[Watershed name] Watershed Restoration and Protection Strategy Report [Date of report] [Insert watershed-specific photo or graphic] Watershed Partners [Insert logos of other organizations that have participated in this process or list on next page if multiple.] wq-ws4-03 Note: Change the template document number to the assigned WRAPS Report document number. Project Partners [List all project partners] [Watershed Name] WRAPS Report 2 Table of Contents Project Partners......................................................................................................................................... 2 Key Terms .................................................................................................................................................. 4 Executive Summary ................................................................................................................................... 5 What is the WRAPS Report?...................................................................................................................... 6 1. Watershed Background & Description............................................................................. 7 2. Watershed Conditions .................................................................................................... 8 3. 2.1 Condition Status ............................................................................................................................ 9 2.2 Water Quality Trends .................................................................................................................. 10 2.3 Stressors and Sources .................................................................................................................. 11 2.4 TMDL Summary ........................................................................................................................... 14 2.5 Protection Considerations ........................................................................................................... 15 Prioritizing and Implementing Restoration and Protection ............................................ 16 3.1 Targeting of Geographic Areas ................................................................................................... 16 3.2 Civic Engagement ........................................................................................................................ 20 3.3 Restoration & Protection Strategies ........................................................................................... 21 4. Monitoring Plan............................................................................................................ 33 5. References and Further Information ............................................................................. 34 Appendix............................................................................................................................. 35 [Watershed Name] WRAPS Report 3 Key Terms Assessment Unit Identifier (AUID): The unique water body identifier for each river reach comprised of the USGS eight-digit HUC plus a three-character code unique within each HUC. Aquatic life impairment: The presence and vitality of aquatic life is indicative of the overall water quality of a stream. A stream is considered impaired for impacts to aquatic life if the fish Index of Biotic Integrity (IBI), macroinvertebrate IBI, dissolved oxygen, turbidity, or certain chemical standards are not met. Aquatic recreation impairment: Streams are considered impaired for impacts to aquatic recreation if fecal bacteria standards are not met. Lakes are considered impaired for impacts to aquatic recreation if total phosphorus, chlorophyll-a, or Secchi disc depth standards are not met. Hydrologic Unit Code (HUC): A Hydrologic Unit Code (HUC) is assigned by the USGS for each watershed. HUCs are organized in a nested hierarchy by size. For example, the Minnesota River Basin is assigned a HUC-4 of 0702 and the Pomme de Terre River Watershed is assigned a HUC-8 of 07020002. Impairment: Water bodies are listed as impaired if water quality standards are not met for designated uses including aquatic life, aquatic recreation, and aquatic consumption. Index of Biotic integrity (IBI): A method for describing water quality using characteristics of aquatic communities, such as the types of fish and invertebrates found in the waterbody. It is expressed as a numerical value between 0 (lowest quality) to 100 (highest quality). Protection: This term is used to characterize actions taken in watersheds of waters not known to be impaired to maintain conditions and beneficial uses of the waterbodies. Restoration: This term is used to characterize actions taken in watersheds of impaired waters to improve conditions, eventually to meet water quality standards and achieve beneficial uses of the waterbodies. Source (or Pollutant Source): This term is distinguished from ‘stressor’ to mean only those actions, places or entities that deliver/discharge pollutants (e.g., sediment, phosphorus, nitrogen, pathogens). Stressor (or Biological Stressor): This is a broad term that includes both pollutant sources and nonpollutant sources or factors (e.g., altered hydrology, dams preventing fish passage) that adversely impact aquatic life. Total Maximum Daily Load (TMDL): A calculation of the maximum amount of a pollutant that may be introduced into a surface water and still ensure that applicable water quality standards for that water are met. A TMDL is the sum of the wasteload allocation for point sources, a load allocation for nonpoint sources and natural background, an allocation for future growth (i.e., reserve capacity), and a margin of safety as defined in the Code of Federal Regulations. [Watershed Name] WRAPS Report 4 Executive Summary [High-level overview; ~one page] [Watershed Name] WRAPS Report 5 What is the WRAPS Report? The State of Minnesota has adopted a “watershed approach” to address the state’s 80 “major” watersheds (denoted by 8-digit hydrologic unit code or HUC). This watershed approach incorporates water quality assessment, watershed analysis, civic engagement, planning, implementation, and measurement of results into a 10-year cycle that addresses both restoration and protection. As part of the watershed approach, waters not meeting state standards are still listed as impaired and Total Maximum Daily Load (TMDL) studies are performed, as they have been in the past, but in addition the watershed approach process facilitates a more cost-effective and comprehensive characterization of multiple water bodies and overall watershed health. A key aspect of this effort is to develop and utilize watershed-scale models and other tools to identify strategies and actions for point and nonpoint source pollution that will cumulatively achieve water quality targets. For nonpoint source pollution, this report informs local planning efforts, but ultimately the local partners decide what work will be included in their local plans. This report also serves as a watershed plan addressing EPA’s Nine Minimum Elements to qualify applicants for eligibility for section 319 implementation funds. [Report authors: see guidance attached to this template.] Purpose Scope Audience •Support local working groups and jointly develop scientifically-supported restoration and protection strategies to be used for subsequent implementation planning •Summarize Watershed Approach work done to date including the following reports: •[Name] Watershed Monitoring and Assessment •[Name] Watershed Biotic Stressor Identification •[Name] Watershed Total Maximum Daily Load •Impacts to aquatic recreation and impacts to aquatic life in streams •Impacts to aquatic recreation in lakes •Local working groups (local governments, SWCDs, watershed management groups, etc.) •State agencies (MPCA, DNR, BWSR, etc.) [Watershed Name] WRAPS Report 6 1. Watershed Background & Description [Provide brief overview of the watershed: size, basin, ecoregion(s), overview of land use, major cities. Refer reader to a webpage or other documents for additional information. A map showing land use or some other basic landscape features should be added here. [Insert Watershed Map (e.g., land cover map)] This could be a place to identify and briefly summarize past studies in the watershed.] Additional [Watershed Name] Watershed Resources USDA Natural Resources Conservation Service (NRCS) Rapid Watershed Assessment for the [Name] Watershed: [include link to watershed found at: http://www.mn.nrcs.usda.gov/technical/rwa/Assessments/index.html] Minnesota Department of Natural Resources (DNR) Watershed Assessment Mapbook for the [Name] Watershed: [include link to watershed found at: http://www.dnr.state.mn.us/watershed_tool/promo.html] [Watershed Name] WRAPS Report 7 2. Watershed Conditions [This section is intended to satisfy several required WRAPS elements provided in Mn. Stat. 114D (Clean Water Legacy Act): identification of impaired waters, waters needing protection, point sources, nonpoint sources, allocations, current loading, and needed reductions. [Insert Watershed Map (e.g., impaired waters)] In this intro portion, it is appropriate to provide some high-level overview, e.g., waters assessed for both aquatic recreation and aquatic life use, percent of waters assessed and impaired in the watershed, general spatial trends or patterns. In addition, it may be worth briefly describing the major land-water components that interact to affect aquatic life in the watershed (land use, hydrology, biology, in-channel factors, etc.). The map should clearly identify impaired waters by name or ID as well as subwatersheds (10digit HUC scale appears to be a reasonable scale).] [Watershed Name] WRAPS Report 8 2.1 Condition Status [Per 114D.26, Subd. 1, (1) WRAPS shall “identify impaired waters and waters in need of protection.” This can mostly be done in tabular form covering the full range of conventional parameters used in assessment. However, in the narrative it is important to introduce the point that the waters that are not listed as impaired will be subject to protection efforts. More on protection considerations can be covered in section 2.5.] [Consider including the following regarding mercury impairments (or similar language if other nonconventional listings.)] Some of the waterbodies in the [Name] Watershed are impaired by mercury; however, this report does not cover toxic pollutants. For more information on mercury impairments see the statewide mercury TMDL at: http://www.pca.state.mn.us/index.php/water/water-types-andprograms/minnesotas-impaired-waters-and-tmdls/tmdl-projects/special-projects/statewide-mercurytmdl-pollutant-reduction-plan.html. Streams [Provide narrative to introduce table below.] Table 1: Assessment status of stream reaches in the Pomme de Terre River Watershed, presented (mostly) from north to south Aq Rec Bacteria Dry Wood Creek Turbidity/TSS Middle Pomme de Terre River Dissolved Oxygen Upper Pomme de Terre River AUID (Last 3 digits) Macroinvertebrate Index of Biotic Integrity HUC-10 Subwatershed Fish Index of Biotic Integrity Aquatic Life IF IF NA NA NA T130R41W S4, N line to PdT River Sup Sup NA Sup IF Pomme de Terre River Pelican Creek to PdT Lake Sup Sup NA NA NA 558 Pomme de Terre River N PdT Lake to Middle PdT Lake IF IF NA NA NA 562 Pomme de Terre River Perkins Lake to Muddy Creek Imp Sup IF Sup IF 556 Dry Wood Creek Dry Wood Lake to PdT River Imp Imp Imp Imp Imp Stream Reach Description 528 Unnamed Creek Long Lake to Stalker Lake 506 Pelican Creek 504 Sup = found to meet the water quality standard, Imp = does not meet the water quality standard and therefore, is impaired, IF = the data collected was insufficient to make a finding, NA = not assessed [Watershed Name] WRAPS Report 9 Lakes [Provide narrative to introduce table below. Important to explain parameters used in eutrophication assessment and that it is an aquatic recreation-based standard.] Table 2 Assessment status of stream reaches in the Pomme de Terre River Watershed, presented (mostly) from north to south HUC-10 Subwatershed Upper Pomme de Terre Pelican Creek Aquatic Recreation Lake ID Lake 56-0379 North Turtle Imp 56-0377 South Turtle Sup 56-0639 Indian IF 56-0651 Larson IF 56-0781 Swan Sup 56-0437 Stalker Sup 56-0390 Long Sup 56-0252 Middle 56-0253 Eagle 56-0160 Spitzer IF 56-0408 Sewell IF 21-0375 Christina IF Sup Imp Imp = impaired for impacts to aquatic recreation, Sup = fully supporting aquatic recreation, IF = insufficient data to make an assessment 2.2 Water Quality Trends [This section can report any observed overall trends in stream and/or lake monitoring, if available. Indicate time period and discuss significance of these trends. Use caution when evaluating data for trends—a long-term record is needed. See example table below (for the main stem river only). Refer reader to other documents for more information on historic water quality results.] [Watershed Name] WRAPS Report 10 Table 3 Water quality trends of the Pomme de Terre River at Appleton (just upstream from the mouth of the river), green values indicate an improving trend in water quality for that parameter while red values indicate a degrading trend in water quality for that parameter Historical Trend (1971-2009) Recent Trend (1995-2009) no trend -38% Biochemical Oxygen Demand -56% no trend Total Phosphorus -42% no trend Nitrite/ Nitrate +280% no trend Chloride +89% no trend Parameter Total Suspended Solids 2.3 Stressors and Sources [Insert brief introductory narrative, such as provided below. Be aware of some readers’ confusion over the terms ‘stressor’ and ‘source’ (in spite of their being defined in the Key Terms section). Also note that the content below is largely focused on restoration, rather than protection (mainly because it is summarizing impairment-focused reports), but consideration should be given to protection-related stressors/sources. Section 2.5 Protection Considerations may be an appropriate place to provide such information.] In order to develop appropriate strategies for restoring or protecting waterbodies the stressors and/or sources impacting or threatening them must be identified and evaluated. Biological stressor identification is done for streams with either fish or macroinvertebrate biota impairments and encompasses both evaluation of pollutants and non-pollutant-related factors as potential stressors (e.g. altered hydrology, fish passage, habitat). Pollutant source assessments are done where a biological stressor ID process identifies a pollutant as a stressor as well as for the typical pollutant impairment listings. Section 3 provides further detail on stressors and pollutant sources. Stressors of Biologically-Impaired Stream Reaches [Per 114D.26, Subd. 1, (2) WRAPS shall “identify biotic stressors causing impairments or threats to water quality.” Information should come from the stressor ID Report summarizing, at a minimum, the primary stressors identified. Information should be summarized in a table if possible (see example below), but should be accompanied with some narrative to, at a minimum, provide further explanation and discussion for some of the less self-explanatory stressors, like “altered hydrology” or “habitat.” [Watershed Name] WRAPS Report 11 Table 4: Primary stressors to aquatic life in biologically-impaired reaches in the Pomme de Terre River Watershed Lower Pomme de Terre River Habitat Dry Wood Creek Altered Hydrology Middle Pomme de Terre River ● ● ● ● ● ● ● Pomme de Terre River Barrett Lake to North PdT Lake Fish 562 Pomme de Terre River Perkins Lake to Muddy Creek Fish 556 Dry Wood Creek Dry Wood Lake to PdT River 551 Unnamed Creek Unnamed Creek to Unnamed Creek Fish ● ● 501 Pomme de Terre River Muddy Creek to Minnesota River Fish & Macroinvert. ● ● Biological Impairment Fish & Macroinvert. Turbidity 563 Reach Description Phosphorus Stream Nitrate AUID (Last 3 digits) Dissolved Oxygen HUC-10 Subwatershed Fish Passage (dams) Primary Stressor ● ● ● ● ● ● Pollutant sources [Per 114D.26, Subd. 1, (4) and (5) WRAPS shall “identify point sources of pollution for which an NPDES permit is required” and “identify nonpoint sources of pollution for which an NPDES permit is not required, with sufficient specificity to prioritize and geographically locate watershed restoration and protection actions.” The point source table below should meet the requirement of (4) above (possible permit types to include are listed). Nonpoint documentation will be more of a challenge, particularly the italicized portion of (5). Some of that detail could be deferred to section 3 (e.g., modeling output/figures; targeting tool figures and narrative). The nonpoint table below is a potential way to summarize some source information (though still not to the level of rigor inferred in (5)). If you indicate relative magnitudes of sources you should explain in the narrative how that was done. Inclusion of the figure below portraying nonpoint vs. point source is recommended; as it provides important basic source information and context (information can be derived using HSPF; right-click on pie chart to edit data). In partial fulfillment of element ‘a’ of EPA’s “Nine Minimum Elements to Be Included in a Watershed Plan…” there should be a map “that locates the major causes and sources of impairment.” Such a map (or maps) may be included in this section or, if more appropriate, section 3.1.] [Watershed Name] WRAPS Report 12 Phosphorus Nitrogen Sediment (TSS) 10% 20% 40% 60% 80% 90% Figure X. Overall breakdown of nonpoint source vs. point source pollution in [Name] Watershed. Table 5: Point Sources in the [Name] Watershed Point Source HUC-10 Subwatershed Name Permit # Type Municipal wastewater Pollutant reduction needed beyond current permit conditions/limits? Notes [Yes / No] Industrial wastewater Municipal stormwater Industrial stormwater Construction stormwater CAFO [Watershed Name] WRAPS Report 13 Table 6: Nonpoint Sources in the [Name] Watershed. Relative magnitudes of contributing sources are indicated. Bacteria Upland soil erosion Poor riparian vegetation cover TSS Pomme de Terre River (563) Middle Pomme de Terre River Wildlife Pollutant Failing septic systems Stream/Reach (AUID) or Lake (ID) Livestock overgrazing in riparian HUC-10 Subwatershed Fertilizer & manure run-off Pollutant Sources TP N Pomme de Terre River (562) Bacteria Perkins Lake (75-0075) TP TSS TSS Dry Wood Creek Dry Wood Creek (556) TP N Key: = High = Moderate = Low 2.4 TMDL Summary [The CWLA requires inclusion of TMDL information in the WRAPS report. Specifically, per 114D.26, Subd. 1, (3) and (6), WRAPS shall “summarize watershed modeling outputs and resulting pollution load allocations, wasteload allocations, and priority areas for targeting actions to improve water quality” and “describe the current pollution loading and load reduction needed for each source or source category to meet water quality standards and goals, including wasteload and load allocations from TMDL's.” It would likely be cleaner to limit the TMDL Summary section of this report to the allocations, current loading and reductions, and to defer the italicized elements above (modeling outputs and priority areas) to section 3. The allocations, etc. can be summarized by bringing in specific tables from the TMDL report. However, given that there may be dozens of impairments with completed TMDLs it may be best to place a general summary table here (simply listing which waterbodies have a completed TMDL for example) and put the actual TMDL tables in an appendix to this report. Also, some TMDL summary tables do not include current loads or reductions, so those elements will need to be addressed in some alternate way.] [Watershed Name] WRAPS Report 14 2.5 Protection Considerations [If not already covered elsewhere, this section should further highlight protection needs in the watershed. This can take on various forms. Possibly highlight waters that are trending toward impairment, outstanding resource value waters (or other waters the state considers to be of high value), or highlight particular pressures on waters (e.g., land development issues). Strategies for addressing these waters can be part of section 3.] [Watershed Name] WRAPS Report 15 3. Prioritizing and Implementing Restoration and Protection [Below is some narrative to consider for this intro portion. In addition, there should be narrative regarding the entities/collaboration/compromises/etc. involved to develop these tools/strategies. This introduction to Section 3 can be used to reiterate that the intention of the WRAPS is to bring to bear all technical resources to identify and prioritize strategies and geographies in the watershed in an effort to inform subsequent local planning efforts.] The Clean Water Legacy Act (CWLA) requires that WRAPS reports summarize priority areas for targeting actions to improve water quality, identify point sources and identify nonpoint sources of pollution with sufficient specificity to prioritize and geographically locate watershed restoration and protection actions. In addition, the CWLA requires including an implementation table of strategies and actions that are capable of cumulatively achieving needed pollution load reductions for point and nonpoint sources. This section of the report provides the results of such prioritization and strategy development. Because much of the nonpoint source strategies outlined in this section rely on voluntary implementation by landowners, land users and residents of the watershed, it is imperative to create social capital (trust, networks and positive relationships) with those who will be needed to voluntarily implement best management practices. Thus, effective ongoing civic engagement is fully a part of the overall plan for moving forward. The implementation strategies, including associated scales of adoption and timelines, provided in this section are the result of watershed modeling efforts [specify, if desired] and professional judgment based on what is known at this time and, thus, should be considered approximate. Furthermore, many strategies are predicated on needed funding being secured. As such, the proposed actions outlined are subject to adaptive management—an iterative approach of implementation, evaluation and course correction. [Element ‘d’ of EPA’s “Nine Minimum Elements to Be Included in a Watershed Plan…” calls for “An estimate of the amounts of technical and financial assistance needed, associated costs, and/or the sources and authorities that will be relied upon, to implement this plan.” MPCA recognizes that a local plan or project work plan is a more appropriate document for cost estimates. However, it appears that narrative that focuses on the “sources and authorities that will be relied upon” is adequate for meeting element ‘d’ and should include a discussion of available funding sources to be sought (e.g., cost share, grant and loan programs from local, state and federal sources) as well as narrative indicating organizations that could provide technical assistance.] 3.1 Targeting of Geographic Areas [Per 114D.26, Subd. 1, (3) and (5) WRAPS shall “summarize … priority areas for targeting actions to improve water quality” and “identify nonpoint sources of pollution … with sufficient specificity to prioritize and geographically locate watershed restoration and protection actions.” It is generally expected that in order to accomplish these objectives some combination of the tools outlined in the table below will need to be utilized. (Note: this table is not all-inclusive of the possible prioritization approaches that can be used. Also, the table is not intended to be included in the actual WRAPS report; [Watershed Name] WRAPS Report 16 rather, it is provided as guidance for the project team. Elements of the selected tool(s) should be explained in this section, however.) The primary purpose of this section, and the statutory language on which it’s based, is to identify priority or critical areas for implementation. In the context of pollutant loading and water quality impairment, these are areas identified by a watershed model or similar tool (and ultimately confirmed by field observation and/or vetted/confirmed by local partners/stakeholders) that show disproportionately contributing pollutant loads or excess flow to surface waters. For protection purposes such areas may include areas that if altered would have a high potential for adversely affecting water quality. This section should describe the selected tools, illustrate overall results/output and outline how the tools will be used over time. Depending on the tools selected, it is important to point out that follow-up field reconnaissance will be part of the process to validate the identified areas potentially needing work. Include maps illustrating priority/critical areas and results of analysis (e.g., top 5% of EBI land areas; pollutant loading by subwatershed using a color-scale, green (low loading) to red (high loading); HSPF-identified scour/deposition reaches). The results of modeling efforts to simulate the types and extent of BMPs (i.e., scenarios) can be summarized in this section as well. Element ‘c’ of EPA’s “Nine Minimum Elements to Be Included in a Watershed Plan…” calls for “A description of the NPS management measures that will need to be implemented to achieve the load reductions under paragraph (b) above (as well as to achieve other watershed goals identified in this watershed-based plan), and an identification (using a map or a description) of the critical areas in which those measures will be needed to implement this plan.” This section is key for addressing the ‘critical areas’ component of this element. To better assure meeting this element, it is recommended that the narrative of this section specifically use the term ‘critical areas’ when describing the results/output.] [Watershed Name] WRAPS Report 17 Tool Ecological Ranking Tool (Environmental Benefit Index EBI) Zonation Restorable Wetland Inventory Description How can the tool be used? Notes These data layers are available on the BWSR website. This dataset consists of three GIS raster data layers including soil erosion risk, water quality risk, and habitat quality. The 30-meter grid cells in each layer contain scores from 0-100. The sum of all three scores is the EBI score (max of 300). A higher score indicates a higher priority for restoration or protection. The three layers can be used separately, or the sum of the layers (EBI) can be used to identify priority areas for restoration or protection projects. The layers can be weighted or combined with other layers to better reflect local values. This tool serves as a framework and software for large‐scale spatial conservation prioritization, and a decision support tool for conservation planning. The tool incorporates valuesbased priorities to help identify areas important for protection and restoration. Zonation produces a hierarchical prioritization of the landscape based on the occurrence levels of features in sites (grid cells). It iteratively removes the least valuable remaining cell, accounting for connectivity and generalized complementarity in the process. The output of Zonation can be imported into GIS software for further analysis. Zonation can be run on very large data sets (with up to ~50 million grid cells). The software allows balancing of alternative land uses, landscape condition and retention, and feature‐ specific connectivity responses. (Paul Radomski, DNR, has expertise with this tool.) Identifies potential wetland restoration sites with an emphasis on wildlife habitat, surface and ground water quality, and reducing flood damage risk. The GIS data layer is available for viewing and download on the Minnesota ‘Restorable Wetland Prioritization Tool’ web site. A GIS data layer that shows potential wetland restoration sites across Minnesota. Created using a compound topographic index (CTI) (10-meter resolution) to identify areas of ponding, and USDA NRCS SSURGO soils with a soil drainage class of poorly drained or very poorly drained. [Watershed Name] WRAPS Report Link to Information and data In addition, a GIS data layer that shows the five percent of each 8-digit watershed in Minnesota with the highest EBI scores is available for viewing in the MPCA ‘water quality targeting’ web map, and download from MPCA. BWSR MPCA Web Map MPCA download Software Examples Restorable Wetlands 18 National Hydrography Dataset (NHD) & Watershed Boundary Dataset (WBD) The NHD is a vector GIS layer that contains features such as lakes, ponds, streams, rivers, canals, dams and stream gages, including flow paths. The WBD is a companion vector GIS layer that contains watershed delineations. General mapping and analysis of surface-water systems. These data have been used for fisheries management, hydrologic modeling, environmental protection, and resource management. A specific application of this data set is to identify riparian buffers around rivers. The layers are available on the USGS website. USGS Light Detection and Ranging (LiDAR) Elevation data in a digital elevation model (DEM) GIS layer. Created from remote sensing technology that uses laser light to detect and measure surface features on the earth. General mapping and analysis of elevation/terrain. These data have been used for erosion analysis, water storage and flow analysis, siting and design of BMPs, wetland mapping, and flood control mapping. A specific application of the data set is to delineate small catchments. The layers are available on the Minnesota Geospatial Information Office website. MGIO Hydrological Simulation Program – FORTRAN (HSPF) Model Simulation of watershed hydrology and water quality for both conventional and toxic organic pollutants from pervious and impervious land. Typically used in large watersheds (greater than 100 square miles). [Watershed Name] WRAPS Report Incorporates watershed-scale and non-point source models into a basin-scale analysis framework. Addresses runoff and constituent loading from pervious land surfaces, runoff and constituent loading from impervious land surfaces, and flow of water and transport/ transformation of chemical constituents in stream reaches. Local or other partners can work with MPCA HSPF modelers to evaluate at the watershed scale: 1) the efficacy of different kinds or adoption rates of BMPs, and 2) effects of proposed or hypothetical land use changes. USGS 19 3.2 Civic Engagement [Below is a brief introduction with a link for more information regarding Civic Engagement (CE). (Reviewers of the draft template prefer limited boilerplate content and have more focus on CE occurring in the watershed.)] A key prerequisite for successful strategy development and on-the-ground implementation is meaningful civic engagement. This is distinguished from the broader term ‘public participation’ in that civic engagement encompasses a higher, more interactive level of involvement. Specifically, the University of Minnesota Extension’s definition of civic engagement is “Making ‘resourceFULL’ decisions and taking collective action on public issues through processes that involve public discussion, reflection, and collaboration.” A resourceFULL decision is one based on diverse sources of information and supported with buy-in, resources (including human), and competence. Further information on civic engagement is available at: http://www1.extension.umn.edu/community/civic-engagement/ Accomplishments and Future Plans [Format here can vary. Element ‘e’ of EPA’s “Nine Minimum Elements to Be Included in a Watershed Plan…” calls for “An information/education component…”. Completion of the items below should fulfill this requirement. - Citizen-led groups established Listing of groups/organizations involved Summary of all local involvement (CE and others) to date (for all phases of the WRAPS process: citizen stream/lake monitoring to decision-making for restoration/protection strategies) Planned CE efforts moving forward Other ongoing education/outreach/awareness efforts (other than CE) moving forward Need for resources to build local capacity or other challenges] Public Notice for Comments An opportunity for public comment on the draft WRAPS report was provided via a public notice in the State Register from [XXX] to [XXX]. [Watershed Name] WRAPS Report 20 3.3 Restoration & Protection Strategies [This section provides a summary of implementation strategies and actions for both restoration and protection. While there should be some supporting/explanatory narrative, the bulk of this section must be in the form of a table. The CWLA is very specific about the components of this table and in order to meet these requirements and facilitate MPCA tracking and reporting it is required that the format and headings in the example provided below be used. However, additional information may be added in separate columns if that is deemed useful. The example content (i.e., the cell “entries”) provided (see accompanying Excel spreadsheet for Table 7) is meant to demonstrate a range of possibilities that may correspond to available resources/data and stakeholder processes. It is important to consider the interplay between the WRAPS table content and subsequent local planning steps; this may vary somewhat across major watersheds and thus the level of detail provided in the table content may also vary. In general this section should culminate the discussion of estimating what needs to happen (and where) to achieve described water quality goals; subsequent local planning steps will then describe “how to do it.” In the example table in the spreadsheet many (and in some instances all) of the strategy types for a given “strategy group” have been input, but this need not be the case in typical WRAPS report completion; use some or all of the strategy types and adoption information as needed. It is also important to note that the table should include strategies for impairments that are caused by non-pollutant stressors for which a TMDL was not required (AKA category 4C). An example might be a fish-biota impairment due to connectivity/passage issues and the strategy being dam removal or culvert modification. Per 114D.26, Subd. 1, (8) WRAPS shall “contain an implementation table of strategies and actions that are capable of cumulatively achieving needed pollution load reductions for point and nonpoint sources, including: (i) water quality parameters of concern; (ii) current water quality conditions; (iii) water quality goals and targets by parameter of concern; (iv) strategies and actions by parameter of concern and the scale of adoptions needed for each; (v) a timeline for achievement of water quality targets; (vi) the governmental units with primary responsibility for implementing each watershed restoration or protection strategy; and (vii) a timeline and interim milestones for achievement of watershed restoration or protection implementation actions within ten years of strategy adoption. Completion of this table also fulfills or partially fulfills elements a, b, c, f and g of EPA’s “Nine Minimum Elements to Be Included in a Watershed Plan…” Additional explanation of specific columns in table (see accompanying Excel spreadsheet for example content for the columns): [Watershed Name] WRAPS Report 21 Water Quality – Current Conditions: “Current” condition is interpreted as the baseline condition over some evaluation period for the pollutant or non-pollutant stressor identified in the previous column. This should be a numeric descriptor and unit of measurement. This can be a current load (from the TMDL or from the load monitoring program if pursuing a downstream goal and not a local goal), a pollutant concentration (e.g., E. coli geometric mean) or a score (e.g., IBI or Minnesota Stream Habitat Assessment (MSHA) score). In the interests of length and readability for unimpaired waters, you will need to use judgment as to which of the potentially many parameters to show. Water Quality – Goals / Targets: This should be expressed in the same terms as applied in the previous column (Current Conditions) and will generally be a load target (could be percent reduction or a load value) or a water quality concentration target. For some parameters (e.g. phosphorus reduction in a lake watershed), it may be best to use a load target. For others (e.g., E. coli) a concentration may be easier to both express (avoiding strings of scientific notation) and understand. For protection, specify a numeric goal/target if available. Water Quality – Current Conditions, Goals / Targets pertaining to downstream considerations: The WRAPS (and subsequent planning work) should be developed to not only address the goal of protecting and restoring water resources within a given Minnesota major watershed, but to also contribute to pollutant load reductions needed for downstream waters (in-state and out-of-state, e.g., Mississippi River, Lake Pepin, Gulf of Mexico). To describe a “current condition” relating to a downstream goal, consider citing the load monitoring program data (e.g., “current phosphorus load is XXXX kg/year); this will in most cases be an appropriate resolution and will fit well with a load reduction goal that can be included in the goals/targets column (e.g., 45% load reduction per Nutrient Reduction Strategy). If the reductions to address the HUC-8 impairments are sufficient to address downstream goals/targets then it’s fine to simply state that. Each watershed has a different capacity to make reductions for downstream waters, and therefore the reduction targets for downstream waters may vary. Strategies: This column is intended to provide the high-level strategies to be used for both protection and restoration. Strategies outline the method, approach or combination of approaches that could be taken to achieve water quality goals. This field is not intended to prescribe specific projects and practices (therefore, as an example, use the more general strategy of ‘Improve upland/field surface runoff controls’ rather than ‘Cover Crops’). The strategies should be briefly stated and then further described in Table 8. In these template materials, Table 8 includes an extensive list of example strategies (in the ‘Descriptions’ column) with accompanying example BMPs/actions for those strategies. To the extent possible, it is recommended that you use these strategies as described for completing Table 7 to accommodate and simplify future entry into a tracking database. However, you may certainly consider other strategies than what is listed here if appropriate. Strategy Type and Estimated Scale of Adoption Needed to Meet Final Water Quality Target: This column ties to the Strategies column and provides the basic outcome of a modeling scenario (or similar analysis) that generally describes the collective magnitude of effort (over however many years or decades) that it will take to achieve the water quality target. This estimate is meant to describe approximately “what needs to happen” but does not need to detail precisely “how” goal attainment will be achieved (the latter is left to subsequent planning steps). As such, it is acknowledged that this is an approximation only and subject to adaptive management. Detail regarding degree of implementation of [Watershed Name] WRAPS Report 22 various BMPs may be added per stakeholder design/support, as long as it is recognized that there are often many permutations of BMP implementation that constitute a goal attainment scenario. This column can reference example scenarios (e.g., “See NBMP spreadsheet tool scenarios selected by stakeholders as viable general approaches”). Interim 10-yr Milestones: This column ties to the Estimated Scale of Adoption column and should describe progress to be made toward implementing the strategy in the first 10 years from completion of the WRAPS report. This may be provided in the form of a percentage, amount, or narrative descriptor. This milestone will generally be more coincident (relative to the estimated year to achieve water quality targets) with local water planning milestones. Governmental Units with Primary Responsibility: Identify the governmental unit with primary responsibility Varying symbology in this field can be used to identify primary/secondary leadership for a given strategy. It should be noted that identifying a responsible party does not imply any newly associated or suggested authority or regulation. Symbology can also be used to describe a regulatory lead for a strategy (e.g. planning and zoning lead on buffer rule) vs a programmatic lead (e.g. cover crop promotion). Estimated Year to Achieve Water Quality Targets: This applies to the waterbody, specifically the year it is reasonably estimated that applicable water quality targets will be achieved. Explanatory information may be added either as a footnote or in the preceding narrative providing any assumptions or caveats used in the estimate. Table Formatting Considerations For ease of use and readability, it is recommended that the table be broken up by geographic area and that a map of the geographic area precede the table. This may be done by subwatershed or some other useful land management-based area. See the Sunrise River WRAPS at: http://www.pca.state.mn.us/zihya01. The table may also include rows (preferably at the top; in white) for watershed-wide strategies, addressing things like ‘social infrastructure’ (e.g., education/outreach, relationship building, demonstration projects, etc.) or wastewater permit and construction and industrial stormwater permit compliance that do not have waterbody-specific targets associated with them.] [Watershed Name] WRAPS Report 23 [include if needed] This page intentionally left blank to facilitate double-sided printing. [Watershed Name] WRAPS Report 24 Table 7: Strategies and actions proposed for the [Name] Watershed. [See Excel spreadsheet version for structure and example contents. The spreadsheet may be used for drafting purposes and then incorporated into a final PDF report] [Watershed Name] WRAPS Report 25 Table 8: Key for Strategies Column Strategy Key Parameter (incl. nonpollutant stressors) Description Improve upland/field surface runoff controls: Soil and water conservation practices that reduce soil erosion and field runoff, or otherwise minimize sediment from leaving farmland Example BMPs/actions Cover crops Water and sediment basins, terraces Rotations including perennials Conservation cover easements Grassed waterways Strategies to reduce flow- some of flow reduction strategies should be targeted to ravine subwatersheds Residue management - conservation tillage Forage and biomass planting Open tile inlet controls - riser pipes, french drains Contour farming Field edge buffers, borders, windbreaks and/or filter strips Total Suspended Solids (TSS) Stripcropping Protect/stabilize banks/bluffs: Reduce collapse of bluffs and erosion of streambank by reducing peak river flows and using vegetation to stabilize these areas. Stabilize ravines: Reducing erosion of ravines by dispersing and infiltrating field runoff and increasing vegetative cover near ravines. Also may include earthwork/regrading and revegetation of ravine. Strategies for altered hydrology (reducing peak flow) Streambank stabilization Riparian forest buffer Livestock exclusion - controlled stream crossings Field edge buffers, borders, windbreaks and/or filter strips Contour farming and contour buffer strips Diversions Water and sediment control basin Terrace Conservation crop rotation Cover crop Residue management - conservation tillage [Watershed Name] WRAPS Report 26 Strategy Key Parameter (incl. nonpollutant stressors) Description Stream Channel Restoration Example BMPs/actions Addressing road crossings (direct erosion) and floodplain cut-offs Clear water discharge: urban areas, ag tiling etc. – direct energy dissipation Two-stage ditches Large-scale restoration – channel dimensions match current hydrology & sediment loads, connect the floodplain, stable pattern, (natural designstep principals) Stream channel restoration using vertical energychannel dissipation: pool morphology Improve forestry management Proper Water Crossings and road construction Forest Roads - Cross-Drainage Maintaining and aligning active Forest Roads Closure of Inactive Roads & Post-Harvest Location & Sizing of Landings Riparian Management Zone Widths and/or filter strips Improve urban stormwater management [to reduce sediment and flow] Increase fertilizer and manure efficiency: Adding fertilizer and manure additions at rates and ways that maximize crop uptake while minimizing leaching losses to waters Nitrogen (TN) or Nitrate Store and treat tile drainage waters: Managing tile drainage waters so that nitrate can be denitrified or so that water volumes and loads from tile drains are reduced See MPCA Stormwater Manual: http://stormwater.pca.state.mn.us/index.php/Information_on_pollutant_removal_by_BMPs Nitrogen rates at Maximum Return to Nitrogen (U of MN rec's) Timing of application closer to crop use (spring or split applications) Nitrification inhibitors Manure application based on nutrient testing, calibrated equipment, recommended rates, etc. Saturated buffers Restored or constructed wetlands Controlled drainage Woodchip bioreactors Two-stage ditch Increase vegetative cover/root duration: Planting crops and vegetation that maximize vegetative cover and [Watershed Name] WRAPS Report Conservation cover (easements/buffers of native grass & trees, pollinator habitat) Perennials grown on marginal lands and riparian lands Cover crops 27 Strategy Key Parameter (incl. nonpollutant stressors) Phosphorus (TP) Description Example BMPs/actions capturing of soil nitrate by roots during the spring, summer and fall. Rotations that include perennials Improve upland/field surface runoff controls: Soil and water conservation practices that reduce soil erosion and field runoff, or otherwise minimize sediment from leaving farmland Reduce bank/bluff/ravine erosion Strategies to reduce sediment from fields (see above - upland field surface runoff) Increase vegetative cover/root duration: Planting crops and vegetation that maximize vegetative cover and minimize erosion and soil losses to waters, especially during the spring and fall. Preventing feedlot runoff: Using manure storage, water diversions, reduced lot sizes and vegetative filter strips to reduce open lot phosphorus losses Improve fertilizer and manure application management: Applying phosphorus fertilizer and manure onto soils where it is most needed using techniques that limit exposure of phosphorus to rainfall and runoff. Address failing septic systems: Fixing septic systems so that on-site sewage is not released to surface waters. Includes straight pipes. Reduce in-water loading: Minimizing the internal release of phosphorus within lakes Conservation cover (easements/buffers of native grass & trees, pollinator habitat) [Watershed Name] WRAPS Report Crop conversion to low nutrient-demanding crops (e.g., hay). Constructed wetlands Pasture management Strategies to reduce TSS from banks/bluffs/ravines (see above for sediment) Perennials grown on marginal lands and riparian lands Cover crops Rotations that include perennials Open lot runoff management to meet 7020 rules Manure storage in ways that prevent runoff Soil P testing and applying nutrients on fields needing phosphorus Incorporating/injecting nutrients below the soil Manure application meeting all 7020 rule setback requirements Sewering around lakes Eliminating straight pipes, surface seepages Rough fish management Curly-leaf pondweed management Alum treatment 28 Strategy Key Parameter (incl. nonpollutant stressors) Description Example BMPs/actions Lake drawdown Hypolimnetic withdrawal Improve forestry management See forest strategies for sediment control Reduce Industrial/Municipal wastewater TP Municipal and industrial treatment of wastewater P Treat tile drainage waters: Treating tile drainage waters to reduce phosphorus entering water by running water through a medium which captures phosphorus Improve urban stormwater management Phosphorus-removing treatment systems, including bioreactors Reducing livestock bacteria in surface runoff: Preventing manure from entering streams by keeping it in storage or below the soil surface and by limiting access of animals to waters. Strategies to reduce field TSS (applied to manured fields, see above) Improved field manure (nutrient) management Upgrades/expansion. Address inflow/infiltration. See MPCA Stormwater Manual: http://stormwater.pca.state.mn.us/index.php/Information_on_pollutant_removal_by_BMPs Adhere/increase application setbacks Improve feedlot runoff control Animal mortality facility Manure spreading setbacks and incorporation near wells and sinkholes E. coli Rotational grazing and livestock exclusion (pasture management) Reduce urban bacteria: Limiting exposure of pet or waterfowl waste to rainfall Address failing septic systems: Fixing septic systems so that on-site sewage is not released to surface waters. Includes straight pipes. [Watershed Name] WRAPS Report Pet waste management Filter strips and buffers See MPCA Stormwater Manual: http://stormwater.pca.state.mn.us/index.php/Information_on_pollutant_removal_by_BMPs Replace failing septic (SSTS) systems Maintain septic (SSTS) systems 29 Strategy Key Parameter (incl. nonpollutant stressors) Dissolved Oxygen Description Example BMPs/actions Reduce Industrial/Municipal wastewater bacteria Reduce straight pipe (untreated) residential discharges Reduce WWTP untreated (emergency) releases Reduce phosphorus Increase river flow during low flow years See strategies above for reducing phosphorus See strategies above for altered hydrology In-channel restoration: Actions to address altered portions of streams. Goal of channel stability: transporting the water and sediment of a watershed without aggrading or degrading. Restore riffle substrate Road salt management [Strategies currently under development within Twin Cities Metro Area Chloride Management Plan] Increase living cover: Planting crops and vegetation that maximize vegetative cover and evapotranspiration especially during the high flow spring months. Grassed waterways Cover crops Chloride Conservation cover (easements & buffers of native grass & trees, pollinator habitat) Rotations including perennials Altered hydrology; peak flow and/or low base flow (Fish/Macroinvertebrate IBI) Improve drainage management: Managing drainage waters to store tile drainage waters in fields or at constructed collection points and releasing stored waters after peak flow periods. Reduce rural runoff by increasing infiltration: Decrease surface runoff contributions to peak flow through soil and water conservation practices. Improve urban stormwater management [Watershed Name] WRAPS Report Treatment wetlands Restored wetlands Conservation tillage (no-till or strip till w/ high residue) Water and sediment basins, terraces See MPCA Stormwater Manual: http://stormwater.pca.state.mn.us/index.php/Information_on_pollutant_removal_by_BMPs 30 Strategy Key Parameter (incl. nonpollutant stressors) Description Groundwater pumping reductions and irrigation management Improve riparian vegetation: Planting and improving perennial vegetation in riparian areas to stabilize soil, filter pollutants and increase biodiversity 50' vegetated buffer on waterways Poor Habitat (Fish/Macroinvertebrate IBI) Water Temperature Connectivity (Fish IBI) Example BMPs/actions Improve irrigation water management: Increase groundwater contributions to surface waters by withdrawing less water for irrigation or other purposes. One rod ditch buffers Lake shoreland buffers Increase conservation cover: in/near water bodies, to create corridors Improve/increase natural habitat in riparian, control invasive species Tree planting to increase shading Streambank and shoreline protection/stabilization Wetland restoration Accurately size bridges and culverts to improve stream stability Restore/enhance channel: Various restoration efforts largely aimed at providing substrate and natural stream morphology. Retrofit dams with multi-level intakes Urban stormwater management See MPCA Stormwater Manual: http://stormwater.pca.state.mn.us/index.php/Information_on_pollutant_removal_by_BMPs Riparian vegetative buffers Improve riparian vegetation: Actions primarily to increase shading, but also some infiltration of surface runoff. Remove fish passage barriers: Identify and address barriers. [Watershed Name] WRAPS Report Restore riffle substrate Two-stage ditch Dam operation to mimic natural conditions Restore natural meander and complexity Tree planting to increase shading Remove impoundments Properly size and place culverts for flow and fish passage 31 Strategy Key Parameter (incl. nonpollutant stressors) Description Example BMPs/actions Construct by-pass All [protection-related] Implement volume control / limitedimpact development: This is aimed at development of undeveloped land to provide no net increase in volume and pollutants [Watershed Name] WRAPS Report See MPCA Stormwater Manual: http://stormwater.pca.state.mn.us/index.php 32 4. Monitoring Plan [Per 114D.26, Subd. 1, (7) WRAPS shall “contain a plan for ongoing water quality monitoring to fill data gaps, determine changing conditions, and gauge implementation effectiveness.” In addition to specific local monitoring efforts this section can outline the MPCA’s major watershed outlet monitoring program, which will provide a long-term, ongoing data record. Element ‘h’ of EPA’s “Nine Minimum Elements to Be Included in a Watershed Plan…” calls for “A set of criteria that can be used to determine whether loading reductions are being achieved over time and substantial progress is being made towards attaining water quality standards.” EPA’s guidance indicates using water quality “benchmarks or waypoints to measure against through monitoring (e.g., direct measures like fecal coliform concentrations or indirect measures like # of beach closings).” This generally translates to listing the parameter, implementation phases/years, and parameter concentration to be achieved (e.g., TP: year 10 = 80 µg/L; year 20 = 70 µg/L; etc.). This could get unwieldy given the many parameters covered and varying starting points for the many waterbodies in a watershed. Therefore, it may be preferable to use an approach and narrative as indicated below to meet this element:] It is the intent of the implementing organizations in this watershed to make steady progress in terms of pollutant reduction. Accordingly, as a very general guideline, progress benchmarks are established for this watershed that assume that improvements will occur resulting in a water quality pollutant concentration decline each year equivalent to approximately [one] percent of the starting (i.e., longterm) pollutant concentration. For example, for a lake with a long-term growing season total phosphorus concentration of 90 µg/L, by year 10 it would be 90 – (10 * 0.9) = 81 µg/L. [If the pace varies by parameter then expand this accordingly.] Again, this is a general guideline. Factors that may mean slower progress include limits in funding or landowner acceptance, challenging fixes (e.g., unstable bluffs and ravines, invasive species) and unfavorable climatic factors. Conversely, there may be faster progress for some impaired waters, especially where high-impact fixes are slated to occur. [Note: WRAPS authors should consider project modeling/scenario information and also review relevant statewide efforts, e.g., Minnesota Nutrient Reduction Strategy, to align any implementation pacerelated information from these efforts with water quality projections in this section. Element ‘i’ of EPA’s “Nine Minimum Elements to Be Included in a Watershed Plan…” calls for “A monitoring component to evaluate the effectiveness of the implementation efforts over time, measured against the criteria established under item (h).” Both local and PCA-led monitoring outlined here should address this element.] [Watershed Name] WRAPS Report 33 5. References and Further Information [Include any references cited in the text such as stressor ID reports, monitoring and assessment reports, TMDLs, documentation for tools and implementation strategies.] [Watershed Name] Reports All [watershed name] reports referenced in this watershed report are available at the [watershed name] Watershed webpage: [insert link to watershed from http://www.pca.state.mn.us/index.php/water/water-typesand-programs/watersheds/watershed-overview-map.html ] [Watershed Name] WRAPS Report 34 Appendix [Watershed Name] WRAPS Report 35 EPA 319 NINE ELEMENTS SUMMARY: GUIDANCE FOR WRAPS TEMPLATE EPA requires that applications for 319 grants be based on watershed plans that address the nine elements described below. This is from guidance found on EPA’s website at: http://water.epa.gov/polwaste/nps/upload/2008_04_18_NPS_watershed_handbook_ch02.pdf (see section 2.6). Element # A Element Description An identification of the causes and sources or groups of similar sources that will need to be controlled to achieve the load reductions estimated in this watershed-based plan (and to achieve any other watershed goals identified in the watershed-based plan), as discussed in item (b) immediately below. Sources that need to be controlled should be identified at the significant subcategory level with estimates of the extent to which they are present in the watershed (e.g., X numbers of dairy cattle feedlots needing upgrading, including a rough estimate of the number of cattle per facility; Y acres of row crops needing improved nutrient management or sediment control; or Z linear miles of eroded streambank needing remediation). Section 2.3 Stressors and Sources should provide the general source ID information needed. Section 3.3 Restoration & Protection Strategies provides more source specific subcategory type of information. An estimate of the load reductions expected for the management measures. Section 3.3 Restoration & Protection Strategies should provide source specific reduction information. A description of the NPS management measures that will need to be implemented to achieve the load reductions under paragraph (b) above (as well as to achieve other watershed goals identified in this watershed-based plan), and an identification (using a map or a description) of the critical areas in which those measures will be needed to implement this plan. Section 3.3 Restoration & Protection Strategies and Section 3.1 Targeting of Geographic Areas should provide this via the strategies table and supporting maps/GIS tools showing critical areas. B C WRAPS section where addressed [Watershed Name] WRAPS Report Notes EPA guidance says the plan should include a map “that locates the major causes and sources of impairment.” Guidance also states, “If a TMDL exists, this element may be adequately addressed.” 36 Element # D E Element Description An estimate of the amounts of technical and financial assistance needed, associated costs, and/or the sources and authorities that will be relied upon to implement this plan. Section 3 Prioritizing and Implementing Restoration and Protection should address this. Reference to cost estimates in TMDLs should also be cited. An information/education component that will be used to enhance public understanding of the project and encourage their early and continued participation in selecting, designing, and implementing the NPS management measures that will be implemented. Section 3.2 Civic Engagement A schedule for implementing the NPS management measures identified in this plan that is reasonably expeditious. Section 3.3 Restoration & Protection Strategies Interim 10-year milestones in Strategies table likely address this. A description of interim, measurable milestones for determining whether NPS management measures or other control actions are being implemented. Section 3.3 Restoration & Protection Strategies Interim 10-year milestones in Strategies table likely address this. A set of criteria that can be used to determine whether loading reductions are being achieved over time and substantial progress is being made towards attaining water quality standards. Section 4 Monitoring F G WRAPS section where addressed H [Watershed Name] WRAPS Report Notes Based on one recent EPAapproved plan (Bad Axe River, MI), it appears acceptable to focus narrative on the available funding sources and organizations that could provide technical assistance. EPA guidance indicates using water quality “benchmarks or waypoints to measure against through monitoring (e.g., direct measures like fecal coliform concentrations or indirect measures like # of beach closings).” This generally translates to listing the parameter, implementation phases/years and parameter concentration to be achieved (e.g., TP: year 10 = 80 µg/L; year 20 = 70 µg/L; etc.). This could get unwieldy given the many parameters covered and varying 37 Element # I Element Description A monitoring component to evaluate the effectiveness of the implementation efforts over time, measured against the criteria established under item (h) immediately above. [Watershed Name] WRAPS Report WRAPS section where addressed Section 4 Monitoring Notes starting points for the many waterbodies in a watershed. Therefore, see the alternative approach/narrative in Section 4. This element is to be integrated with element I below. Per EPA guidance, this is intended to be watershed-scale monitoring and not monitoring for individual BMPs. Both local and PCA-led monitoring (i.e., HUC-8 pour point continuous monitoring and 10-year IWM cycle) should be described. 38
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