A unified framework is presented for addressing stormwater sizing criteria in the context of the 2003 MPCA Construction General Permit (CGP) and local stormwater management requirements, if chosen by the local community. The unified approach addresses five different sizing criteria, as shown below:

  • Recharge
  • Water quality
  • Channel protection
  • Over bank flooding
  • Extreme storms

Once the basic stormwater sizing criteria are defined for regular waters, this article then describes how they can be adapted to provide greater protection for special and other sensitive waters of the state. The goal of the unified framework is to develop a consistent approach for sizing stormwater practices that can:

  • Perform effectively: Manage enough runoff volume to actually solve the stormwater problem it is intended to address.
  • Perform efficiently: Manage just enough runoff volume to address the problem but not over-control it. More storage is not always better, and can greatly increase construction costs.
  • Be simple to administer: Be understandable, relatively easy to calculate with current hydrologic models, and workable over a range of development conditions and intensities. In addition, criteria should be clear and straightforward to avoid needless disputes between design engineers and plan reviewers when they are applied to development sites, while also eliminating any competitive disadvantages that are created when uniform regulations do not exist.
  • Promote better site design: Be structured in a manner so that property owners have real incentives to reduce storage volumes (and costs) by applying better site design techniques to receive stormwater credits.
  • Be flexible to respond to special site and receiving water conditions: Be expanded to adequately protect unique receiving waters, and to be reduced or eliminated in certain development situations where they are inappropriate or infeasible.

A unified framework for sizing stormwater practices provides greater consistency and integration among the many city, county, watershed organization, regional and statewide stormwater requirements and ordinances adopted over the years. It also establishes a common framework to address all stormwater problems caused by development sites over the entire spectrum of rainfall events. The unified approach still provides communities with flexibility to develop stormwater criteria adapted for local conditions, within overall context of the 2003 MPCA CGP. The Manual provides more detailed guidance on the appropriate design assumptions for accepted hydrologic models used in design.

Overview of the Unified Stormwater Sizing Framework

This section reviews the key stormwater sizing concepts and terminology used in the chapter and presents an overview of the unified framework for managing stormwater in Minnesota. The terminology and abbreviations associated with various stormwater sizing criteria can be confusing at times, as the state and local reviewing authorities often define or interpret them in a slightly different manner.

A review of key stormwater sizing terminology.
Link to this table

Term Definition
Better Site Design (BSD) Better site design refers to the application of non-structural practices at new development sites to reduce site impervious cover, conserve natural areas, and use pervious areas to more effectively treat stormwater runoff. Also know as low impact development.
Channel Protection (VcpVolume) Refers to the recommended runoff storage volume needed to control post-development bankfull flow velocities so they do not increase erosion in downstream channels. typically, detention and/or extended detention of intermediate sized storms (0.5 to 2.0 inches of rainfall) are used for this purpose. The channel protection volume is denoted as Vcp.
Design Storm An engineering term for a single rainfall event with a defined intensity, duration and statistical recurrence interval commonly ranging from 0.5 to 100 years. These single event storms are based on long-term rainfall data and are used in hydrologic models to predict the peak discharges and runoff volumes associated with each type of storm. Unless otherwise indicated, all design storms discussed in the Manual has a 24-hour duration and a Type II distribution.
Detention Time Various definitions for detention time exist in hydraulic manuals and in help screens on computer models. For this Manual, a simple method of computing detention time is recommended. Detention time is equal to the length of time starting at basin full (for a specific design storm) and ending either when the basin is dry (filtration or infiltration) or the basin has attained normal water level (stormwater ponds or constructed wetlands).
Extreme Storm Volume (Vp100 The greatest runoff storage volume is used to the peak discharges of infrequent but very large storm events to pre-development levels. The 100-year design storm, which has a statistical recurrence interval of occurring once in one hundred years, is used by most communities. Extreme floods can cause catastrophic damagae and even loss of life. The storage volume needed to store and detain them is denoted as Vp100. Note that stormes more "extreme" than the 100-year event do occur in Minnesota. The extreme term is used relative to other volume terms for perspective.
Hydrologic Soil Group (HSG) HSG is an USDA-NRCS designation given to different soil types to reflect their relative surface permeability and infiltrative capability. Group A soils have low runoff potential and high infiltration rates. Group B soils have moderate infiltration rates. Group C soils have low infiltration rates. Group D soils have high runoff potential with very low infiltration rates and consist chiefly of clay soils (TR-55, 1986).
Other Sensitive Receiving Waters In addition to special waters defined in the CGP, there are other receiving waters that merit additional management attention because of their sensitivity, as defined by various state and local entities. Recommended stormwater criteria exist for
  • Lakes (most sensitive and sensitive)
  • Wetlands (susceptible and non-susceptible)
  • Drinking water source areas (ground and surface water)
  • Impaired waters (computable and non-computable.
Overbank Flood Volume (Vp10) Refers to the runoff storage volume needed to prevent an increased frequency of floods that spill out of the channel and onto the floodplain where they may cause damage to the conveyance systems, property and infrastructure. Overbank flooding is normally controlled by detention of post-development 10-year storm so that pre-development peak discharge rates (as defined by state or local agencies) are maintained, and is denoted by Vp10 (assuming the local review authority requires control of the 10-year storm event).
Permanent Pool Volume (Vpp) The CGP requires that all wet sedimentation basins contain a permananet pool with a volume of 1,800 cubic feet of storage for each acre that drains to the basin. This equates to 1/2 inch of runoff per acre. The permanent pool must reach a minimum depth of three feet, stay below 10 feet and be configured to minimize scour and resuspension of solids.
Pre-Development Conditions The term pre-development conditions can be interpreted in many different ways. The MPCA uses land cover conditions immediately preceding the current development project as the CGP pre-development condition, whereas many other local and watershed managers use a more natural definition, such as meadow or woodlands in good shape (stated in a manner to help in CN selection). Obviously the CGP version will usually result in a smaller net runoff increase for most land that has anything but a natural cover. It is recommended that the CGP definition be used for its intended purpose as part of state permit issuance, but that the more natural pre-development condition be used if a stormwater manager wants to assume a more conservative condition.
Recharge Volume (Vre) Refers to the recommended volume of runoff which should be spread over pervious areas and otherwise infiltrated into the soil to promote groundwater recharge. The recharge volume is denoted as Vre and is normally included as part of the water quality volume.
Special Waters A list of eight categories of receiving waters are specifically designated as "special waters" in the CGP. Additional BMPs and enhanced runoff controls are required for discharges to the following special waters:
  • Wilderness areas
  • Mississippi River (Lake Itasca through Morrison County)
  • Scenic or recreation river segments
  • lake Superior
  • Lake trout lakes
  • Trout lakes
  • Scientific and natural areas
  • Trout streams
Total Storage Volume (Vts) For ponds built under the requirements of the CGP, the total storage volume required is the sum of the permanent pool volume (Vpp) plus the water quality volume (Vwq).
Water Quality Volume (Vwq) Generic term for the storage volume used to capture, treat and remove pollutants in stormwater runoff. It is normally expressed as a volume (watershed-inches or acre-feet) and is denoted by Vwq. For ponds and wetlands, the MPCA CGP defines it as the volume of live storage above the permanent pool (above the dead storage) used for water quality. For non-pond BMPs, MPCA defines the water quality volume in the same manner as the general definition above.

example of a typical rainfall frequency spectrum for Minnesota (MSP airport) which shows the percent of rainfall events that are equal to or less than an indicated rainfall depth. Similar graphs for other locations are found at this link
An example of a typical rainfall frequency spectrum for Minnesota (MSP airport) which shows the percent of rainfall events that are equal to or less than an indicated rainfall depth.

In the course of a year, anywhere from 35 to 50 precipitation events fall on Minnesota. Most events are quite small but a few can be several inches in depth. A rainfall frequency spectrum describes the average frequency of the depth of precipitation events (adjusted for snowfall) that occur during a normal year. Rainfall frequency maps have been developed for Minnesota for several return frequencies. The majority of storms are relatively small but a sharp upward inflection point occurs at about one-inch of rainfall.

The unified sizing approach seeks to manage the entire frequency of rainfall events that are anticipated at development sites. The runoff frequency spectrum is divided into five management zones, based on their relative frequency, as follows:

  • Recharge: targets rainfall events that create little or no runoff but produce much of the annual ground water recharge at the site.
  • Water Quality: targets rainfall events that deliver the majority of the stormwater pollutants at the site.
  • Channel Protection: targets storms that generate bankful and sub-bankful floods in the stream that cause channel enlargement.
  • Overbank Floods: targets large and infrequent storm events that spill over to floodplain and cause damage to infrastructure.
  • Extreme Storms: controls the largest, most infrequent and most catastrophic floods that threaten property and public safety (e.g., commonly known as the 100-year storm.

The goal of stormwater management is to provide effective control over each management zone in order to produce post-development hydrology that most closely resembles state or locally defined pre-development conditions at the development site. Each criterion defines a unique storage volume that should be managed at the site. They are best understood visually as a layer cake that has progressively larger layers from bottom to top, with recharge volume being the narrowest layer at the bottom and extreme storm control comprising the thickest layer at the top. Figure 10.2 shows how the five storage volumes interact in a stormwater BMP.

The unified approach proposes to standardize the basic approach to stormwater design for regular waters of the state, while also defining certain site conditions or development scenarios where individual stormwater sizing criteria may be relaxed or waived. The unified framework also clearly indicates when sizing criteria need to be enhanced to provide a higher degree of water resource protection for special or other sensitive waters. Table 10.2 profiles the recommended or required sizingcriteria for each of the five stormwater management zones for both regular and special waters. The next five sections of the chapter describe each of the standard stormwater sizing criteria, including how they are calculated and the conditions where they may be relaxed or waived. This chapter is a general guide, and designers should always check with their local review authority and the MPCA to determine the appropriate sizing criteria used in their community.

Recharge and Infiltration Criterion (Vre )

The intent of this sizing criterion is to maintain ground water recharge rates at development sites to preserve existing water table elevations and support natural flows in streams and wetlands. Under natural conditions, the amount of recharge that occurs at a site is a function of slope, soil type, vegetative cover, precipitation and evapotranspiration. Sites with natural ground cover, such as forest and meadow, typically exhibit higher recharge rates, less runoff and greater transpiration losses than sites dominated by impervious cover. Since development increases impervious cover, a net decrease in recharge rates is inevitable.

Recharge and/or infiltration criteria offer additional benefits, as they promote more on-site infiltration/filtration of stormwater runoff, and enable communities to offer stormwater credits that reduce the water quality storage volume. Recharge credits provide real incentives to apply better site design techniques at development sites that can reduce the size and cost of stormwater BMPs needed at some sites. To maximize recharge, designers should explore how to use pervious areas for infiltration early in the site layout process.

The recharge volume is considered to be part of the total water quality volume provided at a site and is not an additional CGP requirement (e.g., Vre is contained within Vwq). Recharge can be achieved either by a structural BMP (e.g., infiltration, bioretention, and filter), better site design techniques, or a combination of both.

There are currently no statewide recharge sizing requirements for regular waters in the state of Minnesota, although previous stormwater guidance has strongly promoted recharge and infiltration (MPCA, 2000 and MC, 2001). Also, infiltration can be used as one way to meet the state CGP requirement for permanent stormwater management. Recharge and infiltration are strongly encouraged through better site design and stormwater credits. There are three readily available options for how a community or stormwater manager could determine the amount of runoff to include as the Rev factor. The three methods for determining recharge volumes are included in the boxes on the following page.

Since there are no current required state infiltration requirements, any of the three approaches that follow could be used. Stormwater managers are cautioned to review local conditions and select a method according to what can logically be expected, keeping in mind that the goal is to match pre-development volumes of infiltration as closely as possible in most cases. However, if the potential for using site development to enhance or increase local infiltration exists, for example through an infiltration basin, managers might choose another method to increase infiltration expectations. The Manual Sub-Committee (MSC) noted infiltration as an area for needed discussion during the next CGP update.

Modifications to Recharge Criteria

Infiltration and recharge of polluted stormwater runoff is not always desirable or even possible at some development sites. Therefore, most communities qualify their recharge and/or infiltration requirements to reflect special site conditions, protect ground water quality, and avoid common nuisance issues. For example, the local review authority may require:

  • Some form of special pre-treatment of stormwater runoff prior to infiltration for some land cover types and pollution source areas (e.g. parking lots).
  • Recharge be restricted or prohibited at specific industrial, commercial and transport-related operations designated as potential stormwater hotspots (PSH). Chapter 13 defines the range and type of development sites designated as potential stormwater hotspots within Minnesota.
  • Recharge be prohibited or otherwise restricted within the vicinity of ground water aquifers, wellhead protection areas, individual wells, structures and basins.
  • Recharge be discouraged within certain geological zones such as active karst and bedrock, and adjacent to steep or unstable slopes.
  • Recharge be reduced or waived for minor redevelopment projects that have previously compacted soil structures.

Water Quality Criteria

Computing water quality volume

Treatment of stormwater runoff is needed to meet in-stream water quality standards and protect aquatic life and water resources. Extensive monitoring has revealed high concentrations of sediments, nutrients, bacteria, metals, oxygen-demanding substances, hydrocarbons and other pollutants in untreated stormwater runoff (Pitt et al., 2004) and demonstrated their impact on stream and lake quality (CWP, 1999 and CWP, 2003). A range of BMPs can provide a high degree of removal for stormwater pollutants (ASCE, 2004 and Winer, 2001). The 2000 state manual (MPCA, 2000) established a performance goal that BMPs provide a minimum degree of pollutant removal for a defined fraction of stormwater runoff events, which has been operationally defined as 90% sediment removal. A 50% total phosphorus removal can be assured to accompany this removal. Parts of the state CGP reference the 80% Total Suspended Solids (TSS) standard.

The state has defined how to compute the water quality volume for projects that must meet the requirements in the 2003 Construction General Permit. The current MPCA water quality volume criteria is referred to as the “hybrid rule” because it actually encompasses four different rules, depending on the type of BMP used and whether the development drains to regular or special waters.

Designers in the state have traditionally relied on ponds for water quality treatment, so the first water quality rule applies to ponds that drain to regular waters. As illustrated in Figure 10.3, the total storage volume (Vts) has two additive components: dead (or permanent) storage of a half-inch per acre (also stated as 1800 cubic feet per acre) and live (or temporary) water quality storage of one-half inch times the fraction of new impervious cover (IC) for the site. Mathematically, the acre feet of storage needed for basic pond sizing in regular waters is computed as:

Rule 1:

Figure 10.4 shows the relationship of the two water quality storage components (dead and live) in a pond sized according to Rule 1. In addition, ponds are also required to have a live storage release rate no greater than 5.66 cubic feet per second (cfs) per surface acre of pond area (as measured from the top of the live water quality storage bounce above the permanent pool). For example, if the maximum surface area of the pond created by the Vwq is three acres, the allowable maximum discharge rate from the pond would be 16.98 cfs (3 5.66). It is important to note that this is a geometrical requirement to achieve an overflow rate that ensures that a five-micron (5µ) sediment particle can be effectively settled within the pond, based on prior work by Pitt (1989). Designers are encouraged to ensure that at least 12 hours of extended detention are provided for the live storage in the pond BMP (using an acceptably sized and protected outlet at the orifice) to ensure an acceptable level of pollutant removal.

The second water quality sizing rule pertains to ponds located within the special waters of the State (Chapter 2) as defined in the CGP. These ponds must have a greater live storage component (Vwq) -- one-inch times the fraction of new IC for the site. The required acre-feet of total storage volume (Vts) needed for ponds draining to special waters is computed as:

Rule 2:

The live storage in ponds draining to special waters must also conform to the maximum 5.66 cfs required release rate and should allow for a recommended minimum 12 hour extended detention time.

A third water quality sizing rule contained in the 2003 GCP applies to non-pond BMPs such as infiltration, bioretention and filtering practices. These practices are not explicitly required to have permanent pool storage, although some dead sediment storage is recommended for pre-treatment before discharging into the practice. The basic sizing equation for non-pond BMPs located in regular waters is shown below:

Rule 3:

The minimum pre-treatment volume recommended (not required in CGP) to protect non-pond BMPs from clogging and increase their longevity is 0.10 watershed inches, as shown in Figure 10.5.

Non-pond BMPs located in special waters must have additional live storage ( Vwq), as shown below.

Rule 4:

These non-pond BMPs should have a minimum water quality storage volume of 0.2 watershed inches reserved for pre-treatment, regardless of site impervious cover, as shown in Figure 10.5.

The four water quality sizing rules are compared against each other in Figure 10.6. An even higher degree of phosphorus removal may be needed to protect the most sensitive lakes and susceptible wetlands. Recommended guidance on sizing BMPs for these special receiving waters is provided in Sections IX Lakes and XII Wetlands, respectively.

Modifications to Water Quality Criteria

Most communities do not allow many exemptions to their basic water quality sizing criteria, although they may choose to reduce or exempt certain redevelopment and infill projects. Some guidance on handling water quality sizing in redevelopment situations is provided in Section 14, Stormwater Sizing for Redevelopment Projects.

Water quality sizing criteria can be modified upward or downward. The first occurs when stormwater credits are offered to reduce water quality sizing when acceptable better site design techniques are applied on the site (Chapter 11). The second occurs when sizing criteria are increased to provide an enhanced level of treatment to protect special waters, such as a nutrient sensitive lake or when local criteria exceed the state minimum. Guidance on these potential modifications is provided later in this chapter.

Channel Protection Criteria (Vcp)


The purpose of channel protection criteria is to prevent habitat degradation and erosion in urban streams caused by an increased frequency of bankful and sub-bankful stormwater flows. Channel protection criteria seek to minimize downstream channel enlargement and incision that is a common consequence of urbanization (Schueler and Brown, 2004). As fields and forests are converted to impervious surfaces, the volume and frequency of runoff is increased significantly. Research indicates that urbanization causes channels to expand two- to ten-times their original size to adjust to the increased volume and frequency of runoff caused by impervious cover, as well as the increased conveyance efficiency of curbs, gutters and storm drains (CWP, 2003 and 2004).

Urban stream channel enlargement significantly impacts stream habitat, water quality and public infrastructure. Bank erosion sharply increases total annual sediment yield and nutrient loads as nutrient-rich floodplain soils are eroded and transported downstream. In addition, channel erosion degrades and simplifies stream habitat structure, which diminishes aquatic biodiversity. Lastly, channel erosion can cause severe damage to bridge, culvert and sewer infrastructure and loss of private property.

Historically, two-year peak discharge control has been the most widely applied local criteria to control channel erosion in Minnesota, and many communities continue to use it today. More specifically, two-year peak control seeks to keep the post-development peak discharge rate for the 2-year, 24-hour design storm at pre-development rates. The reasoning behind this criterion is that the bankful discharge for most streams has a recurrence interval of between 1 and 2 years, with approximately 1.5 years as the most prevalent (Leopold, 1964 and 1994), and maintaining this discharge rate should act to prevent downstream erosion.

Recent research, however, indicates that two-year peak discharge control does not protect channels from downstream erosion and may actually contribute to erosion since banks are exposed to a longer duration of erosive bankful and sub-bankful events (MacRae, 1993 and 1996, McCuen and Moglen, 1988; see also Appendix O). Consequently, two-year peak discharge control may have some value for overbank flood control, but is not effective as a channel protection criterion, since it may actually reach peak flow that is too high and extend the duration of erosive velocities in the stream and increase downstream channel erosion. Communities may wish to drop two-year peak discharge control if they also need 10-year peak discharge control for overbank flooding when they adopt or revise stormwater ordinances as part of NPDES Phase II MS4 permits.

There are currently no state requirements to provide channel protection for regular waters, although a few local reviewing authorities have recently adopted channel protection criteria. Communities are encouraged to adopt new channel protection criteria (and eliminate two-year peak discharge control requirements) when they revise or adopt local stormwater ordinances to comply with municipal NPDES permits.

The state CGP references an “enhanced runoff control” criterion wherein the post-development runoff rate and volume need to be maintained for both the one-year 24-hour and two-year 24-hour storm. This criterion could have some channel protection applicability. The criterion only applies to a very restricted subset of special waters designated in the CGP permit, including:

  • Wilderness Areas
  • Trout Lakes
  • Lake Trout Lakes
  • Scientific and Natural Areas

The options suggested in the CGP for controlling temperature could also help reduce channel volume by infiltrating or otherwise controlling discharges to trout streams.

The recommended channel protection criteria described next should satisfy the CGP channel protection criterion. Channel protection is also highly recommended for trout streams and certain discharge situations to lakes and wetlands.

The recommended channel protection criterion is to provide 24 hours of extended detention for the runoff generated from the 1-year 24-hour design storm. This runoff volume generated is stored and gradually released over a 24-hour period so that critical erosive velocities in downstream channels are not exceeded over the entire storm hydrograph. As a very rough rule of thumb, the storage capacity needed to provide channel protection is about 60-65% of the one-year storm runoff volume. The rainfall depth for the one-year, 24-hour storm varies across the State, but can be inferred from intensity-duration-frequency [IDF] curves. The one-year, 24-hour rainfalls range between 1.8 and 2.5 inches across the State of Minnesota (Appendix B). Maximum extended detention time should be limited to 12 hours in trout streams to minimize stream warming, provided erosive velocities can be avoided.

Channel protection has recently been adopted by the States of Maryland, New York, Vermont, and Georgia, and is relatively easy to compute at most development sites using existing hydrologic design models. The recommended criterion reduces the magnitude and duration of highly erosive stream channel velocities which should help to reduce downstream channel erosion.

For those wishing more in-depth analysis of channel protection flows, the following option could be used. The State of Washington (2004) has adopted an extremely stringent channel protection criterion that requires the duration of post-development peak stormwater discharges match pre-development durations for the entire range of storms between 50% of the one-year storm and the 50-year event. Designers must use a continuous hydrologic simulation model (HSPF, e.g.) to demonstrate compliance. As of 2004, hydrologic models such as TR-55 or P-8 that employ single event design storms are no longer allowed in Washington for design purposes. The goal of the peak duration matching criteria is to exactly replicate the pre-development frequency of peak discharge rates for all storm events that should provide a high level of channel protection. This approach was considered by the Manual Sub-Committee, but recommended only as an option because of the high cost of implementation. Additional discussion of the effect of peak flows on channel erosion occurs in Appendix O.

Finally, a special study was undertaken in the Version 2.0 revisions to look at the potential for cumulative peak flows released from detention BMPs to occur in an urban watershed. The parameters of the study focused on a 450 acre developing watershed within an urban area and the placement of detention BMPs in five sub-watersheds scattered within the larger basin. The results showed that when the design specifics contained in the Minnesota Stormwater Manual are used, there will not be an elevated cumulative flow that results. Further analysis showed that for this condition to result in the test watershed, releases from BMPs would have to occur before the passage of the overall watershed peak flow, a situation that would not occur under the Manual design. Some caution should be exercised when considering the likelihood of cumulative flows for large watersheds, where there might be a primary peak flow from near-source areas, followed by a secondary peak as the rest of the watershed contributes. In larger watershed situations, similar modeling for near, medium and far sub-watershed inflows should be undertaken.

Channel Protection Methods

For more information about Channel Protection Methods, see Appendix M and Appendix O.

Modifications to Channel Protection Criteria

There are some practical limitations in applying channel protection criteria to small development sites because orifice diameters or weir sizes become extremely small and are prone to clogging. As a result, it is recommended that localities waive the channel protection requirements at small sites that have less than three acres of impervious cover. Channel protection need not be applied at sites that have a discharge condition that will not likely cause a local channel erosion problem, such as sites that directly discharge to:

  • Fourth order or higher streams and rivers (data on stream order is available from DNR or the USGS from the National Hydrography Dataset at http://nhd.usgs.gov.)
  • Lakes and reservoirs where the development area is less than 5% of the watershed area upstream of the development site.

Overbank Flood Protection Criteria (Vp10)

The goal of this criterion is to prevent flood damage to conveyance systems and infrastructure and reduce minor flooding caused by overbank floods. Overbank floods are defined as floods which exceed the bankful capacity of the channel and spill over to the floodplain where they can damage property and structures. The key management objective is to protect downstream structures (houses, businesses, culverts, bridge abutments, etc.) from increased flows and velocities from upstream development.

Most local reviewing authorities establish an overbank design storm that is matched with the same design storm used to design open channels, culverts, bridges, and storm drain systems. Most localities in Minnesota require that post-development peak discharge rates from the 10-year and/or 25-year, 24-hour design storm event be controlled to pre-development rates.

In general, the storage volume needed to manage the 25-year return design storm is much greater than the 10-year design storm. Modeling has shown that control of the 10-year storm coupled with control of the 100-year storm effectively attenuates storm frequencies between these two events (e.g., the 25-year storm). Even without attenuation of the 100-year event, 10-year control provides a significant control for the 25-year storm (approximately 70 to 80%).

Consequently, most communities across the state have adopted the 10-year design storm control for overbank protection, since it requires less storage volume and provides some de-facto control for the 25-year storm. The choice of what design storm(s) to target for overbank control is always a local decision, and normally depends on whether the 10- or 25-year design storm has historically or currently been used as the basis for the design of conveyance systems and culverts.

Extreme Flood Control Criteria (Vp100)

The goal of extreme flood criteria is to maintain the boundaries of the pre-development 100-year floodplain, reduce risk to life and property from infrequent but very large floods and protect the physical integrity of a stormwater BMPs and downstream infrastructure.

The accepted design storm to manage extreme storms in most communities in Minnesota is the 100-year, 24-hour event. Designers are required to control the post-development 100-year, 24‑hour peak discharge rate to locally defined pre-development levels. Communities should carefully reassess extreme flood criteria since it requires the largest storage volume and greatest cost of any stormwater sizing criteria.

Communities may elect to waive 100-year peak discharge criteria in certain situations. The most common situation is when they have a buffer or floodplain ordinance that effectively excludes development from ultimate 100-year floodplain. Designers may also need to demonstrate that no downstream structures exist within the 100-year floodplain and that bridges and other infrastructure can safely pass the storm using an acceptable downstream analysis. This approach accomplishes the goal of extreme flood control by protecting the downstream ultimate 100-year floodplain rather than providing expensive upstream storage.

Hydrologists have often noted that extreme flood criteria may not always provide full downstream control from the out-of-bank events, due to differences in timing of individual peak discharges in the downstream portion of the watershed. Depending on the shape and land use of a watershed, it is possible that upstream peak discharge may arrive at the same time a downstream structure is releasing its peak discharge, thus increasing the total discharge. As a result of this “coincident peaks” problem, it is often necessary to evaluate conditions downstream from a site to ensure that effective out-of-bank control is being provided. Hydrologic and hydraulic models that can be used for analysis of downstream effects are provided in Appendix B.

Debo and Resse (1992) proposed the concept of the “10% rule” as the point to which a downstream analysis should extend. This is operationally defined as the downstream point where the development site represents 10% of the total contributing drainage area of a watershed. They contend that the hydrologic effects of flooding stabilize and remain constant further downstream. A typical downstream analysis will need a hydrologic investigation of the site area draining to a proposed detention facility and of the contributory watershed to the location of the 10% rule for the 10- and 100-year storms. As a minimum, the analysis should include the hydrologic and hydraulic effects of all culverts and/or obstructions within the downstream channel and assess whether an increase in water surface elevations will impact existing buildings or other structures. The analysis should compute flow rates and velocities for pre-developed conditions and proposed conditions both with and without the detention facility.

While the 10% rule is useful in establishing a limit for assessment, stormwater program managers still have some basic issues that need to be addressed. For example:

  • Is a downstream analysis always required?
  • Should a downstream analysis be required on a case-by-case basis?
  • Is a certain site size threshold required to trigger the analysis?
  • What should the analysis include (culverts, channel erosion, flooding, etc.)?
  • What data requirements are necessary for the analysis and what methods should be employed?

The following recommendations are provided to help answer these questions.

  • A downstream analysis is probably warranted for projects over 50 acres that posses more than 25% impervious cover or when deemed appropriate by the reviewing authority when existing conditions are already causing a problem (e.g., known drainage or flooding conditions documented in a regional plan or existing channel erosion is evident).
  • A typical downstream analysis will require a hydrologic investigation of the site area draining to a proposed detention facility and of the contributory watershed to the location of the 10% rule for the 10- and 100-year storms. A hydraulic analysis of the stream channel below the facility to the location of the 10% rule will also be necessary (a HEC-RAS water surface profile analysis, e.g.). Depending on the magnitude of the impact and the specific conditions of the analysis, additional information and data may be necessary such as collecting field run topography, establishing building elevations and culvert sizes or investigating specific drainage concerns or complaints.
  • If the hydrologic investigation shows that flow rates and velocities (for Vp10 and Vp100) with the proposed detention facility increase by less than 5% from the pre-developed condition, and no existing structures are impacted, then no additional analysis is necessary. If the flow rates and velocities increase by more than 5%, then the designer should either redesign the detention structure, evaluate the effects of no detention structure, or propose corrective actions to the impacted downstream areas. Additional investigations may be required by the approving authority on a case-by-case basis depending on the magnitude of the project, the sensitivity of the receiving water resource, or other issues such as past drainage or flooding complaints. Special caution should be employed where the analysis shows that no detention structure is required. Stormwater designers should be able to demonstrate that runoff will not cause downstream flooding within the stream reach to the location defined by the 10% rule.

A local community may elect to waive the Vp100 criteria when a development project:

  • Directly discharges to a large reservoir or lake,
  • Directly discharges to a 4th order or larger stream or river
  • Is smaller than five acres in area
  • Is a redevelopment or infill project
  • Is within an area where a regional flood model indicates that 100-year control is not needed at a particular site.

Some Minnesota communities base their extreme storm design on a rain-on-snow scenario, rather than a specific design storm approach. Under this scenario, communities may define the effective 100-year event as having as much as 7.2 inches of equivalent rainfall that needs to be controlled to pre-development levels. There is little basis for this approach in Minnesota based on rainfall records or experience, and it clearly results in costly over-control (Chapter 9), although some communities chose to continue its use for conservative design in land-locked basins.

Adapting Stormwater Criteria for Receiving Waters

This section begins by reviewing the diversity of “special” watershed and receiving water resource designations in Minnesota, and then presents recommendations for adapting the standard stormwater sizing criteria described earlier in the chapter to better protect these important receiving waters.

The State of Minnesota has many different kinds of mandated special watershed and water resource designations that directly influence how stormwater is managed at a site (Chapter 2 and Appendix F). When these are combined with the even more numerous water resource designations created by localities and watershed organizations (see for example, WCWC, 2003 and EOR, 2000), there is a great deal of potential for overlap and confusion. Indeed, in many regions of the state there can be more area designated and managed for specially protected waters than for regular ones. The remainder of this chapter presents a condensed framework for managing stormwater when these sensitive waters need additional protection. Please note that this section focuses on additional stormwater management practices that can be used to supplement protection of sensitive receiving waters. Some of these waters currently have limited protections under state or local programs, while others do not. The material in this section is offered as guidance when further stormwater management is deemed necessary or desirable by state or local decision makers.

In addition to the eight specific “special waters” mentioned in the state CGP and listed in Table 10.1, there are several specifically protected waters that may warrant supplemental protection relative to stormwater. These include calcareous fens, all DNR designated Public Waters, many kinds of wetlands, shoreland/floodplain areas, areas with active karst, drinking water source areas, impaired waters and the Mississippi River Critical Area. Appendix A and Appendix F present a directory of on-line maps and lists to help designers and reviewers determine if their development project is located in a special water of the state.

The many different local and state receiving waters noted above that could be addressed by supplemental stormwater management fall into five basic groups:

  • Lakes
  • Trout Resources
  • Drinking Water Source Areas
  • Wetlands
  • Impaired Waters

Some of these groups may be further divided into management subcategories, as shown in the right column of Table 10.3. These subcategories will each be discussed in the remainder of this chapter.

Table 10.4 compares the main stormwater management criteria and considerations for all five groups in Table 10.3 The text following the table discusses the details of application for each of the receiving water classes.


Research has shown that development can increase eutrophication, bacteria and turbidity levels in lakes. According to a national survey of 3,700 urban lakes, more than 80% were found to be either eutrophic or hyper-eutrophic (U.S. EPA, 1980). Urban and urbanizing lakes receive higher phosphorus loads than non-urban lakes because urban watersheds, particularly those under construction, produce higher unit area phosphorus loads from stormwater runoff, compared to other watersheds (Caraco and Brown, 2001). A summary of the impacts of eutrophication on lakes is provided in Table 10.5.

From a stormwater management standpoint, lakes can be divided into three management categories based on their current trophic status and sensitivity to additional phosphorus loads. Most-Sensitive Lakes are normally defined as being oligotrophic, whereas Sensitive Lakes are considered to be mesotrophic or slightly eutrophic. A third category of all other lakes would include eutrophic and highly eutrophic lakes that are not generally categorized as sensitive because of their relatively poor quality. These lakes should be treated under regular stormwater programs. The lake designation is normally made by the local or regional lake management authority, although the state may do so for certain special waters such as trout lakes or lake trout lakes (Table 10.1). Often, the lake management designation has already been made by the local, watershed, regional or state agencies, or perhaps even by a university or local educational institution. If no designation has been made, the local review authority should consult available data on water clarity, phosphorus content and algal abundance (using Chlorophyll-a as a surrogate measure). If none of these data exist, the local review authority may want to collect lake monitoring data to make a designation. Future phosphorus loadings should also be considered when making a stormwater management designation for a lake.

As a general rule, all surface water drinking supplies, such as water supply reservoirs and river intakes should be managed using the same stormwater sizing criteria as Sensitive Lakes, given the importance of controlling bacteria, toxic pollutants and turbidity that can threaten drinking water quality. The ensuing section presents stormwater guidance for most-sensitive and sensitive lakes, including enhanced sizing criteria and recommendations for BMP design and selection.

Most-Sensitive Lakes

The following adjustments to the basic sizing criteria are recommended for lakes designated as most-sensitive:


Highly recommended

Water Quality

Highly recommend a site-based phosphorus load reduction if the lake in question is a state-designated “special water” under the CGP or falls under a similar local regulatory designation; also highly recommended for non-designated lakes with documented oligotrophic quality.

Under this criterion, designers would demonstrate that no increase in total phosphorus (TP) loads will occur at a site from pre-development to post-development conditions using a site-based TP load calculation. The designer could use the Simple Method (Schueler, 1987) or equivalent to compute pre-development and post-development TP loads at the site and determine the pollutant removal requirement (in pounds; Appendix L). The designer would then propose a series of BMPs that maximize the amount of phosphorus removal at the site to reach the desired condition. This criterion provides a major incentive to design for maximum phosphorus removal which is essential for managing most-sensitive lakes. Site-based phosphorus reductions have been adopted by several communities in Minnesota, which vary between no change in phosphorus load to as much as a 25% reduction from pre-development conditions.

The step-wise computational approach is described in detail in Appendix L and is outlined below:

  1. Calculate site imperviousness before and after development
  2. Calculate the pre-development phosphorus load
  3. Calculate the expected post-development pollutant load
  4. Calculate the pollutant removal requirement
  5. Identify feasible BMPs and calculate load removed (using standard BMP removal efficiencies, Table 10.6)
  6. Select off-site mitigation option, if needed.

If a designer cannot meet the total removal requirement, they could be allowed to pay an offset fee that is equivalent to the cost of removing an equivalent amount of phosphorus elsewhere in the watershed.

Channel Protection

Highly recommended if the site drains to a direct tributary stream to a lake.

BMP Selection

The following BMP design and selection guidance is recommended for lakes designated as most-sensitive. The foremost concern is to choose BMPs with a proven ability to reliably remove high levels of phosphorus. Table 10.6 summarizes the total and soluble phosphorus removal capabilities of common BMPs. Soluble phosphorus is of particular interest since it is most readily available for algal uptake. Therefore, any BMP employed to protect most-sensitive lakes protection should have a moderate to high capability to remove total and soluble phosphorus.

Infiltration practices tend to have the highest phosphorus removal, but are not always be feasible due to soil constraints or lack of the three-foot separation distance between the bottom of the infiltration device and the seasonally saturated water table. Pond systems are generally a reliable removal option for both soluble and total phosphorus. Filters are fairly effective at removing total phosphorus, but exhibit little or no capability to remove soluble phosphorus. This can be explained by the fact that most sand filters have no biological or chemical processes to bind soluble phosphorus. The addition of organic matter or binding agents to sand filters may show promise in boosting removal, but early monitoring of experimental filters have yet to demonstrate this result conclusively (Schueler, 2000a).

Wetlands have a highly variable capability to remove both soluble and particulate forms of phosphorus. The variability can be explained in part by internal phosphorus cycling within the wetland, sediment release, and vegetative dieback during the non-growing season (Schueler, 1992). Factors such as soil pH, oxygen conditions, nutrient saturation and presence of Ca, Mg or Fe in the soil can also make a big difference in whether phosphorus is removed or released. The best design variation for phosphorus removal in the stormwater wetland group is the pond-wetland system (e.g., wetland with a relatively large portion of its storage devoted to a deep pool -- Chapter 12).

Sensitive Lakes

The following recommends that stormwater ponds and constructed wetlands discharging to sensitive lakes be sized larger to increase the retention time for additional phosphorus removal. These designs are more conservative than the MPCA sizing rule and could be considered by local authorities interested in greater protection for sensitive lakes. Recommended adjustments to the standard stormwater sizing criteria for Sensitive Lakes are:


Highly recommended.

Water Quality

Adjusted pond sizing. The MPCA water quality sizing Rule 2 should be applied to size stormwater ponds (e.g., ponds located within special waters). If the site has more than 30% impervious cover, the Walker Rule presents a size option that should result in similar TP load reductions in ponds. Users interested in the details on the development of this relationship are referred to Issue Paper D (Figure 13) via Appendix J. The Walker Rule was developed in the upper Midwest to maximize retention time needed within a pond to promote maximum algal uptake of phosphorus and subsequent settling between storm events. The Walker Rule seeks to attain an average pond retention time of about two weeks. Based on the distribution of storm events in the upper Midwest, Walker (1987) recommended all storage via a permanent pool storage volume equivalent to 2.5 inches multiplied by the site runoff coefficient. Based on the Minnesota rainfall frequency spectrum, the Walker Rule would capture about 98% of all runoff producing events each year, resulting in very little bypass of untreated runoff. In addition, runoff from many storm events is retained within the pond over several storm cycles to help improve phosphorus uptake. The pond designer should allocate total storage to the permanent pool under the Walker Rule. The total storage in acre-feet needed under the Walker Sizing Rule is provided using the following equation:

Walker Rule

The MPCA water quality sizing Rule 4 should be applied if the designer is using a BMP other than a pond (e.g., non-BMPs draining to special waters), keeping in mind that a minimum water quality storage volume of 0.2 watershed inches is recommended for pre-treatment, regardless of site impervious cover.

Channel Protection

Limited application. Channel protection is recommended if a development site drains to a tributary stream to a lake. Channel protection is not needed if the site discharges directly to the lake.

BMP Selection

The following guidance on BMP design and selection is offered for Sensitive Lakes:

  • Designers should only apply BMPs that have a total phosphorus removal rate exceeding 50%. Based on Table 10.7, four kinds of BMPS are not recommended in sensitive lakes: media filters, wet vegetated swales, micropool extended detention ponds, and extended detention wetlands. If these BMPS are used, they need to be combined with more effective BMPs in a treatment train. By contrast, infiltration, wet ponds, and bioretention have high phosphorus removal rates, and are strongly encouraged in Sensitive Lakes.
  • In addition, designers and plan reviewers should evaluate every BMP to look for ways to maximize phosphorus removal. For example, the use of multiple treatment pathways is encouraged (e.g., directing runoff to a filtering or infiltration BMP, and then routing it a wet pond). Additional tips on maximizing phosphorus reduction in BMP design are provided in Table 10.8.
  • Also, as a general rule, no BMPs should be located inside the shoreline buffer, as defined by the local reviewing authority.

Trout Streams

Trout populations are threatened by stream habitat degradation, stream warming, possible chloride toxicity, and other impacts associated with upland development. Trout are very sensitive to increases in water temperature. The optimal temperature range for adult trout is from about 57°F to 65°F. Generally, adult trout can survive warmer temperatures if cool water refuge is present in the form of ground water upwelling or springs. Juvenile trout, fry and eggs are much more susceptible to warm water temperatures and are not able to tolerate temperatures much above 68°F (Emmons & Olivier Resources, 2000). Stream warming also harms trout by reducing dissolved oxygen available for fish and aquatic life. Increased temperatures can also increase the metabolic rates of aquatic organisms and increase their sensitivity to other pollutants, parasites, and diseases (SSL SWCD, 2001).

The reduction in streamside forest cover removes much of the mechanisms that keep a stream cool. The heating of impervious surfaces by solar radiation also warms precipitation that runs over them and potentially into a stream. A series of monitoring studies have documented the stream warming effect in urban trout streams (Roa-Espinosa et al. 2003; SSL SWCD, 2001; Johnson, 1995; Galli, 1990).

Sedimentation is also a major concern for trout. Construction runoff, channel erosion and road sand all increase sediment loads which can impair streambed habitat in trout streams. Excess sediment can affect the productivity of a trout stream in several ways. Sediment can impede trout respiration by clogging gill plates. In addition, sediment deposition can destroy spawning habitat and harm the benthic organisms upon which the trout feed.

Road salt may also significantly impact trout habitat. Chloride is one of the main components of road salt, and is extremely soluble in water. As a result, there is virtually no way to remove chloride once it gets into either surface or ground water. Chloride levels are the highest in late winter as initial melting occurs from snow containing significant amounts of road salt and stream flows are lowest. The chloride from the salt can be toxic in trout streams during some meltwater events (Chapter 9).

The following adjustments to the basic sizing criteria are recommended to protect trout streams.


Highly recommend infiltration as part of stormwater control. It is highly recommended that all excess runoff volume above that produced from the pre-development 2- year, 24-hour storm event should be infiltrated for designated trout streams, where soils conditions permit. The state CGP contains this method as one option to meet mandated temperature control for designated trout streams.

Water Quality

Discourage use of ponds/wetlands. Use MPCA water quality sizing rule 4 for non-pond BMPs volume determination for special waters, and infiltrate and/or filter this volume at the site regardless of soil conditions (e.g., bioretention, dry swales, infiltration, and better site design practices). Discharge from ponds or wetlands with standing water to trout streams is discouraged. If they are used, they should be sized according to MPCA Sizing Rule 2, incorporate temperature controls, and have an extended detention time no longer than 12 hours.

Channel Protection

Highly recommended. Given the importance of trout habitat, it is highly recommended that channel protection criteria be applied to all trout streams. If soils do not permit infiltration of the channel protection volume, then designers should provide 12 hour extended detention of 1-year, 24-hour runoff volume in a thermally acceptable pond option. Note that CGP allows up to 24 hours, but 12 is recommended in the Manual. Release of the 1-yr, 24-hour volume in 12 hours should be compared with the ½ 2-yr pre-development peak matching method described previously to determine which approach would result in less heating of the stored water.

BMP Selection

There are quite a few do’s and don’ts when it comes to BMP design for trout streams. Designers should look for ways to incorporate the following design features into their BMPs:

  • Consider using forested wetland design (see Capiella 2005b).
  • Maximize use of better site design techniques
  • Use infiltration and bioretention to the maximum extent possible
  • Construct BMPs “off-line”
  • Shade pilot and outflow channels and micropools by planting trees and shrubs
  • Plant trees to the maximum extent possible in the stormwater practices and buffers
  • Manage buffers to maximize forest cover and shading in riparian areas
  • Pre-treat roadway runoff to reduce sediment and road sand discharges to streams
  • Develop and test roadway spill management plans

Designers should ensure that each BMP does not have:

  • A large, unshaded permanent pool or shallow wetland
  • Extensive and unshaded pilot and outflow channels within the BMP
  • An extended detention time longer than 12 hours
  • Extensive exposed riprap or concrete channel
  • An on-line or in-stream location
  • A location within the forested buffer
  • Infiltration practices that are undersized or lack pre-treatment.

Drinking Water Source Areas

Ground Water

This group includes any ground water recharge areas that supply water used for drinking water supply. The management goal is to maintain ground water recharge while preventing the possibility of ground water contamination. Ground water is a critical water resource, as many residents depend on ground water for their drinking water, and the health of many aquatic systems depends on steady recharge to maintain surface water bodies throughout the year. For example, during periods of dry weather, ground water sustains flows in streams and helps to maintain the hydrology of wetlands. Because development creates impervious surfaces that prevent natural recharge, a net decrease in ground water recharge rates can be expected in urban watersheds. Thus, during prolonged periods of dry weather, stream flow sharply diminishes. In smaller headwater streams, the decline in stream flow can cause a perennial stream to become seasonally dry.

Urban land uses and activities can also degrade ground water quality if stormwater runoff is directed into the soil without adequate treatment. Certain land uses and activities are known to produce higher loads of metals and toxic chemicals and are designated as potential stormwater hotspots or “PSHs” (see Chapter 13 for definitions and further discussion). Soluble pollutants, such as chloride, nitrate, copper, dissolved solids and some hydrocarbons can migrate into ground water and potentially contaminate wells. Stormwater runoff should never be infiltrated into the soil from sites designated as a PSH (Table 10.9).

Stormwater hotspots commonly occur as commercial, industrial, institutional, municipal, or transportation-related operations that produce higher levels of stormwater pollutants, and/ or present a higher potential risk for spills, leaks or illicit discharges (Table 10. 9). Runoff from these operations may contain soluble pollutants which cannot be effectively removed by current BMPs and can contaminate ground water quality.

Typical sources of nutrients, metals, hydrocarbons, toxins and other pollutants that can be generated from PSH are summarized in Table 10.10. It should be noted that not all of these operations or activities will actually generate pollution at an individual stormwater hotspot. In fact, many industrial operations are highly regulated under state and federal programs. There are, however, many small or unregulated facilities (such as gas stations or auto salvage yards) that are of concern because of the potential for release of toxic material to stormwater.

The management goal in ground water drinking water source areas is to prevent possible ground water contamination by preventing infiltration of untreated hotspot runoff. At the same time, recharge of unpolluted stormwater is needed to maintain flow in streams and wells during dry weather. As such, structural BMPs alone should not be relied upon as a sole stormwater management strategy at a PSH. A stormwater pollution prevention plan for a PSH should also incorporate a combination of:

  • Good housekeeping
  • Preventive maintenance
  • Spill prevention and clean-up
  • Employee training
  • Inspections
  • Record-keeping
  • Chemical use restrictions

More information on how to prepare an effective pollution prevention plan for a site can be found in Chapter 12 and Chapter 13.

The following adjustments to the standard stormwater sizing criteria are recommended to protect the quality of ground water drinking water source areas.

Water Quality

Enhanced sizing and pre-treatment. MPCA water quality sizing Rules 2 or 4 should be applied to development sites within ground water drinking water source areas, depending on whether a pond or non-pond BMP option is being considered. A minimum of 0.2 watershed-inches of effective pre-treatment is recommended for non-pond BMPs to remove pollutants prior to any infiltration or soil filtration.

11.1.2 Recharge

Encouraged in limited situations. Infiltration is encouraged at residential subdivisions to increase ground water recharge through rooftop disconnections and other better site techniques. Commercial and institutional rooftops can also be disconnected as long as they are not a potential stormwater hotspot. No infiltration or recharge of runoff from potential stormwater hotspot operations should be allowed to reduce the risk of ground water contamination. Caution on the source of infiltrating water should be exercised in all cases.

11.1.3 BMP Selection

The following guidance on BMP design and selection is offered to protect ground water drinking water source areas.

  • In general, infiltration of clean runoff from residential and non-residential rooftops is encouraged with acceptable pre-treatment
  • Stormwater ponds, wetlands, bioretention, and filters are effective surface treatment
  • No infiltration from PSHs, especially those with potentially high chloride levels and/or vulnerable ground water resources
  • Minimum setbacks from wells, septic systems, sinkholes and wellhead protection zones in conformance with state and local regulations (contact Minnesota Department of Health) and plans
  • Avoid pooling or infiltrating stormwater in active karst areas (Chapter 13)

Additional BMP design criteria for ground water protection are presented in Table 10.11.

Surface Water

There is a large portion of Minnesota residents served by drinking water obtained from a surface water source. The supplies for the St. Cloud, Minneapolis and St. Paul metropolitan areas are obtained mostly from the Mississippi River; St. Paul’s supply is supplemented by both small stream flow and ground water. Several other cities throughout the state are also supplied by smaller rivers such as the Minnesota/Blue Earth, Red Lake and Red Rivers, by Lake Superior or by large abandoned quarries in the Iron Range. In each of the river source areas, protection of the surface water source reaches far beyond the local border to the entire watershed feeding the supply intake. For the quarries, inflow occurs primarily from ground water sources that must be protected as noted in the previous section. Lake Superior itself requires attention, as do the tributary streams that feed it.

Each of the surface water sources is preparing or has prepared a source water protection plan in which they identify potential pollutants of interest and the likely source of those pollutants. They also must put together a plan to protect the source of water. This plan, as is the case for the Mississippi River communities, can stretch far upstream (or up-gradient for ground water) to areas not under the control of the served communities. This severely limits the direct control that the supplied communities have over pollution generating activities. Fortunately, a willingness to help protect these drinking water source areas has led to multi-community cooperative protection efforts.

The pollutants mentioned in the previous ground water section certainly all apply to surface water sources. In addition, surface water suppliers have to be concerned about such things as sediment, phosphorus, nuclear waste (Mississippi River suppliers), any cargo hauled through the watersheds on rail or roads, or on the water in barges, PSHs, fire-fighting runoff and a myriad of other potential surface water contaminants. All of the precautions mentioned in the previous section for ground water source areas should also be applied to surface waters that provide drinking water.

The management goal in surface water drinking water source areas is to prevent possible source contamination by preventing any potential contaminant from reaching either the stream or river providing the water or any ground water inflow that will eventually feed a surface water source. Pollution prevention and emergency response become primary BMP approaches for source waters. Information on how to prepare an effective pollution prevention plan for a site can be found in Chapter 12 and Chapter 13. The list of focal BMPs remains similar to the ground water list noted previously with the addition of good watershed management to control pollutants associated with nonpoint sources.

The following adjustments to the standard stormwater sizing criteria are recommended to protect the quality of surface water drinking water source areas.

Water Quality

Enhanced sizing and pre-treatment. MPCA water quality sizing Rules 2 or 4 should be applied to development sites within surface water drinking water source areas that are determined in a source water protection plan to be critical to maintaining the quality of the source water. A minimum of 0.2 watershed-inches of effective pre-treatment is recommended for non-pond BMPs to remove pollutants prior to any infiltration or soil filtration.


Encouraged for watersheds, with caution for ground waters feeding a surface water source. Infiltration is encouraged within watersheds upstream of drinking water intakes from surface water. Protective measures consistent with the previous ground water supply section are encouraged for ground waters feeding surface water sources.

BMP Selection

Supplemental BMPs should follow those suggested for Sensitive Lakes. The following guidance on BMP design and selection is offered to protect surface water source areas:

  • A pollution prevention plan is essential for the entire area draining to the surface water intake;
  • Stormwater ponds, wetlands, bioretention, and filters are effective surface treatment;
  • No infiltration or direct runoff in the vicinity of the intake from PSHs, especially those with potentially high chloride levels and/or vulnerable ground water resources; and
  • An emergency response plan should be prepared for spill response in areas critical to supply protection.

Additional BMP design criteria for ground water protection are presented in Table 10.12.


For a long time, wetlands were viewed as wastelands that were better drained or filled. It is estimated Minnesota has lost nearly 42 percent of its original wetland acreage (MN SWAG, 1997). Wetlands are now recognized as performing many important watershed functions and services, and their direct disturbance is closely regulated. Chapter 5 of this Manual reviews state, local and federal aspects of wetland regulation and management.

Naturally occurring quantities of runoff with seasonal fluctuations are essential for the maintenance of a wetland, and moderate amounts of nutrients and sediment in the runoff can increase a wetland’s productivity. However, excessive stormwater runoff has the potential to alter the hydrology, topography, and the vegetative composition of a wetland (U.S. EPA, 1993). For example, an increased frequency and duration of inundation can degrade native wetland plant communities or deprive them of their water supply.

Stormwater inputs can also cause changes in water or soil chemistry that can degrade wetlands. This is a particular concern for wetlands with a narrow pH range such as acidic sphagnum bogs and alkaline calcareous fens (MN SWAG, 1997). Calcareous fens are the rarest wetland plant community in Minnesota, and as such are specially protected (Chapter 5 and Appendix F). These fens are peat-accumulating wetlands dominated by distinct ground-water inflows having specific calcium carbonate chemical characteristics. Flows are circum-neutral to alkaline, with high concentrations of calcium and low dissolved oxygen content. The water chemistry creates a unique environment for a disproportionately large number of rare, threatened, and endangered wetland plant species compared to other plant communities in the Great Lakes region (MN SWAG, 1997). Changes in wetland water quality can alter the nature of the plant community, encouraging invasive species, and reducing sensitive species that are preferred by fish, mammals, birds, and amphibians for food and shelter (U.S. EPA, 1993).

Stormwater runoff inputs can exceed the water depths and frequency/duration of inundation prevalent in natural wetlands. Deposition of sediment carried by urban stormwater can have the same effect, causing replacement of diverse species with monotypes of reed-canary grass or cattails, which are much more tolerant of sedimentation and fluctuating water levels. Schueler (2000b) reported that invasive or aggressive plant species are favored when water level fluctuation (WLF) is high (e.g., reed-canary grass). The result is low vegetative diversity and lower quality wildlife habitat values (MN SWAG, 1997). A modest change in WLF sharply decreases plant species richness, and amphibian species richness a study in the Pacific Northwest (Horner, et al., 1996). Some communities have used existing wetlands for stormwater treatment by increasing the depth of ponding on a permanent or temporary basis. The end result is the transformation of a natural wetland into a stormwater wetland, with the attendant loss of diversity and functional values.

Not all wetlands respond in the same way to the impact of stormwater runoff. In the context of this Manual, wetlands can be defined as Susceptible or Non-Susceptible to stormwater runoff, based on the MN SWAG (1997) wetland classification scheme. This classification provides a useful framework for managing stormwater inputs to different types of wetlands.

Highly susceptible wetland communities can be composed of dozens of plant species. Table 10.13 presents the MN SWAG classification of wetland types according to their presumed susceptibility to degradation by stormwater. Given this diversity of wetland types, it is not surprising that wetlands have a broad range of tolerance to stormwater runoff. Some wetlands (e.g. calcareous fens) are sensitive to any disturbance and will show signs of degradation with even low-level inputs of urban stormwater. Note that Susceptible Wetlands are defined as highly and moderately susceptible in Table 10.13 and Non-Susceptible Wetlands are defined as slightly and least in the table.

The following adjustments to the standard stormwater sizing criteria are recommended to protect wetlands from the indirect impact of stormwater runoff. Note that wetlands are highly regulated within the state (Chapter 5) and that all federal, state and local/watershed authorities should be consulted before any activity is initiated on any parcel of land that appears to be a wetland.


Highly recommended for Susceptible Wetlands. Many Susceptible Wetlands are dependent on ground water to maintain their natural hydrology so it is important to maintain recharge at a consistent rates in the contributing source area to the wetland. Recharge is also recommended for Non-Susceptible Wetlands that are dependent on ground water.

Water Quality

Recommend site based phosphorus load reduction. Site-based phosphorus load reduction for Susceptible Wetlands using the method described for Most-Sensitive Lakes (Section IX) are recommended to control nutrients. Site-based nutrient load reduction should be used for nutrient sensitive bogs and calcareous fens. No untreated stormwater discharges should be allowed to Non-Susceptible Wetlands, which are operationally defined as providing water quality volume according to MPCA sizing Rules 2 and 4 (depending on the type of BMP chosen). Currently, the MPCA interprets the CGP as requiring a permanent pool in constructed stormwater wetland systems. While this seems appropriate for a pond/wetland system, it does detract from the bioretention character of the other wetland BMPs described in Chapter 12. The application of a permanent pool to constructed stormwater wetland systems that behave as bioretention systems should be considered for change in the next CGP update.

In addition, Susceptible Wetlands should not be used for stormwater treatment. A Non-Susceptible Wetland should only be used for stormwater treatment if designers can demonstrate that it will restore wetland functional value, and only when approved by the local government unit acting as approving agency under the Minnesota Wetland Conservation Act.

Channel Protection

Limited. Channel Protection is recommended only when a channel is a direct tributary to a wetland.


Maintain wetland hydroperiod. Designers should maintain the hydroperiod of Susceptible Wetlands following development to prevent detrimental impacts. Any wetlands present at the site should be investigated in the field to determine their wetland type and contributing hydrologic source area, and then determine if any additional runoff will be delivered to the wetland as a result of the proposed project. Based on this determination, a wetland will be classified as either Susceptible or Non-Susceptible, using the criteria outlined in Table 10.13.

Table 10.14 presents hydroperiod guidelines for wetlands, developed by MN SWAG (1997) for use unless better site-specific data are available. The term “existing” in this chart means the existing hydrologic conditions. If there have been recent significant changes in conditions, it means the conditions that established the current wetland. Designers then model the effect of runoff discharge from the site on the wetland to ensure they conform to the storm bounce and inundation duration guidelines standards set forth in Table 10.14 using infiltration, extended detention, diversion or other methods.

BMP Selection

Additional guidance on BMP design to protect wetlands is offered below:

  • BMPs such as stormwater wetlands, infiltration systems, and bioretention are encouraged to treat runoff prior to discharge to a wetland.
  • Direct pipe outfalls to wetlands should be restricted (e.g., not allowed, allowed if energy dissipated, or routed through a pre-treatment system).
  • Stormwater should be routed around sensitive wetlands using a diversion or bypass system.
  • Constrictions at wetland outlets should be avoided.
  • Natural wetlands should not be used for stormwater treatment, unless they are severely impaired and construction would enhance or restore wetland functions; if natural wetlands are used in this manner, MN Rules 7050 establishes the sequence of avoid, minimize and compensatory replacement.
  • The discharge of untreated stormwater to a wetland is prohibited.

Impaired Waters

Under the Clean Water Act, Minnesota administers water quality standards which consist of numeric and narrative criteria that protect the physical, chemical and biological integrity of surface waters in the state. These criteria are set to maintain seven designated or beneficial uses of water in the state. The state routinely monitors the quality of its waters to determine if they are meeting their designated uses. If monitoring indicates that water quality standards are not being met and/or designated uses are not being achieved, the state lists the water as being “impaired”. This, in turn, triggers the Total Maximum Daily Load (TMDL) provisions of the Clean Water Act.

A TMDL consists of an analysis to determine what pollutant reduction is needed to achieve water quality standards, and is normally conducted at the watershed scale. A TMDL determines the amount of pollutants that a waterbody can receive from both point and nonpoint sources and still meet water quality standards (e.g., no impairment). Water quality sampling and computer modeling determine how much each pollutant source needs to be reduced to assure the water quality standard is met. More discussion on how TMDLs are developed in Minnesota can be found at www.pca.state.mn.us/water/tmdl/index.html.

Impaired waters include streams and lakes that do not meet their designated uses because of excess pollutants or identified stressors. As of 2004, 916 lakes and 199 river and stream segments were listed as impaired waters for Minnesota (MPCA, 2004). Each listed water will ultimately require a TMDL based on the assessment. Currently, there are 14 pollutants causing water quality standard violations in some part of the state as shown in Table 10.15. To date (fall 2005), only four final TMDLs and their corresponding implementation plans have been completed in Minnesota, so many listed waters currently lack a TMDL or are in the process of developing one.

While none of the completed TMDL implementation plans currently contain stormwater requirements, they may eventually be included if stormwater pollution is determined to be a significant source of the listed pollutant. Therefore, development projects that occur in a listed watershed may require a higher level of stormwater treatment, regardless of whether a TMDL has been completed or not. The main reason is that both municipal NPDES Phase I or II stormwater permits and individual construction general permits must be consistent with the load allocations and pollutant reductions contained in an approved TMDL. If stormwater runoff is likely to be a significant pollutant source within a listed watershed, the local review authority may elect to require higher levels of stormwater treatment to restore the impaired water.

Some general guidance on how to deal with stormwater pollutant loads at development sites located within listed waters is provided below.

In the first step, the local review authority should check with MPCA to determine:

  • Whether any local waters as listed as impaired;
  • Which pollutant(s) is causing the impairment to be listed;
  • The estimated watershed area to the receiving water;
  • The timeframe under which the water will fall under the TMDL program; and
  • Whether stormwater is expected to be a significant source of the impairment for the indicated pollutant.

If an impairment exists, the local reviewing authority should determine whether the indicated pollutant is considered computable or non-computable. In the context of stormwater, “computable” is defined as a pollutant for which enough data exist to perform a site-based pollutant load calculation that documents no increase or even a reduction in pollutant loading. By contrast, “non-computable” pollutants lack enough data to perform a reliable site based pollutant reduction calculation. Issue Paper E outlined the process for determining pollutant computability. Computable pollutant must pass four tests:

  1. Enough stormwater EMC data is available to characterize its average level in stormwater;
  2. Stormwater concentrations are high enough to constitute a major source in the stormwater load allocation;
  3. Sufficient BMP performance data are available to estimate expected removal for a range of stormwater practices; and
  4. Stormwater removal rates are high enough to warrant performing the calculation.

Currently, only five pollutants meet all four criteria -- sediment, phosphorus, nitrogen, ammonia, and fecal coliform bacteria (Table 10.15). A stormwater strategy to deal with computable and non-computable pollutants within listed is offered below.

Water Quality: Computable pollutants

If a new development site is located in a watershed subject to a TMDL that has no remaining stormwater allocation, the local review authority may wish to adopt a “no net increase” policy for the listed computable pollutant (e.g., sediment, phosphorus, nitrogen, ammonia or fecal coliform). Pollutant removal calculations should be conducted on a site-by-site basis, using the general method proposed for the Most-Sensitive Lakes, adapted for the listed pollutant. An example of an approach for calculating phosphorus removal is provided in Appendix L.

Water Quality: Non-computable pollutants

Since non-computable pollutants lack enough data to perform a site-based load reduction calculation, they can only be managed by increasing the Vwq assuming that a higher level of pollutant reduction will occur within the BMP. In these situations, the local review authority may wish to require that development sites satisfy MPCA water quality volume sizing Rules 2 or 4, depending on the type of BMP employed.

Channel Protection

Recommend for waters listed for sediment or sediment related pollutant. Given the importance of channel erosion in the sediment budget of urban streams, it is advisable to require channel protection criteria in watersheds that are listed for sediment. In all cases, the local review authority should check with MPCA to determine what, if any, water quality or channel protection requirements need to be addressed as part of TMDL implementation.

BMP Selection

The selection and design of specific BMPs to address impaired water pollutant reductions will be determined through the TMDL process. Chapter 12 can be used to construct an effective BMP implementation strategy.

Stormwater Sizing for Redevelopment Projects

Small redevelopment sites can pose special challenges for stormwater design, given their small size, intensive use, and compacted soils. Redevelopment projects are also not covered under the CGP unless they created more than one acre of new impervious surface or are part of a larger related planned development. Communities may wish to develop special sizing criteria for smaller redevelopment so that the cost to comply with stormwater requirements does not become a barrier to smart growth.

The following guidance is offered for handling redevelopment projects. It has been adapted from several recent manuals that represent a balanced approach to stormwater management for these sites.

The first issue is how to define what is meant by infill and redevelopment, which may be different in each locality. One accepted definition is that redevelopment is “any construction, alteration, or improvement that disturbs greater than or equal to 5,000 square feet of existing impervious cover performed on sites where the existing land use is commercial, industrial, institutional, or residential.” Note that this definition does not fall under the purview of the CGP.

The second issue is to provide some greater flexibility in how redevelopment projects can comply with basic stormwater sizing criteria. This is done by proposing stormwater management guidance that a redevelopment will:

  1. Provide a reduction in impervious area; or
  2. Implement stormwater management practices; or
  3. A combination of both (a) and (b) to result in an improvement to water quality.

More specifically, redevelopment projects introduce a chance to reduce existing site impervious area. Where site conditions prevent the reduction of impervious area, stormwater management practices could be implemented to provide water quality control for at least 20 percent of the site’s impervious area as a general guideline.

When a combination of impervious area reduction and stormwater management practice implementation is used for redevelopment projects, the combination of impervious area reduction and the area controlled by a stormwater management practice should equal or exceed 20 percent coverage of the project size.

The MPCA may allow practical alternatives where conditions prevent impervious area reduction or on-site stormwater management. Practical alternatives include, but are not limited to:

  • Fees paid in an amount specified by the approving agency and then dedicated to stormwater management;
  • Off-site stormwater treatment practice implementation for a drainage area comparable in size and impervious cover to that of the project;
  • Watershed or stream restoration; or
  • Stormwater retrofitting.

The recharge, channel protection storage volume, overbank, and extreme flood protection volume requirements specified in the Manual do not apply to redevelopment projects unless specified in an approved and adopted basin plan.


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