be confusion with particle density, which is about 2.65 g/cm³ for soil solids. Since bulk density includes the volume taken up by air and water, it is always less than the particle density for undisturbed soils. In the caption for this table we included a link to the page on alleviating compaction in soil.

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Comment: There are missing some explanations in the formulas from this page.

Response: We rewrote the section referred to above. We felt the section, as previously written was confusing and contained irrelevant information. The section should now be clearer.

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Comment: Correction is needed in several areas where SWPPP is written when it should state SWMP. This is important, because many professionals look to Minnesota for leadership in MS4 program management areas. For example, there are several documents (such as MS4 checklists) and webpages such as https://stormwater.pca.state.mn.us/index.php?title=Phase_II_MS4_audit_process

Response: During the rule making in 2002, Minnesota decided to use the term Stormwater Pollution Prevention Program (SWPPP) for municipal stormwater, rather than Stormwater Management Plan (SWMP). This was institutionalized in Minn. 7090.1040. Therefore, unless we open up our Stormwater rules to revise them, we can’t change it.

We've decided to include the following alert box at appropriate places in our manual to notify readers of this.

Information: NOTE: Minnesota uses the term Stormwater Pollution Prevention Program (SWPPP) for MS4 stormwater, while several states and EPA may use the term Stormwater Management Plan (SWMP). These terms refer to the same thing.

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Comment: Referencing this page - links are broken

Response: Resolved

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Comment: In the "Overview for iron enhanced sand filter" the following statement is made: "Vegetation should not be allowed to grow over the iron enhanced media. Decomposed vegetation may reduce oxygen in the filter media and cause a chemical change in the iron resulting in filter media fouling." Yet, on the "design criteria for iron enhanced sand filters," under the "design phase maintenance considerations" section it recommends utilizing native plantings. These conflicting points are somewhat confusing and should be reviewed.

Response: We modified the language on the design phase to indicate that the surface of the iron-enhanced sand filter should not be vegetated, The language now reads:

• utilizing native plantings (see Plants for Stormwater Design). NOTE this does not apply to the sand filter surface.

Caution: The MPCA Recommends that the iron-sand filter surface be maintained free of vegetation or grasses. Ground cover can be used to stabilize the banks of the live storage zone above the elevation of the sand filter surface. Shrubs or other woody plants can be planted above live storage.

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Comment: [Regarding constructed stormwater ponds] - What are the building setbacks, how far should a building be from the edge of the pond?

Response: There is a section on the pond design page that discusses setbacks, but specific numbers are not provided. The horizontal setback distances for infiltration practices, provided on this page, can be applied to constructed ponds unless local regulations apply. NOTE that a pond buffer of 25 feet is recommended and no buildings should be located within the buffer. Since the recommended setback for buildings is 10 feet for infiltration practices, this would be 10 feet from the outer edge of a pond buffer.

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Comment: The last link under References doesn't work. (from the page Pollution prevention)

Response: The link went to the University of Michigan's page on winter maintenance. We were unable to find an updated link and replaced it with a link to the MN Pollution Control Agency's page on winter maintenance.

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Comment: WHERE ARE THE DETAILS FOR PAVERS (Reference is to this page)

Answer: The above reference page provides links to fact sheets on permeable pavements. Specific information in the Minnesota Stormwater Manual can be found using the links in the "Related articles" section at the bottom of the page. Details for permeable pavement will most likely be found in Design criteria for permeable pavement or Types of permeable pavement.

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Comment: Link to U of M street sweeping page is broken: http://larrybakerlab.cfans.umn.edu/home/research-projects/quantifying-nutrient-removal-by-street-sweeping (on this page

Answer: Thanks- resolved.

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Comment: Can this tool (the MIDS calculator) be used for zipcodes in other states?

Answer: The calculations in the calculator are based on long-term modeling for different Minnesota locations and scenarios (see here for more information). Modifying the zip code data, while feasible, would result in erroneous results, particularly if rainfall amounts and patterns differ significantly from those in Minnesota. To modify the zip code information, the user would open the excel file they are working with, go to the Zip Code Precip Lookup tab in the spreadsheet, and change the values in populated cells. You cannot add new cells since the calculation, made in cell C24 of the tab called Site Information and Summary, is locked and cannot be modified by users to accommodate new zip code information. But again, calculations in the calculator are based on modeling using Minnesota data.

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Comment: I have been looking for a straight up version of the SWPPP manual for 30-45 minutes, the same one that was given to us in the SWPPP class. I have been able to find 2005, 2008, and 2014 versions of the full manual, but have been unable to find the current version anywhere. I know it exists because I used the online version two months ago.

Answer: We don't know what this comment refers to. It may be referring to the University of Minnesota course. A link to their page is here. If the commenter wants to contact me, I can try to help identify the location of this resource (Mike Trojan, 651-757-2790).

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Comment: will this page be updated for 2018 annual reports?

Answer: Yes it will. The goal is to have it updated and the 2018 annual reports available be the end of this month (January).

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Comment: Illustration of perimeter ditch please Perimeter control.

Answer: To the page referenced above, we added links to other pages that include information and illustrations on perimeter control.

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Comment: Type on export TP Table above, lists Commercial TP export as 20, I think it should be 2.0

Answer: Corrected - thanks.

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Comment: Add capacity to download as pdf!

This comment references this page

Answer: It isn't clear if this comment refers to this specific page or to any page in the wiki. We have created a pdf for this specific page and include a link to that at the top of the page. The Mediawiki extension for creating .pdf documents was not maintained and the functionality became unreliable. We therefore deleted the extension and created instructions for exporting information. These instructions can be found on this page. We can also easily create pdf documents for any given page. Just send us a request via the comment box at the bottom of the page of interest.

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Comment: the tables [on this page] are not readable and it is really hard to tell which table you need to look at. Cumbersome to have to click on each one. Preferred the list, or at least make it more obvious what general industry sectors are covered in each table.

Answer: We are in the process of incorporating actual tables, instead of screen shots, onto this page. We expect to have this complete by late December, 2018.

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Comment: Please provide a citation reference for this table - Comparison of bulk densities for undisturbed soils and common urban conditions

Answer: Citation added - Schueler, T. 2000. The Compaction of Urban Soil: The Practice of Watershed Protection. Center for Watershed Protection, Ellicott City, MD. pp. 210-214.

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Comment: Referring to the page Erosion prevention practices, the following comment was submitted - Can you make a report about barriers?

Answer: We assume the comment relates to erosion control barriers. Barriers are sediment control practices and and are found here. We have a work order that will add information on stabilized earth/soil berms, including wood chip berms. ________________________________________________________________________________

Comment: This comment refers to this page - I can't find the list of certified contractors. How can I promote them if I can't even find the list? Please make it more noticeable as this could be very useful information for the public to use. Thank you!

Answer: The lists can be accessed by clicking on the appropriate link at the above webpage. We have added a brief paragraph at the top of this page that provides instructions for accessing the lists.

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Comment: Regarding the MS4 annual report submittal - Allow you to advance forward even if don't answer all questions. It is efficient to be able to continue inputting data while finding questions that need staff support. I would like to be able to go all the way to the end and then back up and fill in a few questions a day or two later rather than putting in a dummy place holder. Thank you.

Answer: This is a limitation of the Annual Report on Snap Surveys. Required fields cannot be bypassed before moving to the next page. A fillable word document is available so that users may see all of the possible questions contained in the Annual Report. It is available near the bottom of the: page here.

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Comment: Comment probably applies to all pages. In the left margin under Navigation, there's a link to "Export to PDF" - which leads to this page which indicates that's no longer feasible: "The MN Stormwater Manual no longer supports the following functions: Create a book Download as PDF That said, alternatives to 'save to PDF' are suggested. Recommend changing the text under Navigation from "Export to PDF" to "How to save this page"

Answer: Good comment. We are working with our IT people to attempt and change this. Mediawiki has some default links, so this is not a straightforward fix.

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Comment: What is a BMP? I came directly to this great plant list, from a google search on rain gardens.

Answer: BMP stands for best management practice, which is defined in our glossary as "one of many different structural or non–structural methods used to treat runoff, including such diverse measures as ponding, street sweeping, filtration through a rain garden and infiltration to a gravel trench." We added a link to the glossary. Also note that we have a new page in the manual on appropriate plants for swales. We hope to continue expanding information on plants in the future, including information on landscape design to maximize benefits of plants. See this page, which is in development.

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Comment: This comment references this page on alleviating compaction - I'm surprised you don't mention high pressure air injection with an "air spade" as a method to relieve soil compaction. Its fairly commonly used in the arborculture industry to excavate and/or restore soil perculation around soil compacted tree roots without damage. One can go quite deep, so it seems like a very promising tool that should be studied further.

Answer: We added a section on air spading to the page on alleviating compaction. The information we provide is very basic and we encourage readers to visit websites for more information. Since information on this technique is primarily on proprietary websites, we refrain from providing links, except for one site that provides information on using an air spade.

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Comment: What does PSH stand for (see footnote 1 under the table)? It's not defined on this page or in the glossary.

Answer: PSH stands for potential stormwater hotspot. We spelled this out and created a link to the page addressing potential stormwater hotspots.

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Comment: This comment pertains to the MS4 Annual Report - It would be nice if items that do not change would be uploaded automatically . An example is the list of inspectors that has not changed . It would save time during a busy time period ( Spring). It would be nice to have the previous years report in the system and all that has to be done is modify any changes.

Answer: At this time, the MPCA does not have the ability to have the Annual Report autopopulate with a previous year's entries. We are currently looking into this.

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Comment: On the page for road salt and smart salting, add in the link for the winter maintenance model policy. Will help city/county develop more sustainable policies. Is on mpcas website somewhere in the smart salting.

Answer: We created a "Check it out" image on the right side of this page, with a link to the model policies and examples.

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Comment: Had to contact MPCA to print doc.

Answer: To print the MS4 Annual Report (annual report), click the “Print” button near the bottom of the page. Some web browsers may block the printable annual report, as it is viewed as a pop-up. If the printable version of the annual report does not appear in a new page, you will need to allow the pop-up from survey.mn.gov. For Internet Explorer, if the page was blocked, an option to allow it should appear at the bottom of the page. For Chrome and Firefox, an icon should appear at the end of the address bar. Once allowed, a printable version of your annual report will appear in a new page.

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Comment: I find myself unable to log in to an actual report. The site simply takes me in circles on the home page.

Answer: To log in to the MS4 Annual Report, for new permittees (Albertville, Bayport, Blue Earth County, Buffalo-Red River Watershed District, Eagle Lake, Hanover, Isanti, Lake City, Mankato Township, Minnesota Correctional Facility- Stillwater, Minnesota State University- Mankato, Morris, Oak Park Heights, Rogers, Skyline, South Bend Township, St. Augusta, St. Francis, Thomson Township, VA Medical Center MS4- St. Cloud, and Wyoming) visit this link. All other permittees must go to this link.

To log in, you will need your login and password. This information can be found in an email sent the week of January 22, 2018 to each MS4 General Contact. This email was from "MPCA MS4 Permit Program" (mnit@webhost.snapsurveys.com), with the subject line, "MS4 Annual Report for 2017 - Login Information." If you are unable to find your login information, contact one of these MS4 staff.

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Comment: I cannot find where to begin the MS4 annual report for MS4 cities!

Answer: The MS4 Annual Report is through a separate website, Snap Surveys. To start the MS4 Annual Report, for new permittees (Albertville, Bayport, Blue Earth County, Buffalo-Red River Watershed District, Eagle Lake, Hanover, Isanti, Lake City, Mankato Township, Minnesota Correctional Facility- Stillwater, Minnesota State University- Mankato, Morris, Oak Park Heights, Rogers, Skyline, South Bend Township, St. Augusta, St. Francis, Thomson Township, VA Medical Center MS4- St. Cloud, and Wyoming) visit this link. All other permittees must go to this link to access the login page.

To begin the MS4 Annual Report, you will need your login and password, which were sent the week of January 22, 2018, to each MS4 General Contact. This email was from, "MPCA MS4 Permit Program" (mnit@webhost.snapsurveys.com), with the subject line, "MS4 Annual Report for 2017 - Login Information." If you are unable to find your login information, contact one of these MS4 staff.

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Comment: Please post more content I need more info for my project (MS4 fact sheet - Reducing Pet Waste)

Answer: We currently don't have resources to expand the information on this page. However, we added links to several external websites that should provide useful information. You may also do a search on "pet waste" using the search box in the Stormwater Manual wiki.

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Comment: I am trying to plan for my green roof, but have found sources that say Birdsfoot Coreopsis is an invasive species from Europe. Is this true, and if so, is it irresponsible to plant on my roof? And if so, it should be removed from this list. I'm wondering how accurate the other items are, in being labeled "native."

Answer: Birdsfoot Coreopsis is a native perennial forb (see here for more information). Birdsfoot trefoil (Lotus corniculatus) is an invasive species and perhaps the commenter mixed these two species. See DNR website for more information on Birdsfoot trefoil.

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Comment: This table, "Design infiltration rate as a function of soil texture for bioretention in Minnesota," used to have a modifier statement for compacted soils. I believe it pushed the grade one letter lower. If a B was compacted, it became a C. If that is still appropriate, it should be added to any section that shows the table.

Answer: This table has been modified to include the recommended language, including links to information on soil compaction. We also modified the table Design infiltration rates.

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Comment: In the table "Summary of drilling methods to collect soil samples for infiltration basins", "unable to perform blow counts" is listed as a liability for many methods; however, the interpretation of blow counts is not explained on this page. Is 11 blows per foot significant? Is 25? It would be helpful if an interpretation of blow counts was included on this page.

Answer: We added links to information on blow counts. See the footnote in the table.

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Comment: This link does not bring me to a stormwater manual pdf

Answer: There is no pdf version of the entire manual. We began creating individual pdf versions for some topics, but we did not believe they were being widely used so stopped creating these. It is relatively easy to create pdf or Word versions of pages from the manual. See link for help.

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Comment: Where can I view the previous annual reports?

Answer: We do not post the annual reports online or in the Manual. You can request previous annual reports by contacting the staff contact for the MS4.

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Comment: there's no citation. please put some. (see Filtration devices)

Answer: This page is from the original Minnesota Stormwater Manual (2005) and is outdated. We recommend using the Pretreatment section of the manual. We placed an alert at the top of the old page to guide users to this new page.

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Comment: Both the USDA soil classification system and the Unified Soil Classification System (USCS) are used in describing soils, but the USCS dominates the examples. Please include more examples with the USDA soil classification system, which was created specifically to reflect water movement and retention in soils.

Answer: We were unable to find an example boring log that we could use, but did find a blank form that allows for USDA classifications. We added text to the discussion of boring logs to illustrate how the USDA classification could be used.

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Comment: Could you please send me the link to this calculator. I am using it for a project which is proposed with an infiltration basin.

Answer: We assume this is requesting a link to the USGS mounding calculator. Go to this USGS website and on the right side at the top of the page look for the link to the Hantush Excel spreadwsheet.

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Comment: You can improve this page by putting the date on this website so people know when you made this website.

Answer: The data of the most recent page modification is shown at the bottom of each page. Also, in the left toolbar, under TOOLS, click on Page information to see the edit history for a particular page. This will show the date when the page was created and a history of changes made to the page. You can access any previous version of the page.

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Comment: the link for "Cost-benefit considerations for Smart Salting and road salt winter maintenance, https://stormwater.pca.state.mn.us/index.php?title=Cost-benefit_considerations_for_Smart_Salting_(S2)_and_road_salt_winter_maintenance&action=edit&redlink=1, is bad.

Answer: The page referred to in the comment had not been created. We built two pages that provide some information on costs.

• Success stories: salt reduction and cost saving examples
• Information on costs and economic impacts of road salt

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Comment: I can't find the ms4 permits anywhere. Would really like to find those. I'm looking for a particular permit, mn0061018 ... links to ms4 permits would be nice

Answer: These permits are now in the Manual

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Comment: A correction; the contact for Coon Creek watershed District (Sand Creek Stormwater Retrofit Project-2011) is not Jim Shaver of Carnelian-Marine WD, it is Tim Kelly, 763-755-0975, tkelly@cooncreekwd.org. Jim is also listed for Comfort Lake Forest Lake WD's project: Sand and Long Lakes Protection Project-2013

Answer: Both references corrected - thanks.

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Comment: I was looking for information on underground detention systems, particularly the idea of installing such a system in a road shoulder/outside lane as part of a road widening project

Answer: I'll check with our engineers and hopefully post a response in the next week.

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Comment: Just wanted to let you know about a math error in part 5 of the 3x 29,000 gallon tank spreadsheet. You divide the total cost by 3 for the price per tank, but then you divide it by 3x29,000 to get your price per gallon. Correct number should be $4.44.

Answer: Resolved.

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Comment: I'd like to search for stormwater offsite/crediting. I had heard that this exists in MN. But there doesn't seem to be a good way to just search through everything.

Answer: Information on stormwater credits can be found here. Another way of searching the manual is to go to Categories in the left toolbar and look for your topic. Not everything is included in a category, but many topics are. Credits are included in a category called Calculating credits.

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Comment: many broken links in your refs

Answer: Resolved.

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Comment: Many of the citations in this section do not appear in the reference list.

Answer: Resolved.

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Comment: The definition of sedimentation is incorrect. It is a copy and paste error.

Response: Fixed. Thanks. New definition - Process by which solids are removed from the water column by settling.

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Comment: Broken link in this sentence: "For more information on source water protection see Minnesota Department of Health." (found on this page)

Response: Fixed. Thanks. We appreciate being informed about broken links.

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Comment: There is another error in the permeable pavement section of the BMP Credit Calculations. Columns H-P row 127 incorrectly computes the volume reduction stored below underdrain. Refer to column G for the correct formula. Please update and publish a corrected version ASAP. Thank you.

Response: We found the error and created a corrected spreadsheet. You can access this spreadsheet at this link. Please read the alert box on this page. Because we have to write a work order and contract for changes to the calculator, we cannot modify the download files for Version 3 of the calculator. You must therefore open the corrected version of the calculator from the graphical user interface and continue to use that file for subsequent work in the calculator. You of course can use the corrected file to begin any number of new projects in the calculator. Contact us if you have questions.

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Comment: The following comment pertains to a page summarizing a case study for the Minneapolis Chain of Lakes: "add data on how quickly Secchi disk readings improved. I recall they went from <1' to 9' in the first couple of years. Is that correct?".

Response: This comment raises an excellent point. Many times case studies summarize work done to implement best management practices. Often there is no follow-up to these examples to demonstrate whether the practice(s) worked or did not work. For the page referenced above, we added the following information to the page: This case study from the original Stormwater Manual (2005) discusses actions taken primarily in the 1990's. The City of Minneapolis continued to implement stormwater practices since the completion of this case study. With data spanning several decades, it is now possible to determine water quality trends. The Minneapolis Park and Recreation Board completed a report in 2013 that discusses water quality in the city's lakes. Water quality analysis indicates water quality improved in three of the five lakes comprising the Chain of Lakes (Calhoun, Harriet, and Cedar), while no trend exists for Lake of the Isles and Brownie lakes.

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Comment: Regarding the table on design infiltration rates - "The footnotes do not agree with the table. The table still shows 2 rates for B soils."

Response: The footnote has been changed to read "NOTE that this table has been updated from Version 2.X of the Minnesota Stormwater Manual. The higher infiltration rate for B soils was decreased from 0.6 inches per hour to 0.45 inches per hour and a value of 0.06 is used for D soils (instead of < 0.2 in/hr)"

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Comment: There's a wealth of information on your page. However information is missing on species of salt-tolerant forbs. A diversity of forbs are important components in prairie. I would truly appreciate an update if available.

Response: We added a section that provides some information on this topic and some links that may be useful.

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Comment: the two reference cited above this table" Hunt et al. (2012) and Hathaway et al., (2011)" are not listed in the reference list. Please include links to those references.

Response: The citations have been added to the reference list.

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Comment: I think the page would be better served by starting it this way, with language from farther down on the page: "Welcome to the Minnesota Stormwater Manual website. The Manual was created to be serve as a single source to guide stormwater managers through the maze of regulations, Best Management Practices (BMPs) designs, models/techniques and terminology that constitute good stormwater management. It is designed to be user-friendly..." etc. I think to get to the point about the purpose of the manual right away, and then talk about its features and design process, would improve the clarity of the page.

Response: Thanks. Please see our adjusted language.

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Comment: How about being able to click to the next page

Response: Resolved. Scroll down to a section called Links to other sections in CSW permit.

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Comment: Would be helpful to include link to download all in combined .pdf (link)

Response: Done. Look for links to pdf documents

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Comment: Couldn't find what I was looking for. PDF download link does not work.

Response: Regarding the pdf link issue, we are aware the pdf function does not always work in Mediawiki. We've found it to work about half the time. There are other options for saving or creating a document. First, you can save the page as a web page. Second, you can download (save) the page as a pdf from your browser. Go to this link or this link or other similar pages to determine how to do this. It is a relatively simple process. A final option is to copy and paste the page into Microsoft Word.

Regarding finding information in the website, the Search tool at the top of the page is effective if you know exactly what you are looking for. This page may be helpful.

Finally, if you have questions, concerns, or suggestions, please contact us. You may contact Mike Trojan at the MPCA or include your contact information in a comment that you submit. A comment box is found at the bottom of most pages.

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Comment: It would be nice to know how to reference the manual in a literature cited section. How should the manual be cited when information is being referenced in other reports?

Response: On the left toolbar, under Tools, you'll see a link (highlighted in blue) to Cite this page. Click on the link and you are taken to a page that provides a description of how to cite the page you want to reference.

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Comment: How about being able to click to the next page (referencing I. PERMIT COVERAGE AND LIMITATIONS)

Response: At the end of each section of the Construction Stormwater Permit, we added a section called Links to other sections in CSW permit. This should enhance moving between sections within the permit.

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Comment: when is an EAW required? (from page Construction Program FAQ).

Response: Minn. R 4410.4300 list what the Mandatory EAW Categories are. There is not one specific to CSW. Citizens may also petition for an EAW per Minn. R 4410.1100.

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Comment: (Regarding the MIDS calculator and permeable pavements), To meet the drawdown requirement, wouldn't a more applicable measure be the EFFECTIVE depth below the underdrain? This would take into account the media porosity.

Response: While it is correct that media affects the volume of water that infiltrates, it does not affect the calculation of drawdown time.

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Comment: The baffle sizing doesn't let you input data

Response: This table was not linked to other information in the manual. The link has now been established. We have also added information to the table header that allows users to access the sizing tool and other information on SHSAM.

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Comment: Why is there a potential for malicious code to be present in your documents (see example)?? trying to rewrite a city stormwater ordinance and I'm including links to each BMP, but when I clicked on the technical document link for "green roofs" I saw that message. The reason I am concerned more than I normally would be (as this can be considered a safe site) is because the contributor for the edits has the word "trojan" in the username, implying a virus.

Response: Mediawiki, by default, provides the following warning when it does not recognize certain standard formats - Warning: This file type may contain malicious code. By executing it, your system may be compromised. This appears to be the case for all Word and Excel documents. It may be true for other documents, such as .pdf, .jpg, etc. The author of this page has the Username MTrojan. The MPCA has control of access to the wiki and any files that have been uploaded into the wiki. We will add the following alert to appropriate places in the manual.

Caution: Mediawiki, by default, provides the following warning when someone downloads certain file formats - Warning: This file type may contain malicious code. By executing it, your system may be compromised. This appears to be the case for all Word and Excel documents. It may be true for other documents, such as .pdf, .jpg, etc. The MPCA has control of access to the wiki and any files that have been uploaded into the wiki. However, if you have concerns for downloading material from the wiki, email Mike Trojan at the MPCA.

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Comment: have the "following pollutants" on this page been added somewhere if not on this page?

Response: We had the idea of creating these pages because we felt they would be useful to people dealing with a specific pollutant. Unfortunately we got sidetracked with other work and never got back to completing these pages. It is still our intention to complete them, but it will be a while before we can get to them.

Note, however, that the one page that was created, Total Suspended Solids, was largely built using information that is already in the manual, albeit scattered among different pages. Some of the information on this page is applicable to all pollutants, such as the sections on antidegradation, pretreatment, and TMDLs. Until we are able to get back to completing these other pages, we recommend the following pages for sources of information.

• Information on pollutants in stormwater
• Pollution prevention practices for different pollutants and different sources
• Infiltration practices

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Comment: This page states that dry ponds do not receive credit for volume or credit removal, however these often behave like wet swales, which do receive credit in the MIDS calculator.

Response: Wet swales do not receive a volume credit in the MIDS calculator. Dry swales do receive volume credit.

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Comment: Dead link at BMP sediment quality, testing and disposal guidelines

Response: This page has been redirected to Managing stormwater sediments

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Comment: Why was the period of inundation definition changed from 3-6 inches above bottom of the facility to 1-2 inches above bottom of the facility. The SW manual had 3-6 inches in 2008, but now it is 1-2 inches. Why?

Response: The original manual had conflicting information on this point. The bioretention section used a value of 1 to 2 inches, while the infiltration section stated a value of 3 to 6 inches. It is unclear why there were two values. The manual has been updated and consistently discusses a value of 1 to 2 inches. Specifically, the manual states: "experience has demonstrated that, although the drawdown period is 48 hours, there is often some residual water pooled in the infiltration practice after 48 hours. This residual water may be associated with reduced head, water gathered in depressions within the practice, water trapped by vegetation, and so on. The drawdown period is therefore defined as the time from the high water level in the practice to 1 to 2 inches above the bottom of the facility. This criterion was established to provide the following: wet-dry cycling between rainfall events; unsuitable mosquito breeding habitat; suitable habitat for vegetation; aerobic conditions; and storage for back-to-back precipitation events. This time period has also been called the period of inundation." We believe that the value of 3 to 6 inches may indicate a system that is not properly draining.

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Comment: in centimeters (Design infiltration rates)

Response: Units of cm/hr have been added to this table

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Comment: I would like to know where this table came from. Can you please provide a reference? I am writing a paper and would like to be able to cite. Thanks.

Response: See page 57 at this link.

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Comment: I'm hoping this program [MIDS calculator] can be made more stable with the updates, as LGUs/agencies are beginning to require its use, regardless of it's significant limitations. I understand the calculator is nothing more than a spreadsheet "model" performing simple calculations; however, if it's going to feature a GUI, it would be nice if it weren't crashing and/or binding up excel regularly. Please don't put out another beta product.

Response: We understand the MIDS calculator is widely used. It is important that specific instances where the calculator is not performing properly be brought to our attention so they can be addressed. If you have questions or concerns about the calculator, please contact Mike Trojan at the MPCA.

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NOTE: We recently received a comment asking us to contact someone. Because of computer security issues it is imperative that if you want us to contact you, you must clearly define the purpose as well as your full contact information. You may also contact Mike Trojan at the MPCA.

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Comment: For filtration and biofiltration practices the storm water manual requires a 3 foot separation from the seasonal groundwater table and the bottom of the practice. The MPCA General NPDES Permit under section III.D.1.h. says an impermeable liner is allowed where it is less than a 3' separation. These two items don't jive. can you help clarify and provide direction. Thank you!

Response: When constructing an infiltration or filtration system to meet the requirements of the construction stormwater permit – the infiltration or filtration system must have a minimum of 3 feet of separation to the seasonally saturated soils or from bedrock. If you are proposing to construct an infiltration system and have less than three feet of separation to the seasonally saturated soils or bedrock – infiltration is prohibited in that location. If you are proposing to construct a filtration (or biofiltration) system and have less than three feet of separation to the seasonally saturated soils or bedrock -the filtration (or biofiltration) system must have an impermeable liner.

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Comment: We received several comments on the Annual report. below are the comments with responses.

1) It would be nice if we could move forward and backward through the pages while leaving questions blank.

Response: This is a limitation of the Annual Report on Snap Surveys—required fields cannot be bypassed before moving to the next page. A fillable word document was released with the Annual Report so that users may see all the questions contained in the Annual Report. It is available here: https://www.pca.state.mn.us/sites/default/files/wq-strm4-06a.doc.

2) Add an index page to move up and down on the annual report. You have to click through each page to get the the beginning of the report. Then you have to go through each page again to get to the end of the report.

Response: Doubtful that this option exists in Snap Surveys, but we will look into it for next year’s Annual Report.

3) It would be helpful to be able to “Save” and stay on the page.

Response: Doubtful that this option exists in Snap Surveys, but we will look into it for next year’s Annual Report. Please note, clicking the ‘Back’ or ‘Next’ buttons also saves the Annual Report. Clicking the ‘Next’ button will save even if you cannot advance to the next page because you have not filled out all of the required fields.

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Comment: The title says infiltration trench, but the sources are about basins.

Response: The original manual combined infiltration trench and infiltration basin into a single chapter. we are in the process of redoing this section of the manual and anticipate calling these "infiltration practices". This would include infiltration basins, trenches, dry wells, and underground infiltration practices. The work order to produce updates for this expires July 31 and we expect to have the changes incorporated into the manual by late summer.

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Comment: I had a question about the impact of using a bioinfiltration basin with an elevated underdrain. While using the MIDS calculator for a given basin with and without elevating the underdrain, I consistently see higher TP, TSS, and volume removals when NOT elevating the underdrain. Why is this? Since using an elevated underdrain "allows for more infiltration and evaporation compared to bioretention with underdrain at the bottom (2)" and "elevating underdrain (1) allows for more infiltration and evaporation compared to bioretention with underdrain at the bottom" I would expect higher removals when elevating the underdrain. Especially since TP and TSS from infiltrated water is considered to have 100% removal rates. Can anyone explain these results? Thanks! - Sorry for a duplicate comment, but I forgot to leave an email. If someone could please get back to me at dmoberly@srfconsulting.com that would be most appreciated. Thanks!

Response: This will be corrected in the next version of the MIDS calculator, which we hope to release in late summer (2016).

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Comment: There are no units listed in the notes #3 under the table.

Response: Resolved - units are Number per 100 milliliters.

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Comment: This comment pertains to this page. This is more of a reflection of the wording of the construction stormwater permit. Am I correct in my assumption that SWPPPs for construction sites under permit are only required to consider impairments for phosphorus, turbidity, dissolved oxygen, and biotic impairment for water bodies to which a site discharges within 1 aerial mile? I have a site that discharges to a water body which has a mercury in fish tissue impairment, for example, which does have TMDL. However, because it is not one of the four impairments listed in the permit, I assume the additional requirements identified for special or impaired waters in Appendix A of the permit do not apply to this site. More clarity here, on the construction stormwater page, or in a separate fact sheet would be a nice alternative to re-writing the permit.

Response: That is correct, there are no additional requirements for a mercury impairment. We will modify the language on this page to make this clearer.

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Comment: It would be nice if the TMDL pages that we upload would be viewable when we are printing the document to ensure that the right thing is being uploaded and submitted. Now we just have to trust that what we thought was being uploaded is being uploaded.

Response: There is no way for a respondent to view the attached uploads. It is a limitation of Snap Surveys. If you upload the wrong attachment and it is a required component, such as the TMDL Annual Report, the MPCA will contact you.

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Comment: more design information on non vegetated filters for pre treatment would be helpful. Hydro dynamic systems, fore bays etc. Thank you

Response: We currently have a Work Order to provide information on pretreatment. Another Work Order will start June 1 to provide design information for vegetated filter strips. See here.

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Comment: What can we do, as homeowners, to environmentally and responsibly reduce the mosquito population in our back yards of Minnesota? It seems that mosquitoes are on the rise again, after several years of limiting their proliferation in Minnesota lake areas, even in the Mpls./St. Paul area.

Response: With the Zika virus making the news recently, this issue has become more important to many people. The section in the manual addressing residential control of mosquitoes offers useful information. If implemented collectively throughout an entire neighborhood, the actions described in this section can suppress mosquito populations. Unfortunately, these actions cannot eliminate mosquitoes, since we not only live in the land of 10,000 lakes but in the land of hundreds of thousands of wetlands. As the comment points out, it is important to employ environmentally-safe methods. The use of chemicals to control mosquitoes in residential settings can be problematic since they may kill non-target organisms, such as bees. We have added some links to additional information in the section on residential control of mosquitoes. For more information, visit the Metropolitan Mosquito Control District website. _________________________________________________________________________________

Comment: Consider moving up the "other surface waters" requirement, it appears that buffers/redundant BMPs are required only for special waters, as 'other surface waters' are buried at the bottom.

Response: The page referred to in this comment is newly created and was migrated from our main construction stormwater page on MPCA's website. In the process of migrating information into this wiki we have noticed several needed updates. This is part of a process of building a construction stormwater section in the Manual, including migrating parts of the old Blue Book into this wiki. Once we have everything migrated we will go back and begin editing pages. thanks for the comment and we will consider it when we begin the review process.

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Comment: is it possible to download a pdf version of the document? I understand that this approach makes it easy to update, and it may even be easy to find a particular topic, but it is not easy to navigate and digest if one seeks to gather a broad understanding of the overall MN stormwater program. The "download a pdf" link on the bottom left only provides a pdf of the first three pages.

Response: The full manual is not available as a pdf document. The Create a Book function can be used to create a pdf document that includes multiple pages (we acknowledge this feature is a bit frustrating as the download doesn't always work smoothly, but it is functional). We are also considering developing a much more detailed Table of Contents as an alternative to the existing highly abbreviated TOC. We will also gladly create pages or pdf documents upon request provided the requests are manageable. We understand that some people prefer pdf documents and we went through an extensive process before deciding that the wiki platform offers tremendous advantages.

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Comment: Hi there, I was looking at your model comparisons found here [1] and was wondering how would you classify HEC-FIA model? Please kindly advise. Thank you.

Response: The User's Manual states: "The HEC-FIA program enables users to calculate flood damage and benefit accomplishment attributed to flood control projects. The analysis period can be the duration of a single flood event or a longer period of record. The program calculates agricultural damage, urban damage, and benefits for use after an event or annually and summarizes the results in reports. HEC-FIA can also look at dam failure events and evaluate the consequences to support risk assessments for dams." An article by Lehman and Needham indicate that further hydraulic modeling using other modeling tools is needed to enhance interpretation of the HEC-FIA model results. It therefore appears the HEC-FIA does not fit into the categories we use for classifying models.

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Comment: Bioretention soil "Mix D" appears to be the best option for a biofilter with underdrain to meet treatment goals, though the recommended mix ratios shown in the description and table are not in agreement. The "suggested mix ratio" in the description includes more compost, and topsoil, than shown in the table, and is very similar to "Mix A".

Response: The discussion of mix ratios includes a quantity of compost to add, while the table shows a quantity of organic matter desirable in the mix. This can lead to confusion, since compost will be about 50 percent solids and the solids will be about 50 percent organic carbon. Thus the values given for compost and organic matter are consistent. We have added some language to clarify this.

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Comment: Have more ideas (links to Temporary Erosion and Sediment Control page)

Response: We are in the process of migrating and updating information from Chapter 6 of the "Blue Book" into the Stormwater Manual. This process is on-going but should gradually improve the content on this topic.

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Comment: constructed pond (links to page on constructed ponds)

Response: We assume this comment is asking about performance curves for constructed ponds for the MIDS calculator. Performance curves were not developed for constructed ponds. The information built into the MIDS calculator for constructed ponds is found here.

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Comment: The performance of stormwater ponds does not differentiate between dry ponds and wet ponds. I believe that they have a different performance.

Response: This is correct - dry ponds do not receive credit for volume or pollutant removal. Several alert boxes have been included in appropriate places to convey this information.

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Comment: This is a pretty good story http://www.shoreviewmn.gov/departments/public-works/our-story/pervious-roadway#ad-image-1.

Response: This story has been noted in In the News and Case studies for permeable pavement

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Comment: The hyperlinks aren't working for me. One in the survey on MCM5 didn't work and the Click here on this page to visit the MPCA MS4 page didn't work.

Response: We occasionally get error messages in the wiki. Try reloading the link. If problems persist or if you have any questions, contact Mike Trojan (mike.trojan@state.mn.us, 651-757-2790) regarding the manual wiki or Cole Landgraf (cole.landgraf@state.mn.us, 651-757-2880) or Rachel Stangl (rachel.stangl@state.mn.us, 651-757-2879) regarding the survey.

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Comment: Re Rainfall Distribution The NRCS Type II Storm distribution was developed from TP-40 data and you should consider updating Stormwater Manual to use storm distributions based on Atlas 14 data. NRCS has updated rainfall distributions using Atlas 14 data. Minnesota NRCS has issued guidance that Type II storms no longer be used, and instead NRCS projects should use the MSE 3 storm that is based on Atlas 14 data. See their document at address below: http://www.nrcs.usda.gov/wps/PA_NRCSConsumption/download?cid=stelprdb1270686&ext=pdf MnDOT Drainage Manual is not current for design storm recommendation and should not be included as a reference until it has been updated. It has been superseded by Technical Memorandum 15-10-B-02. For urban areas, the recommendation is to use a rainfall distribution derived from Atlas 14 data, or use the NRCS MSE 3 distribution. See Tech Memo at: http://dotapp7.dot.state.mn.us/edms/download?docId=1651055

Response: The page containing this information (Introduction to stormwater modeling) has been updated and should address the above comments. Note this page is under review through January, 2016.

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Comment: The rainfall frequency/rainfall volume graphs for Cloquet, Fargo, Grand Forks...on this page were not developed from TP-40 and it may be confusing to put them here with the Statewide TP-40 figures. Issue Paper B states that the MSP graph is based on data from 1971 - 2000, and I assume the others were as well. These were developed by doing analysis of all rainfall events greater than 0.1 in. By contrast, TP-40 and Atlas 14 just analyze the extreme events. They use the highest precipitation amount for a particular duration for each calendar year.

Response: We removed the frequency-volume from the indicated page and created a new page summarizing frequency-volume relationships. We refer the reader to Issue Paper B, which includes a detailed discussion of the methodology and results, but provide some interpretation of volume estimates from the graphs since the graphs can be misleading.

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Comment: Could you please provide dimensions of #3 or #5 AAHSTO STONE.

Response: We added a footnote that includes links to the requested information. See the table referenced in the comment.

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Note: CADD images and .dwg files for CADD use are located on separate pages. The images are .pdf diagrams. We have created links on each of these pages to allow users to toggle back and forth between the two pages.

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Comment: Contact numbers would be helpful. Wouldn't they?

Response: Done

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Comment: It would be helpful to have the name of the BMP type along with a photo of it for this page.

Response: The photo in the table is intended as one example for the type of BMP being discussed. In the third column of the table, labeled BMP examples, we have indicated which specific BMP the photo refers to.

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Comment: The formula given for sizing bioretention practices not under the Stormwater General Permit (the A=VwqDm/(Ir(Hf+Dm)DDT) formula) seems to be incorrect. According to this formula, as you decrease the media/filter depth you also decrease the area needed for the practice which seems counterintuitive. Either the formula has an error of some kind or there needs to be more background included on the proper use of this formula (or maybe its derivation?).

Response: This equation, from the original Stormwater Manual, is inaccurate and has been modified

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Comment: Please provide a suggested citation/reference for the Minnesota Stormwater Manual. Thank you!

Response: In the toolbar on the left of each page, under Tools, look for a link called Cite this page. Click on that link and you will see citation styles for that page. Styles include APA, MLA, MHRA, Chicago, CBE/CSE, Bluebook, and BibTex. For example, if you were on the page Design criteria for permeable pavement and clicked on Cite this page, you would be directed to this page.

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Comment: This page [2] says that MIDS is an excel calculator, and that there is a folder called MIDSCalculatorGUIInstallerJuly8.zip. However at the link above there is only a folder called MIDSCalculatorGUIInstaller1.2.zip and it seems to be in ArcGIS? Anyway I can't find anything in excel, and I can't find a manual that is available without actually installing the set.exe. Is there documentation somewhere so I can figure out whether to install?

Response: Download just the Excel version of the calculator: File:MIDS calculator Excel only.xls. A link to this file has also been placed on the Calculator page.

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Comment: Give me some soil types (referring to [3]).

Response: We added a table showing infiltration rates for different soil textural classes and provided links to other sites where information for specific soil series can be found. See [4].

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Comment: Create a page for definitions. Try searching for the definition of impervious. One should be able to find definitions for regulatory terms ASAP. If you cannot find what is defined as impervious, your site needs a lot of work.

Response: Definitions can be found in the Glossary in the Stormwater Manual Table of Contents. We welcome suggestions about new terms that should be included in the Glossary, changes to existing definitions, or places in the Manual where we should create links to the Glossary.

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Comment: Is there any information on manipulating fish communities in stormwater ponds to optimize sw pond performance - for example using rotenone or other methods to reduce goldfish or black bullhead populations?

Comment:we are unaware of any information on this topic. We welcome information on this topic from any of our readers.

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Comment: make a PDF copy of the entire permit available for easy fownloadiong. Currently you have to copy and paste the entire thing into a document to save as PDF. Formatting gets all messed up doing that.

Response: There is an option to view the entire industrial permit as a single article. Click on this option at the top of the Industrial permit page. We have added an alert box to highlight this option.

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Comment: Please provide EMC for other constituents, especially TSS.

Response: We are in the process of gathering this information for a wide range of pollutants through an on-going contract. We anticipate having this information within the next couple months. The information will be updated on the current page, which currently only contains EMCs for phosphorus. The updated information will include a range of concentrations found in the literature in addition to median concentrations. In the interim, feel free to contact us as we have draft data, or consult this report (see Table 4.1).

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Comment: One someone has earned credit for tree trenches and tree boxes, what is their value? How can the credits be used?

Response: There is a section in the Manual that discusses stormwater credits. An excerpt from that page states

"Stormwater credit is a tool for local stormwater authorities who are interested in

• providing incentives to site developers to encourage the preservation of natural areas and the reduction of the volume of stormwater runoff being conveyed to a best management practice (BMP);
• complying with antidegradation requirements, including meeting the MIDS performance goal; or
• meeting or complying with water quality objectives, including Total Maximum Daily load (TMDL) Wasteload Allocations (WLAs)."

We are currently gathering additional information on stormwater credits for individual BMPs and hope to have this information in the Manual in the next few months.

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Comment:Underway: In failed tree nursery deceased trees in polyethylene grow bags are being removed. Need to know proper means of disposal of grow bags with contained tree root balls. Incineration or other?

Response: We forwarded this message to some tree experts and received the following response from Chad Giblin, a Research Fellow at the University of Minnesota.

"I spoke with Doug Lauer at UMN Landcare with regard to disposing or processing the dead nursery stock in poly grow bags. Doug works with Rumpca Co. who processes the wood waste and organic material at the UMN facility in Saint Paul. Doug thought that the polyethylene would probably not be an issue if the trees could be finely processed using a tub grinder, his bigger concern was field soil attached to the root balls. He suggested that if 90% or more of the soil was removed from the dead trees they could be probably processed using the tub grinder. He did advise me that Rumpca and other wood processing facilities and/or operators may have different policies depending on how things processed and that a final decision would require a more in-depth examination of the dead trees and the resulting product. In general, it sounds like there's options available but it would take working with a contractor who's willing to accept and process the dead nursery stock."

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Comment: I think the minimum drainage area for stormwater ponds should be revisited. A 25-acre minimum drainage area seems too small. Many ponds that treat runoff from highways have much smaller drainage areas.

Response: MPCA staff agree. Language has been changed to indicate a recommended drainage area of 10 to 25 acres, although smaller drainage areas, down to 5 acres, may be acceptable. See [5]

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Comment: The construction sequencing schedule does not indicate when the infiltration basin is installed. Should it not be installed after Site Stabilization?

Response: The following language has been added to the scheduling sequence for infiltration systems:

The Construction Stormwater General Permit requires that infiltration systems not be excavated to final grade until the contributing drainage area has been constructed and fully stabilized unless rigorous erosion prevention and sediment controls are provided (Part III.D.1.c). The permit also requires when an infiltration system is excavated to final grade (or within 3 feet of final grade), the Permittee(s) must employ rigorous erosion prevention and sediment controls (e.g. diversion berms) to keep sediment and runoff completely away from the infiltration area. The area must be staked off and marked so that heavy construction vehicles or equipment will not compact the soil in the proposed infiltration area. It is Recommended that infiltration systems be installed or put online after final stabilization of the site.

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Comment: there are two slightly different infiltration rate tables that could be combined into one.

Response: We created two separate tables, one focused on Hydrologic Soil Groups and the other on soil texture. This is intended to meets the needs of the soil scientist and engineer. We may revert back to a single table if this causes confusion.

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Comment: References to the required water quality volume on this page reference the 0.5" requirement from the previous permit cycle. This should be updated to reference the current 1" requirement.

Response: We attempted to "fix" the Water Quality Volume (V_wq) "issue" on the Water quality criteria page. We realize the section on Unified Sizing Criteria is dated and needs to be updated. We hope to update this page in the next few months.

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Comment: Would be more useful if the links to calculate stormwater volume reductions/credits actually brought you to a page with that information, rather than a page to another link that might have what you're looking for....

Comment: Are Credits for Better Site Design the only way to calculate volume reduction credits?

Response: The Minnesota Pollution Control Agency is currently working with a Contractor to develop information for volume and pollutant credits for most of the BMPs discussed in this manual. We anticipate this information will incorporated into the Manual by early summer, 2014. Draft versions of this information can be found for the following BMPs.

• Permeable pavement
• Tree boxes and tree trenches
• Green roofs

The Minnesota Pollution Control Agency is also working with a Contractor to develop information on using the Minimal Impact Design Standards calculator to calculate credits for volume, phosphorus and total suspended solids. Drafts of that information can be found for the following BMPs.

• Bioretention
• Green roofs

The Manual also contains information on models that can be used to calculate credits for volume and pollutants. Information on models is found on the following pages.

• Available stormwater models and selecting a model
• The Simple Method for estimating phosphorus export

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• Comment: The equation for Rtp in the example calculation is written incorrectly or it contradicts what is written above. Please revise the page to have consistent formulas.

• Response: The equation in the example was incorrect and has been corrected.

_________________________________________________________________________________

• Comment: It would be helpful if this page said WHAT the setback requirement refers to. What must be "set back" from the property line, building foundation, private well, etc.

• Response: resolved. See Minimum setback requirements.

_________________________________________________________________________________

• Comment: Need to add a Table of Contents item for Dry Swale and link to these documents: http://stormwater.pca.state.mn.us/images/e/e3/MIDS_Dry_Swale_Sections-SHEET_1.pdf

• Response: The original manual combined information on swales and sand filters into a single chapter. We eventually intend to create separate sections for these BMPs but have not done so yet. To address this comment we added links to to Swales and Sand filters in the Table of Contents. Clicking on these results in a redirect to the Filtration page. On the filtration page we added links to the drawings referenced in the comment. We realize this is a temporary solution.

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• Comment: Table of Contents item: infiltration basin and infiltration trench - does not contain any information on infiltration basins. These are one of the most common volume control practices in Minnesota and there is no guidance in the stormwater manual how to design and build these? Seems like a major disconnect.

• Response: The manual does contain information on infiltration basins but the titles were misleading. We anticipate eventually having separate sections for trenches and basins but have not gotten around to creating those separate pages. in the interim we combined the two BMPs but mislabeled the pages. We have resolved the labeling.

_____________________________________________________________________

• Comment: You need to expand this section (Design infiltration rates) to include the procedure for measuring infiltration rates. A search for "measured rates" yield the correction factor, but not the testing procedure.

• Response: This information is undergoing final review and will be incorporated into the Manual in the next month or two. We would be happy to provide this information now, as draft material, upon request (contact mike.trojan@state.mn.us).

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• Comment: This page should include additional types of porous pavements like durable versions of grass/gravel reinforced paving (BodPave85, Geoblock5150, Grasscrete) in addition to the unit pavers. These low-cost solutions have been utilized in low-med traffic sites very successfully and have incredible infiltration rates due to the high void space at surface for improved LID performance. However, I would not recommend the roll-out versions as these have not proved effective in trafficked areas, especially those with 4 seasons.

Response: We agree and are looking into incorporating this information into the Manual.

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• Comment: I would like to be able to click on a main heading and see the contents of the whole chapter at once instead of having to click on each topic area under the heading

Response: If we understand the comment correctly, this option exits for every topic that has multiple articles (pages). Look for a sentence on the main page of each major topic that states all the individual articles may be viewed as a single article. See green roofs as an example.

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• Comment: It is extremely hard to get back to where you were at. It would be nice to have a log in of some type or be able to flag currently visited locations.
• Comment: I am periodically reminded of the wiki, but have not made use of it (but should). Not sure how to popularize it as a resource. I wonder if there could be a button made that could stay in my web browser? or an icon that could be installed on a desktop?

Response: If using Internet Explorer, the simplest solution is to place the website onto the Favorites bar. This can be done by clicking on the Add to Favorites bar icon found on the Favorites bar toolbar (look for the yellow star with a green arrow pointing to the right). Clicking on this icon places the current webpage onto the toolbar, where it remains until you choose to remove it. Similar bookmarking features can be utilized in other browsers.

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• Comment: I am used to online manuals having navigation structure that allows the user to easily navigate to the next page or previous page easily. The current design seems to require the user to return to the TOC to both locate where you were and then choose the next page. Navigating through the entire manual page by page seems difficult. it would be helpful to have where one is in the TOC to be indicated by an html outline format on the left side and to have page navigation (back and next) on each page unless this could not be accomplished w/o programming at each page level which would be too laborious.

Response: There are some options for addressing this issue. First, at the top of each page is a breadcrumbs list of the three most recent pages that have been viewed within the wiki. second, a page can be opened in a new tab by right clicking on a link and selecting open in a new tab. This allos the user to have multiple pages open at the same time. We have also added a feature called Related pages. This is a section within all articles found within a specific topic. For example, green roofs is a topic that has 15 separate articles or pages associated with it. On each of those 15 pages is a section called Related pages that link to each of the 15 pages within the green roofs topic. This allows a user to stay within a specific topic without having to return to the Table of Contents. This feature has not been fully implemented yet, but visit one of the pages within green roofs to see an example.

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• Comment: "I often find it quicker and easier to search Google with the MPCA's site focused than to try to find what I need using the internal search, generally there are too many non-relevant results. For instance, your site returns 10,000+ results for ""no"" another 2000+ results for exposure and 199 results for the ""no exposure"" I searched for. 200 results is manageable,but 200 to manage mingled in over 12,000 results that were not necessary is not."

Response: To search for a specific text string, the text string should be placed in quotation marks. For the example above, type in "no exposure" to see only instances where the full term appears in an article. For more information on searching for topics, see Finding a topic.

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• Comment: The categories are confusing. I selected tables and the context that came up was not individual tables but pages that had tables. If one is already very familiar with the manual I can see how one could navigate easily to what one wanted, but I wonder if this design works as well for those just getting familiar with the manual. In that case, a highly linked and bookmarked pdf could serve equally well.

Response: We have resolved this issue (there is a noinclude command that allows us to categorize a page without the category being carried to another page). We also found, through the survey, that Categories are widely used for searching the Manual. we therefore intend on utilizing this feature to a greater extent.

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• Comment: How to use it - there is no information on how to do searches or if there is it wasn't very obvious

Response: Next to the Search box near the upper right part of each page we added Seacrh Help, which is a link to our help page on finding topics within the wiki. We also edited the on finding topics help page.

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• Comment: I had an incredibly difficult time finding figures and tables that were in the original manual. I would be surprised that any of them were simply deleted from the content. This should be improved. It was difficult to cross-reference between information locations in the old manual versus the wiki manual.

Response: We created a cross-reference between the old Manual and the wiki. There is an image at the top and right on the Main page and Table of Contents that takes you to the cross-reference.

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• Comment: Please define where to start measuring three feet from (bottom of basin that you can see, bottom soil media used...) A minimum of 3 feet of separation between the bottom of the bioretention practice and seasonally saturated soils.

Response: There must be 3 feet of undisturbed soil beneath the infiltration practice and the seasonal high water table (saturated soil) or top of the bedrock. We have clarified that in the Manual.

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• Comment: I did not have time read in depth about the BMPs, but I cannot stress enough that the best available information be included in here about protecting ground water, infiltration requirements in DWSMA's, vulnerable areas etc.

Response: This information will be updated in the coming year. See http://stormwater.pca.state.mn.us/index.php/Future_updates#Updates_to_information_on_infiltration_and_infiltration_constraints

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• Comment: Consider having external links open in a new tab if possible. This may be personal preference. -Add link to Ag BMP handbook, I feel some of the research and concepts can be applied to the audience using this manual: http://www.eorinc.com/documents/AG-BMPHandbookforMN_09_2012.pdf

Response: Other webpages can be opened in a new tab by right clicking on the link and selecting "Open in a new tab". The Ag BMP handbook link has been added.

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• Comment: Shouldn't ATLAS 14 be referenced here, rather than TP-40?

Response: This is part of on-going contract work and the Manual will be updated with respect to this issue.

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• Comment: Although the data is lacking, it would be nice to have a 'What we Know' summary of that data and where it came from. (Note: this comment pertains to the page on Stormwater research and education.)

Response:The information on the Stormwater research and education page is from the original Manual. We agree it is in need of updating and will attempt to update this when resources allow.

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• Comment: http://fyi.uwex.edu/shwec/2013/05/29/minnesota-bans-toxic-asphalt-sealcoats/ Please update to include information on the ban of coal tar sealcoat. Thank you!

Response: For now, we've added an alert box informing people that the ban is in effect January 1, 2014. We anticipate additional information being added in August.

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• Comment: Do US EPA WaterSense smart irrigation controllers fall into storm water quantity or quality BMPs for landscape management, and could it be used as a mitigation technique that qualifies for storm water credit in the City of Minneapolis? The controllers monitor plant, soil, and weather data to carefully control calculated daily irrigation schedules, eliminating saturated soils before rain events and minimizing the potential for overland flow generated on vegetated surfaces.

Response: We consulted with Lois Eberhart, City of Minneapolis Water Resources Adminstrator. Her response was:

"No, we would not consider any sort of irrigation management to be eligible for stormwater quality or stormwater quantity credits against the city’s Stormwater Utility Fee. Strictly speaking, irrigation water is non-stormwater and therefore is not intended to enter the MS4 stormwater system, under the city’s MS4 permit (although Minneapolis does not typically seek out, for purposes of enforcement, property owners/managers that are over-irrigating). (The irrigation control would of course save the user money on the water bill due to purchasing less potable water.)"

This is consistent with MPCA's view that irrigation water is non-stormwater and therefore credits should not be given. However, we believe the technology has value and would encourage its use in cases where irrigation is being used.

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• Comment:It is really frustrating when you have to open each section separately. For example, I should have the option to be able to click on the main heading of Stormwater Modeling, etc. and view all six sections at the same time instead of having to click on each of the six sections separately.

Response: We have created an option to view all the articles as a single document. We will likely do the same where appropriate in other places in the Table of Contents. Another option for the Manual user is to create a book (see left toolbar), which allows customization of an article.

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• Comment: Atlas 14 Volume 8 has been completed by NOAA. It is available on the web at http://hdsc.nws.noaa.gov/hdsc/pfds/ This information supercedes TP-40. There are references about using TP-40 throughout this document that should be updated.

Response: We understand the need to update the Manual on this topic and will be doing so in the near future.

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• Comment: If all discharge is sheet flow, it would not be a regulated discharge correct? (My understanding is that it would need to form a channel at the point it left the property or entered waters of the state to be regulated).

Response: As long as the Permittee has chosen their Benchmark Monitoring Location in accordance with the definition of the Industrial Stormwater Permit, how they collect the sample doesn't change that it's a regulated industrial stormwater discharge.

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• Comment: How about replacing these TP 40 maps with Atlas 14 which was has now been adopted by NOAA.

Response We have added a link to Atlas 14. The Stormwater Manual will be updated in the future.

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• Comment: The heading notes that there are two different rates for group B soils, but only one is displayed. The old manual used to have a 0.6 inches per hour rate for group B soils.

Response: As part of the MIDS project, a technical team evaluated the infiltration table and determined there should be one value for B soils (0.3 in/hr). The heading is corrected. This is an important change and we are discussing how to inform Manual users about these types of changes.

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• Comment: This (Stormwater pond/wetland O & M checklist) is a very comprehensive list; most of the criteria would be helpful. It should be reformatted so that it prints more clearly and in a smaller number of pages. A 4 page check list when you are inspecting a pond is too much.

Response: In the header for select checklists we have added an option to access an Excel version of the checklist

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• Comment:The requirement for two year monitoring seems extremely hard on these systems. Monitoring requirements are not stipulated, pre-installation monitoring is required to characterize the runoff etc. No one in their right mind will do this on every site installation. Take into account that field monitoring devices themselves have been shown to be extremely inaccurate. With the move to MID design standards all tools are valid and for urban redevelopment underground systems may be the best option for the site. I strongly recommend replacing the monitoring requirement with a more stringent design process, say sizing on 50 um lab test using a treatment flow rate developed from the design storm event. Then require washout verification to say below 50 mg/l so that retention of sediment is also considered. A lot of work has been done at SAFL on this.

Response:This will not be required under the new CSW permit and it has therefore been removed.

—————————————————————————————————————————————————————————————————————

• Comment: How about replacing these TP 40 maps with Atlas 14 which was has now been adopted by NOAA.

Response We have added a link to Atlas 14. The Stormwater Manual will be updated in the future.

—————————————————————————————————————————————————————————————————————

• Comment: The heading notes that there are two different rates for group B soils, but only one is displayed. The old manual used to have a 0.6 inches per hour rate for group B soils.

Response: As part of the MIDS project, a technical team evaluated the infiltration table and determined there should be one value for B soils (0.3 in/hr). The heading is corrected. This is an important change and we are discussing how to inform Manual users about these types of changes.

—————————————————————————————————————————————————————————————————————

• Comment: This (Stormwater pond/wetland O & M checklist) is a very comprehensive list; most of the criteria would be helpful. It should be reformatted so that it prints more clearly and in a smaller number of pages. A 4 page check list when you are inspecting a pond is too much.

Response: In the header for select checklists we have added an option to access an Excel version of the checklist

—————————————————————————————————————————————————————————————————————

• Comment:The requirement for two year monitoring seems extremely hard on these systems. Monitoring requirements are not stipulated, pre-installation monitoring is required to characterize the runoff etc. No one in their right mind will do this on every site installation. Take into account that field monitoring devices themselves have been shown to be extremely inaccurate. With the move to MID design standards all tools are valid and for urban redevelopment underground systems may be the best option for the site. I strongly recommend replacing the monitoring requirement with a more stringent design process, say sizing on 50 um lab test using a treatment flow rate developed from the design storm event. Then require washout verification to say below 50 mg/l so that retention of sediment is also considered. A lot of work has been done at SAFL on this.

Response:This will not be required under the new CSW permit and it has therefore been removed.

—————————————————————————————————————————————————————————————————————

• Comment: Do US EPA WaterSense smart irrigation controllers fall into storm water quantity or quality BMPs for landscape management, and could it be used as a mitigation technique that qualifies for storm water credit in the City of Minneapolis? The controllers monitor plant, soil, and weather data to carefully control calculated daily irrigation schedules, eliminating saturated soils before rain events and minimizing the potential for overland flow generated on vegetated surfaces.

Response: We consulted with Lois Eberhart, City of Minneapolis Water Resources Adminstrator. Her response was:

"No, we would not consider any sort of irrigation management to be eligible for stormwater quality or stormwater quantity credits against the city’s Stormwater Utility Fee. Strictly speaking, irrigation water is non-stormwater and therefore is not intended to enter the MS4 stormwater system, under the city’s MS4 permit (although Minneapolis does not typically seek out, for purposes of enforcement, property owners/managers that are over-irrigating). (The irrigation control would of course save the user money on the water bill due to purchasing less potable water.)"

This is consistent with MPCA's view that irrigation water is non-stormwater and therefore credits should not be given. However, we believe the technology has value and would encourage its use in cases where irrigation is being used.

—————————————————————————————————————————————————————————————————————

• Comment:It is really frustrating when you have to open each section separately. For example, I should have the option to be able to click on the main heading of Stormwater Modeling, etc. and view all six sections at the same time instead of having to click on each of the six sections separately.

Response: We have created an option to view all the articles as a single document. We will likely do the same where appropriate in other places in the Table of Contents. Another option for the Manual user is to create a book (see left toolbar), which allows customization of an article.

—————————————————————————————————————————————————————————————————————

• Comment: Atlas 14 Volume 8 has been completed by NOAA. It is available on the web at http://hdsc.nws.noaa.gov/hdsc/pfds/ This information supercedes TP-40. There are references about using TP-40 throughout this document that should be updated.

Response: We understand the need to update the Manual on this topic and will be doing so in the near future.

—————————————————————————————————————————————————————————————————————

• Comment: If all discharge is sheet flow, it would not be a regulated discharge correct? (My understanding is that it would need to form a channel at the point it left the property or entered waters of the state to be regulated).

Response: As long as the Permittee has chosen their Benchmark Monitoring Location in accordance with the definition of the Industrial Stormwater Permit, how they collect the sample doesn't change that it's a regulated industrial stormwater discharge.

—————————————————————————————————————————————————————————————————————

• Comment: How about replacing these TP 40 maps with Atlas 14 which was has now been adopted by NOAA.

Response We have added a link to Atlas 14. The Stormwater Manual will be updated in the future.

—————————————————————————————————————————————————————————————————————

• Comment: The heading notes that there are two different rates for group B soils, but only one is displayed. The old manual used to have a 0.6 inches per hour rate for group B soils.

Response: As part of the MIDS project, a technical team evaluated the infiltration table and determined there should be one value for B soils (0.3 in/hr). The heading is corrected. This is an important change and we are discussing how to inform Manual users about these types of changes.

—————————————————————————————————————————————————————————————————————

• Comment: This (Stormwater pond/wetland O & M checklist) is a very comprehensive list; most of the criteria would be helpful. It should be reformatted so that it prints more clearly and in a smaller number of pages. A 4 page check list when you are inspecting a pond is too much.

Response: In the header for select checklists we have added an option to access an Excel version of the checklist

—————————————————————————————————————————————————————————————————————

• Comment:The requirement for two year monitoring seems extremely hard on these systems. Monitoring requirements are not stipulated, pre-installation monitoring is required to characterize the runoff etc. No one in their right mind will do this on every site installation. Take into account that field monitoring devices themselves have been shown to be extremely inaccurate. With the move to MID design standards all tools are valid and for urban redevelopment underground systems may be the best option for the site. I strongly recommend replacing the monitoring requirement with a more stringent design process, say sizing on 50 um lab test using a treatment flow rate developed from the design storm event. Then require washout verification to say below 50 mg/l so that retention of sediment is also considered. A lot of work has been done at SAFL on this.

Response:This will not be required under the new CSW permit and it has therefore been removed.

—————————————————————————————————————————————————————————————————————

• Comment: How about replacing these TP 40 maps with Atlas 14 which was has now been adopted by NOAA.

Response We have added a link to Atlas 14. The Stormwater Manual will be updated in the future.

—————————————————————————————————————————————————————————————————————

• Comment: The heading notes that there are two different rates for group B soils, but only one is displayed. The old manual used to have a 0.6 inches per hour rate for group B soils.

Response: As part of the MIDS project, a technical team evaluated the infiltration table and determined there should be one value for B soils (0.3 in/hr). The heading is corrected. This is an important change and we are discussing how to inform Manual users about these types of changes.

—————————————————————————————————————————————————————————————————————

• Comment: This (Stormwater pond/wetland O & M checklist) is a very comprehensive list; most of the criteria would be helpful. It should be reformatted so that it prints more clearly and in a smaller number of pages. A 4 page check list when you are inspecting a pond is too much.

Response: In the header for select checklists we have added an option to access an Excel version of the checklist

—————————————————————————————————————————————————————————————————————

• Comment:The requirement for two year monitoring seems extremely hard on these systems. Monitoring requirements are not stipulated, pre-installation monitoring is required to characterize the runoff etc. No one in their right mind will do this on every site installation. Take into account that field monitoring devices themselves have been shown to be extremely inaccurate. With the move to MID design standards all tools are valid and for urban redevelopment underground systems may be the best option for the site. I strongly recommend replacing the monitoring requirement with a more stringent design process, say sizing on 50 um lab test using a treatment flow rate developed from the design storm event. Then require washout verification to say below 50 mg/l so that retention of sediment is also considered. A lot of work has been done at SAFL on this.

Response:This will not be required under the new CSW permit and it has therefore been removed.