LAKE SHAMINEAU LAKE IMPROVEMENT DISTRICT

Agency and Public Comments on the EAW

In the matter of the Determination of

The Need for an Environmental
Impact Statement for the Lake Shamineau
High-Water Control Project

April 2020
 Lake Shamineau Lake Improvement District
Environmental Assessment Worksheet Comments
February 24, 2020 through March 25, 2020

Date Person(s) or Entity

1 March 2 Ron Carlson
2 March 5 Lisa and Ryan Dahl
3 March 14 Don Anderson
4 March 17 Crookneck Lake Improvement District Board
of Directors, Dan Seanger, David Gurney
5 March 19 Dan Whitney, Norm Krause, Sharda and
Morris Powell
6 March 21 Debra Nelson, Arlo Rohl, Wanda Bell, Bonita
Sarazin, Roy Rohl, Sharon Rohl, Norman Rohl,
Betty Rohl
7 March 24 Rohl Family Trust, Ellen Noreen, Laural Park,
Gwentha Lumsden
8 March 25 Eugene Rohl
9 March 25 Dave and Nancy Deedrick
10 March 25 Bill Peterson
11 March 25 Shannon Wettstein, Morrison County Soil
and Water
12 March 25 Melissa Collins, MN Department of Natural
Resouces
13 March 23 Sarah J. Beimers,
Minnesota State Historic Preservation Office

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From: Don Anderson <ddander@gmail.com>
Sent: Saturday, March 14, 2020 5:12 PM
Subject: Reference: Environmental Assessment Worksheet Availability: Lake Shamineau High Water
Project

To: Rick Rosar, LSLID EAW Manager, Lake Shamineau Lake Improvement District (Responsible
Governmental Unit)
Reference: Environmental Assessment Worksheet Availability: Lake Shamineau High Water Project
Dated: February 24, 2020

Comment 1: We do not believe that the issue of Water Resources has been adequately assessed. In
section 11.a.ii and Appendix L the only wells that have been identified are those from the MDH Minnesota
Well Index website. If we are to believe the EAW there is no affect on the nearby wells because all those
listed on the MDH website would be considered deep wells.

What is intentionally left out of this EAW is that there are approximately 8-10 shallow wells in the adjacent
properties that could seriously be affected with this project and the dewatering that has to take place
during construction.

Comment 2: There currently is no official property lines and survey markers identified on the
property or the property to know that the construction will take place within the official easement
boundaries or if they will encroach on neighboring properties such as ours.

We request that an official survey and appropriate markers be included in the project along our property
line every 16 feet to ensure that proper setbacks and property rights are maintained along our property
line.

Comment 3: We are concerned that mature trees and tree roots along our property line will be damaged
by the trenching of the force main so close to our property line. Mature 50-150 year old trees and trees
roots that are damaged by trenching can not be replaced by new seedlings or replanting.

Therefore we request that the force main be moved further south, away from the property line, by 20
feet. This would help ensure the preservation of our existing trees and provide a more adequate buffer
of tree and vegetation between the force main and adjacent properties such as ours.

Don Anderson
612-817-2797
Ddander@gmail.com

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 Public Comment Response
To: Environmental Assessment Worksheet
For: Lake Shamineau High Water Project
Report Date: February 2020
Response Date: March 19, 2020

Comments and Reviews by:

Dan Whitney, P.G. Norm Krause Sharda and Morris Powell

Principal Hydrogeologist 43035 County Road 21 5896 Birch Road
Northwest AqwaTek Solutions Staples, Minnesota Motley, Minnesota
219 Bryant Avenue SE
Wadena, Minnesota

Introduction: This document is divided into two sets of responses, General and Technical. The first set
provides an overall view of the conceptual model for addressing the purpose of the project, that being:
to dispose of excess water from Lake Shamineau via an intake structure that pumps water through a
pipeline approximate 1.5-miles to the east and discharges it into two infiltration basins from which the
water will flow through the underlying sediments, into the underlying groundwater aquifer system and
out through Stanchfield Lake. The technical set of responses provides a detailed evaluation of the
information provided in the EAW with respect to the level of understanding of the hydrogeologic
aspects of the project.

As a summary statement of our review, this project has the potential to adversely impact downgradient
wetlands, the water quality of nearby domestic wells, the future current use (“farmability”) of nearby
farmland, and the safety and welfare of the public. The latter results from the potential of substantially
increasing the elevation of the groundwater to a level that may cause hydrologic downgradient
saturation of the slopes in vicinity of Round Lake and its adjacent wetland. Also, there appears to be a
significant level of disregard to the environment and nearby landowners based on the number of
inconsistencies presented in the EAW and its supporting documents respective of the local
hydrogeology and the lack of data that is necessary to develop a sound understanding of the potential
adverse impacts from the proposed changes to the groundwater flow system.

General Response:

The overall success of the project hinges on the ability of the unsaturated zone and underlying aquifer
system to convey the infiltrated water away from the basins and ultimately into Stanchfield Lake via
groundwater baseflow. The proposed average operational discharge rate into the basins is 3,200 gallons
per minute (gpm) over a continuous period of at least 150 days per year for a minimum of two years.
Consequential volumes equate to approximately 4.6 million gallons per day, 691,200,000 (million)
gallons per year and a two-year total of approximately 1.38 billion gallons of lake water introduced to
the aquifer system. As a comparative side note, a center pivot irrigation system operating on a 160-acre

EAW Comments Page 13 April 10, 2020

 field in sandy soil uses approximately 23 million gallons of groundwater annually which is equivalent to
only 5 days of continuous pumping of lake water into the basins.

Consequently, the aquifer system that occurs between the infiltration basins and Lake Stanchfield is
presumed (vs known) by the project proposer to have the matrix characteristics (i.e., porosity,
permeability, homogeneity) necessary to effectively incorporate the water that recharges the
groundwater system and transmit it toward and into the base of Lake Stanchfield. However, the basic
hydrogeology of the local aquifer system such as direction of groundwater flow, physical characteristics
(i.e., total thickness, hydraulic conductivity, transmissivity, storativity), aquifer type (confined or
unconfined (water table)) and depth to groundwater in vicinity of the basins has not been fully
characterized. Also, the potential overall changes in the direction of groundwater flow from the
mounding of the groundwater beneath the basins is not presently understood to the degree necessary
to assess the successful functionality of the basins.

Therefore, the current understanding of the groundwater flow system in our opinion is at a rudimentary
conceptual level at best versus one that is necessary to understand and adequately assess the resulting
effects to the aquifer from the addition of 4.6 million gallons per day or 691,200,000 gallons per year of
lake water. And lastly, the geochemical changes that will occur to the groundwater quality as a result of
adding Lake Shamineau water to the aquifer needs to be addressed by the proposer in order to evaluate
the potential for significant environmental impacts to the ecosystems of the downgradient wetlands and
lakes, and the aquifer which serves as the sole source of drinking water for nearby residents.

Technical Comments:

Comment 1) Reference to: EAW Page 4.

On page 4 it states, “The groundwater table beneath the infiltration basins is 30 to 40 feet below the
surface. As water is infiltrated, it will cause groundwater mounding of 10 to 20 feet above the water
table surface in the immediate area of the infiltration basins. Because the groundwater is at an
average elevation of 1266 beneath the basins, it will not flow back to Lake Shamineau because Lake
Shamineau is over 10 feet higher in elevation at 1277.52.” Additionally, the EAW states that “the
infiltrated water will ultimately flow with groundwater to Stanchfield Lake, which has a flow out
elevation of 1255.22 …”

Summary Finding: The resulting groundwater mounding has the potential to change the direction of
groundwater flow toward Lake Shamineau and other nearby surface waters.

A hydrologic contradiction occurs among the referenced statements. For example, if the natural
elevation of the groundwater is at 1266 feet mean sea level (ft msl) beneath the basins, and the
estimated groundwater mounding beneath the basins is up to 20 feet, then 1266 feet + 20 feet
equals 1288 ft msl which is a higher elevation than 1277.52 (Lake Shamineau Elev.).

Furthermore, the goal of the project is to lower the lake level to the ordinary high water level
(OHWL) which is 1275.1 ft msl. At the lower end of the predicted range of mounding, that being 10
feet, 1266 ft msl + 10 feet of mounding equates to 1276 ft msl which is also higher than the OHWL
of 1275.1 ft msl. Consequently, the elevation values provided in the EAW suggest that the
groundwater mound has the potential to cause the infiltrated water to flow back to Lake
Shamineau. Also, it is important to note that no reference to the mounding calculations is presented
EAW Comments Page 14 April 10, 2020
 in the EAW.
In addition, the EAW states on page 4 that “The groundwater mounding will likely result in higher
water levels in the wetland east of the infiltration basins which is at an elevation of
approximately 1261 feet about NGVD 29.” But with the peak elevation of the mound being higher
than the baseline elevations of the groundwater flow system, the groundwater will flow in all
directions and likely result in higher water levels in all the nearby surface water bodies.

Comment 2) Reference to: Appendix B (Hydrogeologic Investigation Report, Lake Shamineau High
Water Project, Morrison County, Minnesota) and Appendix C (New Infiltration Area Characteristics
Memo, To: Cindy Kavern (LSLID), From: Brian Ross, P.G. (WSN), February 18, 2020).

Summary Finding: The type of aquifer and the thickness of the aquifer has not been defined.

It's important to note that the EAW and its supporting documents do not discuss the total thickness
of the aquifer or describe the aquifer as unconfined or confined within the area between Lake
Shamineau and Lake Stanchfield; however, the term “water table” is occasionally used in the
document. The cross-sections presented in Appendix B (Hydrogeologic Investigation Report, Lake
Shamineau High Water Project, Morrison County, Minnesota) illustrate both confined and
unconfined conditions.

The boring presented in Appendix C (New Infiltration Area Characteristics Memo, To: Cindy Kavern
(LSLID), From: Brian Ross, P.G. (WSN), February 18, 2020) suggests that the aquifer is unconfined
beneath the infiltration basins. All the borings presented in the EAW terminate in sand; therefore,
true thickness of the aquifer has not been established.

Also, no high capacity (several hundred gpm) several-day aquifer test has been conducted in vicinity
of the infiltration basins and Lake Stanchfield which is necessary to determine the hydraulic
conductivity (horizontal), transmissivity and storativity of the aquifer system.

Comment 3) Reference to the statement on Page 4 of the EAW, “As water is infiltrated, it will cause
groundwater mounding of 10 to 20 feet above the water table surface in the immediate area of the
infiltration basins.”

Summary Finding: No methodology or specifics of the hydrologic parameters used by the proposer to
predict the height of the groundwater mound beneath the basins is provided in the EAW.

With respect to the groundwater mounding estimate, an analytical model was used to “cross-check”
the representativeness of these values as it intuitively appears to be on the low end when
considering a recharge of approximately 700 million gallons of water per year into the aquifer. The
model is a spreadsheet application of the Hantush (1967) analytical equation that was developed by
G.B. Carleton (2010) and presented in Simulation of Groundwater Mounding Beneath Hypothetical
Stormwater Infiltration Basins: U.S. Geological Survey Scientific Investigations Report 2010–5102, 64
p.

Based on all the boring logs presented in the EAW, a conservative estimate for the average thickness
of the aquifer is 70 feet. Based on the boring log from beneath the infiltration basins, a conservative
estimate for the hydraulic conductivity is 85 feet/day and storativity is 0.20. The boring log reveals
silty sand at a depth of approximately 5 feet below the groundwater level and a thickness of

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 approximately 17 feet. A hydraulic conductivity of 85 feet/day is in the upper range of such values
for silty sand. The combined average approximate dimensions of the basins are 1080 feet long by
300 feet wide. When using these dimensions along with an aquifer thickness of 70 feet, hydraulic
conductivity of 85 feet/day, storativity of 0.20 (dimensionless), infiltration (recharge) rate of 2.2
feet/day, and a constant influx period of 150 days, use of the Carleton (2010) spreadsheet model
produces a groundwater mound of approximately 40 feet. Depending on the actual elevation of the
groundwater level (see comment #4), a mound of 40 feet will result in the groundwater being just
slightly below, or several feet above the base of the infiltration basin.

The point of the above modeling exercise is to reveal the importance of presenting the methodology
and hydrologic parameters used by the proposer to predict the height of the mound that may occur
beneath the basins from the continuous introduction of lake water over a period of at least 150
days. Furthermore, due to the homogenous assumptions of the analytical model, a more
complicated model, such as one that is based on a finite-difference or finite element discretization is
recommended to best represent the existing and mounded hydrogeologic conditions. Also, it’s
important to consider that Carleton (2010) found that a “comparison of results of finite-difference
simulations of a multi-layer system that includes a vertical component of flow in the saturated zone
with the results from the analytical equation indicates that the horizontal-flow-only assumption in
the analytical equation can cause an under-prediction of the maximum height of a groundwater
mound by as much as 15 percent.” Consequently, use of a more rigorous and refined model for
predicting groundwater mounding may result in a mound height of 46 feet using parameters similar
to those that were used for the analytical simulation.

Comment 4) Reference to: Appendix C (New Infiltration Area Characteristics Memo, To: Cindy
Kavern (LSLID), From: Brian Ross, P.G. (WSN), February 18, 2020) and Figure 6 of Appendix B
(Hydrogeologic Investigation Report, Lake Shamineau High Water Project, Morrison County,
Minnesota)

Summary Finding: The basics of the groundwater flow system such as groundwater elevation and
flow are not well understood by the proposer.

Figure 6 of the Hydrogeologic Investigation Report (Appendix B) shows a groundwater elevation of

1273.27 ft msl in well PZ-3. That elevation is explained as perhaps representing the water level in a
perched aquifer. The groundwater contour line at the location of the infiltration basins is shown at
approximately 1264 msl. In addition, page 11 of the EAW, states, “At the infiltration basins, the
groundwater table is 45 feet below the surface at an elevation of approximately 1264 feet above
NGVD 29, with a groundwater flow gradient to the northeast toward Stanchfield Lake.”

The ground elevation shown on the boring log in Appendix C is listed at 1298.43 feet msl. The
accompanying memo states that “the water level measured in the boring was at a depth of 42.9
feet”. The boring log shows the corresponding water level at that depth. Based on this information,
the elevation of the groundwater beneath the proposed basins appears to be at 1255.53 (1298.43
feet – 42.9 feet) which is 9 feet below the elevation of 1264 msl.

Assuming the bottom of the basins will be slightly below 1298 feet msl upon construction, a 40 feet
resulting mound starting with a base elevation of 1264 feet would result in a top groundwater
mound elevation of approximately 1304 feet msl which is approximately 6 feet over the bottom of

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 the proposed basins. Such an elevation would result in excessive seepage and flooding of the
adjacent farm fields. However, at a groundwater elevation of 1255.53, a 40 feet high mound would
result in the groundwater being at or just below the basins assuming that two feet of the surficial
silty sand will be scraped back and used for the berm construction, as suggested in the EAW. Such a
mound elevation would, at minimum, saturate the root zone of the soils of the adjacent farm fields.
Regardless of the situation, the inconsistencies in the groundwater elevations beneath the basins
conveys a lack of a thorough evaluation of the existing groundwater flow system of the area.

Furthermore, the groundwater contour lines presented in Figure 6 reveal that the direction of
groundwater flow beneath the area of the proposed basins is to the east, which is south of
Stanchfield Lake, and not to the northeast toward Stanchfield lake. Most peculiar is a groundwater
flow arrow that occurs on the east side of the wetland that is just north of Round Lake. The arrow
points in the direction of Stanchfield Lake, but it is not perpendicular to the lines of equipotential
(equal hydraulic head; groundwater contours). One of the basic principles of groundwater flow is
that groundwater flows perpendicular (90 degrees) to the equipotential surface. Interestingly,
Figure A of Appendix C dated August 2019, no longer shows that arrow but shows another flow
arrow that points slightly to the northeast. The EAW is dated February 2020, yet there is no mention
in the writeup of the change in the depicted flow direction which suggests that the basics of the
groundwater flow system are not well understood by the proposer.

Comment 5) Reference to: Page 11 statement that “An updated Groundwater Contour Map that
includes water level readings from last summer is included as Appendix K”; Figure A (Appendix K)
Groundwater Contour Map, Widseth Smith Nolting, August 2019; and Figure 6 (Groundwater
Contour Map) of Appendix B (Hydrogeologic Investigation Report, Lake Shamineau High Water
Project, Morrison County, Minnesota).

Summary Finding: The presentation of three different groundwater elevation values beneath the
infiltration basins convey a certain level of ineptness and disregard toward understanding the
hydrogeology of the area.

The hydrogeologic investigation report provided in Appendix B provides a groundwater contour map
shown as Figure 6 (May 2019) (see attachment to this document). The contour map shows elevation
readings for several surface water features and four groundwater level monitoring wells: OB-1, PZ-1,
PZ-2, and PZ-3. Also, the contours appear to be computer generated being that there is a 90-degree
angle within the 1266 elevation contour line. The groundwater elevation shown for PZ-3 in Figure 6
is 1273.27 ft msl. Yet, the well is located approximately 250 feet north of the proposed infiltration
basins and situated between the 1264 and 1265 groundwater elevation contours; therefore, it is out
of place.

The hydrogeologic investigation report, which is referenced on the last page as being prepared by
Brain Ross, P.G., Widseth Smith Nolting, May 29, 2019, addresses this anomaly by stating in page 8
of the report,

“The elevations of the water levels agree with the wells being screened in the regional surficial
aquifer ranging from 1268.0 in PZ-2 to 1267.09 in OB-1, except for PZ-3, which has an elevation
1273.27. It appears that PZ-3 is screened in a perched water table because it has an elevation of
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 11 to 12 feet above the regional water table.”
In addition, cross-section B-B’ (Figure 5) of the hydrogeologic investigation report shows the
extensive clay layer present in the well to the east (unique well #650796) pinching out beneath PZ-3
suggesting the premise of a perched water table.

However, on Page 10 of the EAW which was prepared February 2020 (WSN No. 2019-13011), it
states,

“Because of the ubiquitous sand and gravels in the area, there are no perched water-tables and
no springs or seeps, except along the edges of the lakes an[d] wetlands in the area…”.

Therefore, a contradiction of the hydrogeologic conceptualization of the aquifer system occurs

between the hydrogeologic investigation report, the accompanying geologic cross-section and the
EAW.

The contradiction is further exasperated by comparing the groundwater contour map of Figure 6 to
the groundwater contour map of Figure A (Appendix K) (see attachment to this document). Figure 6
(May 2019) shows the groundwater elevations in OB-1 as 1267.09 ft msl, PZ-1 as 1267.32 ft msl, PZ-
02 as 1268.00 ft msl and PZ-3 as 1273.27 ft msl. Figure A (dated August 2019) shows the
groundwater elevations of these same wells as follows: OB-1 – 1267.1 (rounding up from 1267.09);
PZ-1 - 1267.3 (rounding down from 1267.32); PZ-02 - 1268.0 (rounding across from 1268.00); and
PZ-03 – 1264.4 (change from 1273.27) which is a decrease in elevation of 8.87 feet from the May
2019 reading. Every groundwater elevation value presented in Figure 6 is the same (or a rounded
version of) as those presented in Figure A, except for the added elevations of the surface water
bodies that are approximately 0.5 miles north of OB-1 and PZ-1.

The Information box of Figure A specifically states that the “initial groundwater/lake level
measurements are from 5/15/19 to 5/24/19”. It is unclear why the May 2019 groundwater
elevations of the four observation wells were rounded to the nearest 10th of a foot in Figure A as no
write-up accompanies Figure A. It is even more unclear why the groundwater elevation of PZ-3 was
changed from 1273.27 ft msl to 1264.4 ft msl between May 2019 and August 2019 other than the
1264.4 fits between the groundwater flow contours of 1264 and 1265 versus the original elevation
of 1273.27 ft msl. Furthermore, a reduction in elevation of 8.87 feet at PZ-3 contradicts the
hydrogeologic investigation report which states PZ-3 is screened in a perched water table and show
a cross-section with a clay layer pinching at the location of PZ-3.

When comparing the groundwater elevation data provided in the EAW and its supporting
documents, the groundwater beneath the basins is either at an elevation of 1273.27 ft msl, 1264.4 ft
msl, or 1255.53 ft msl depending on what document the reviewer is assessing. It is the opinion of
the reviewers that such a contradiction in values conveys a certain level of ineptness and disregard
toward having a technically sound understanding of the hydrogeology of the area prior to suggesting
the disposal of lake water into the proposed infiltration basins. Furthermore, the variability in the
referenced elevation values warrants a rigorous inquiry of the project proposer to the reasons for
the change in groundwater elevations from one document to the next.

Comment 6) Reference to: Appendix C (New Infiltration Area Characteristics Memo, To: Cindy
Kavern (LSLID), From: Brian Ross, P.G. (WSN), February 18, 2020).

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Summary Finding: A clay layer exists within the aquifer of the area contrary to the statement that
well drillers misidentified it supporting the need for an extensive hydrogeologic study of the area by
the proposer.

On page 1 of the referenced memo, the following statements are provided:

“The geologic boring results in some reinterpretation of the geology of the area as many of the
drilling logs in the area indicate clay near the surface and as a confining layer at 30 to 60 feet
below the surface. Based on the geologic boring and geotechnical borings in and near the
infiltration area, the clay layer was misidentified by the well drillers and is actually a silty sand
layer. This misidentification can easily happen when well drillers are using mud rotary drilling in
unsaturated materials. The lack of clay layers means there is more groundwater flow and
communication between the deeper groundwater and the surficial groundwater, which has
implications for the groundwater modeling and flow characteristics from the infiltration.”

A review of four well and boring reports of wells drilled within a radial distance of approximately
2,500 feet from the proposed infiltration basins reveals the presence of a 40 feet thick layer to the
southwest, a 30 feet thick clay layer to the southeast, a 100 feet thick clay layer to the northeast and
a 63 feet thick clay layer to the west. Two of the drillers of the four wells,
were contacted by phone March 13, 2020 to discuss the representativeness of the well logs with
respect to the presence of the clay layers.

stated that he is confident of his interpretation of being in clay when drilling with mud
rotary by the way the tension cable reacts, observed mud viscosity and pressure differences, and
that he collects a sieve and bag sample of the drill cuttings every one foot of depth. stated that
he knows that he is in clay by the way the rig responds, the amount of water encountered and by
the drill cuttings. They both stated that they are confident that clay layers exist in the aquifer system
to the east of Lake Shamineau and south of the infiltration basins. also stated that he believes
that the groundwater flows to the south in the direction of Round lake.

Therefore, these drillers disagree with the statement that the clay layer was misidentified and is
actually a silty sand layer and emphasized that a clay layer exists within the aquifer system of the
area. This certainty further suggests that the project proposer lacks a thorough understanding of the
aquifer system (i.e., confined, unconfined, semi-confined) which in turn justifies the need for an
extensive hydrogeologic study of the area.

Comment 7) Reference to item 10a of the EAW: 10. Geology, soils and topography/land forms: a.
Geology - Describe the geology underlying the project area and identify and map any susceptible
geologic features such as sinkholes, shallow limestone formations, unconfined/shallow aquifers, or
karst conditions. Discuss any limitations of these features for the project and any effects the project
could have on these features. Identify any project designs or mitigation measures to address effects
to geologic features.

Summary Findings: The introduction of Lake Shamineau water into the aquifer has the potential
to adversely affect the quality of the groundwater and therefore, negatively impact the drinking
water quality and irrigation water of nearby landowners. The project also has the potential to
adversely affect the water quality of the nearby surface water bodies.
The EAW content of item 10a provides a description of the geology and the potential limiting effects
of the silts and clays but does not mention any effects the project may have on the
unconfined/shallow aquifers. As stated above, the boring log and memo provided in Appendix C
 states that sand, gravel and silty sand was encountered in the area of the proposed infiltration
basins and that the water level measured in the boring was at a depth of 42.9 feet. Therefore, due
to the lack of a confining clay layer, the aquifer is presumed to be unconfined in the immediate
vicinity of the infiltration basins.

As previously stated, the project entails removing excess water from Lake Shamineau and
discharging it into two infiltration basins. MN State Statute 103H.001 “Degradation Prevention Goal”
states that it is the goal of the state that groundwater be maintained in its natural condition, free
from any degradation caused by human activities.” Yet the quality of the groundwater both in terms
of background conditions and the potential changes to it from the introduction of lake water is not
discussed in the EAW. It is important to note that the aquifer is the sole source of drinking water for
many of the domestic residents in the area. The following website,
https://www.epa.gov/uic/aquifer-recharge-and-aquifer-storage-and-recovery, provides insight to
the potential adverse effects that the lake water may have on the quality of the groundwater
downgradient of the infiltration basins, especially when considering the change in direction of
groundwater flow that will occur from the mounding beneath the basins.

The refenced EPA website provides the following statements:

a) No owner or operator shall construct, operate, maintain, convert, plug, abandon, or conduct any
other injection activity in a manner that allows the movement of fluid containing any
contaminant into underground sources of drinking water, if the presence of that contaminant
may cause a violation of any primary drinking water regulation under 40 CFR part 142 or may
otherwise adversely affect the health of persons. (40 CFR 144.12L)
b) Metals and radionuclides may be mobilized from the rock depending on the chemistries of the
injected water and the aquifer. Differences in pH and reduction-oxidation potential between the
injected water and aquifer may cause arsenic, iron, manganese, or radionuclides that are
present in the rock to dissolve into USDW [drinking water].
c) Pathogens may enter aquifers if water is not disinfected prior to injection.
d) EPA is aware of some ASR [aquifer storage] operations that have exceeded the National Primary
Drinking Water Regulations for arsenic and the National Secondary Drinking Water Regulations
for iron and manganese.

The following website from the Minnesota Pollution Control Agency,

https://stormwater.pca.state.mn.us/index.php/Stormwater_infiltration_and_groundwater_mounding,
states that, “Groundwater mounds may also affect local hydraulic gradients and mobilize contaminants
that are in soil or groundwater.” The EAW states that the area where the proposed infiltration basins
will be sited consists of farmland and a mixed wooded/grassland area. The use and application of
agrichemicals is an integral component of modern-day farming operations. With respect to fertilizer use,
the potential for nitrate to leach beyond the crop root zone due to overwatering and consequently,
saturation of the soil has been examined in several U of M nutrient and irrigation management studies
and demonstration projects. Therefore, the potential that utilizing the infiltration basins will saturate
the soils as a result of the mounding and inhibit nutrient uptake by the crops in the adjacent farm fields
warrants further consideration by the project proposer of the potential water quality impacts to
domestic wells.

The potential change in water quality to the groundwater and drinking water of downgradient irrigation

EAW Comments Page 20 April 10, 2020

and domestic wells, respectively, is further exemplified by an article in the Morrison County Record by
(November 2, 2019) titled, “Lake Shamineau’s Rising Water Levels a Living Nightmare for
Homeowners” in which it’s stated that,

“Our water quality is getting horrible because there are buildings in the water, just rotting. Some of
these places, if they didn’t get their sewer tank emptied, their sewer is seeping into it, so the water has
sewage in it,” said. Because of the dying trees and many of the buildings covered in water, the
quality and clarity of the water has been affected. When the first moved to their home, they
could easily see about 24 feet into the water. Now they can only see about 11 feet. Seventeen years
ago, the lake was placed in the top 10 of lakes when it came to clarity. That is no longer the case.”

Also, a geochemical analysis which includes the soils, basin sediments, groundwater and lake water is
warranted prior to discharging the lake water into the proposed basins. The following website,
https://pubs.usgs.gov/circ/circ1139/htdocs/natural_processes_of_ground.htm, provides the following
insight to the potential changes that may occur to the groundwater:

“Two of the fundamental controls on water chemistry in drainage basins are the type of geologic
materials that are present and the length of time that water is in contact with those materials.
Chemical reactions that affect the biological and geochemical characteristics of a basin include
(1) acid-base reactions, (2) precipitation and dissolution of minerals, (3) sorption and ion
exchange, (4) oxidation-reduction reactions, (5) biodegradation, and (6) dissolution and
exsolution of gases.

The ground-water system as a whole is actually a three-dimensional flow field; therefore, it is

important to understand how the vertical components of ground-water movement affect the
interaction of ground water and surface water.”

Consequently, a detailed assessment is necessary to quantify the potential adverse impacts that may
occur to the quality of the groundwater from the introduction of surface water from Lake Shamineau in
order to protect the groundwater resource and the public health of downgradient domestic well
owners.

Furthermore, on page 13 of the EAW it states that, “Indirect impacts to wetlands will likely consist of the
seasonal increases in water levels of the wetland to the east of the infiltration areas due to groundwater
mounding and discharge to the wetland.” Due to the potential for changes in the quality of the
groundwater from the proposed project, it is imperative that the effects from these changes on nearby
wetlands and their respective ecosystems be thoroughly evaluated prior to pumping the lake water into
the infiltration basins.

Conclusion of Public Comments to:

Environmental Assessment Worksheet
Lake Shamineau High Water Project
Report Date: February 2020

Response Date: March 19, 2020

EAW Comments Page 21 April 10, 2020

Lake Shamineau High-Water Project Page 23 April 10, 2020
From: Debra Nelson <dnelson5546@yahoo.com>
Sent: Saturday, March 21, 2020 9:32:36 AM
To: Rick@RapidGlass.com <Rick@RapidGlass.com>
Subject: Response to water levels-Shamineau

Please email confirmation that you have received this-

Thank you.

To: Board of Directors of Lake Shamineau Lake Improvement District

Attention: Rich Rossar, LSLID EAW Manager

On behalf of the Rohl Family Joint Revocable Trust and our parents, Norman and Betty Rohl, who own property
downstream of Stanchfield Lake, we are concerned that we were not included in the discussions regarding the
Lake Shamineau LID.

While we appreciate the concerns of property owners suffering from high water levels on the Lake Shamineau,
we believe that we should have been made aware of and allowed to comment on the project from the beginning
rather than learning about it less than a month before the deadline.

One explanation we’ve heard is that our land is in a different watershed and thus not downstream from
Stanchfield Lake so there was no reason to contact us. Yet on pages 154 and 155 of the EAW there are
pictures of the dam at Stanchfield which clearly identify the “downstream at outlet channel” which runs directly
into one parcel of our land.

We are not engineers, but we see potential issues here, as do other property owners who fear they will be
affected, and have no reason to believe otherwise because they’ve been excluded from the process.

High-water issues are certainly not new in the country, and unfortunately the solution is usually to flush the
excess downstream and let someone else worry about it. But dumping water for the benefit of one group to the
possible detriment of another is short-sighted and unacceptable.

We hope the LSLID Board of Directors will do us the courtesy of a meeting to listen to our concerns and explain
in detail what you see as the impacts to our land and what, if any, steps to mitigate those impacts have been
considered.

Arlo Rohl
Deb Nelson
Wanda Bell
Bonita Sarazin
Roy Rohl
Sharon Rohl

Norman Rohl
Betty Rohl

Lake Shamineau High-Water Project Page 24 April 10, 2020

Subject:Lake Shamineau Lake Improvement
Date:Tue, 24 Mar 2020 14:16:05 +0000 (UTC)
From:Shelley <shelley_scf@yahoo.com>
To: LSLIDBD@gmail.com
<LSLIDBD@gmail.com>

To the board of directors of the Shamineau Lake Improvement District

Attention : Rich Rossar, LSLID EAW Manager

I am writing on behalf of the Rohl Family Trust, to express our concerns with the newest plans for solving the
Lake Shamineau water problem. We understand the difficult situation that the home and land owners of
Shamineau are experiencing. We hope that the LSLID would want to solve these issues with a good conscience
and not pass the problem forward to someone else.

It would make for better relations with the people in the community if the actions of the LSLID were shared with
the land owners of the area. Steps could be taken such as sending letters to inform inserted persons of what the
plans are, to solve the water issues. The LSLID could schedule some meetings so that the interested parties
could see for themselves the plans that have been approved by the local and state government. We would like
to see the correspondence from the Department of Natural Resources, such as environmental impact
statements.

The effect of any of the past and future plans should not be thought of lightly. Not only for the people around
Lake Shanineau, but to everyone in the area you are sending the water to. It is our understanding that the water
will be pumped from Shamineau to a holding pond to perk into Stanchfield Lake. If the water does not first
destroy property on Round Lake, what effect will it have on all property owners between Morrison County Rd 1,
Morrison County Rd 3, and all the way up to Azalea Rd? We are sure that there is no malice here, so sharing
with us your information about permits, funding, impact statements, and start up dates could and should be
made available to all interested persons outside of using the internet.

We are looking forward to hearing from the LSLID to address our questions and concerns.

Rohl Family Trust,

Ellen Noreen - P.O. Box 194, Fort Ripley MN 56449 eenoreen@msn.com

Laural Park - 1861 240th Ave., Luck WI 54853

Gwentha Lumsden - 311 Elm Ave., W Pillager MN 65473 gwenthalumsden@yahoo.com

Lake Shamineau High-Water Project Page 25 April 10, 2020

From: Eugene Rohl <zerotrail@gmail.com>
Sent: Wednesday, March 25, 2020 9:48 AM
To: Rick@RapidGlass.com
Cc: shannon.wettstein@morrisonswcd.org
Subject: LSLID EAW

To: Board of Directors of Lake Shamineau Lake Improvement District

Attention: Rich Rossar, LSLID EAW Manager

Reference: Environmental Assessment Worksheet Availability: Lake Shamineau High Water Project

The Environmental Assessment Worksheet Availability (EAW): Lake Shamineau High Water Project does not
accurately nor completely access the negative impacts of the project to properties downstream from Stanchfield
Lake

The EAW: Lake Shamineau High Water Project is an excellent document as far as it goes. However, the Lake
Shamineau EAW stops at Stanchfield Lake. Where does the 2438 acre-feet of water (EAW p. 3), in 150 days,
go after it reaches Stanchfield Lake?

The EAW never addresses the detrimental effects on the watershed downstream of Stanchfield Lake, nor does
it address the added hydraulic pressure applied to Stanchfield Lake dam’s foundation and the Lake’s outlet
bank.

According to the EAW, the Lake Shamimeau water will quickly flow from the basins to Stanchfield Lake then into
the wetland fen (WSN’s Hydrogeologic Investigation Report p. 8) approximately two miles northeast of Lake
Shamineau. To lower Lake Shamineau 1.5 feet (EAW p. 3) will require pumping 4.6 million gallons per day into
the wetland fen that is already 1.75 feet over its ordinary high water level (EAW p. 3).

Once the water reaches the wetland fen, it will not quickly flow through the wetland fen. As noted in the EAW,
“the outlet stream from Stanchfield Lake does not connect with the streams near Lake Placid, but disappears
into the large fen area” (HIR p. 8). This lack of direct flow will cause the wetland fen to rise even higher above its
near 100-year high groundwater/surface water level. (HIR p.8).

To mitigate this issue, Public Ditch No. 6, recorded on February 18, 1905, on the Deedrick property deed, could
be cleaned of the obstructions, which would allow for suitable water conveyance.

Lake Shamineau Lake Improvement District needs to conduct an in-depth study into the negative consequences
to the flora, fauna, surrounding land, properties, and buildings before proceeding to discharge water into the
Stanchfield Lake/Crow Wing River drainage system.

These impacts must be investigated and mitigated before the project is started,

(Signed)

Eugene Rohl

35849 70th Ave

Cushing MN 56443

Lake Shamineau High-Water Project Page 26 April 10, 2020

From: Dave Deedrick <davedeedrick@gmail.com>
Sent: Wednesday, March 25, 2020 11:01 AM
To: Rick@RapidGlass.com
Subject: EAW - LSLID

Formally stated, Newton's third law is: "For every action, there is an equal and
opposite reaction. The statement means that in every interaction, there is a pair of forces
acting on the two interacting objects. The size of the forces on the first object equals the size
of the force on the second object". Now I'm not a great scientist but I think Newton was a
pretty smart guy and the more I have thought on what he said the more I believe certainly it
does apply to the Lake Shamineau diversion project.
The plan as I see it is to take a whole bunch of water (millions of gallons) and put it
somewhere else. Now I want to go on record to say that I think that's a good idea. It will
benefit a lot of people and restore lands for their intended uses. On the other side I see
some serious problems. The project will eventually get rid of great amounts of water from
Lake Shamineau. On the other hand the issue is where will all of that "problem" water go and
what will be it's impact on where it's going.
The result of pumping water from Lake Shamineau is good at the source but I believe the
end result of all that water will have a negative impact on: 1. The Stanchfield Lake Dam
(possibly) 2. The stream flowing north from Stanchfield Lake (likely) 3. The large wetland
area to the north which covers approximately 6 sq. miles (for sure).
I'm sure others have commented on the current situation in the wetlands on the north
side of this project. It is and has been experiencing very wet conditions for several years
running. Every aspect of the environmnent in the wetlands has been suffering from these
extra wet conditions. My wife and I own 177 acres right in the bullseye of where all of the
diverted water will be going. We are of the belief that the water from Shamineau Lake
diverted our way will be detrimental to the health of all these wetlands to the north including
our land. There is a way to mitigate the negative effects of all that water. By keeping it going
east and north and that can be a reality if steps are taken initially to properly open the ditch
that runs from west to east on our property and then continue all the way to Highway 1 and
then north to the Crow Wing River. According to the abstract of our property the ditch was
dug initially in 1905 for a cost of about $175.71. I suggest that you open that ditch.
In conclusion: I know digging ditches in wetlands is something that can be
frowned upon and "we just don't do it anymore". I would answer that with, "When was the
last time we tried to drain a lake as big as Lake Shamineau?" , "Desperate times call for
desperate measures." I believe that we can save the folks on Lake Shamineau and save the
6 miles of wetlands to the north as well.

Dave and Nancy Deedrick

Lake Shamineau High-Water Project Page 27 April 10, 2020

March 25, 2020

Dear Rick Rosar,

I own property bordering both Stanchfield Lake and the unnamed creek, which connects Stanchfield Lake to
the large fen area north of the hills. This land has been part of my family since the 1950’s and is a treasured
retreat for connecting with extended relatives, friends, and nature. I am very concerned that the Lake
Shamineau High Water Project will significantly impact my property, Stanchfield Lake, the creek, and this
area’s wildlife. Please accept my below comments on the Lake Shamineau High Water Project EAW.

The current high ground water levels affecting Lake Shamineau are similarly creating very high water
conditions at Stanchfield Lake. July and November, 2019 Stanchfield Lake surveys documented lake elevation
of 1255.96 ft and 1255.42 ft respectively. These levels approach or exceed the lake’s 1255.80 ft ordinary high
water elevation and are very close to the lake’s highest recorded elevation of 1256.2 ft.

The EAW’s Operation and Maintenance Plan entails continuously discharging up to 10 cfs of Lake Shamineau
water into Stanchfield Lake’s groundwater source from mid-May through early November. Its Contingency
Action Plan’s strategy for Stanchfield Lake entails halving the project’s current pumping output if the lake’s
elevation exceeds 1256.3 ft. This exceeds Stanchfield Lake’s highest recorded elevation of 1256.2 ft and
triggers a pumping reduction, rather than a cessation. Despite a halving of the project’s pumping output,
Stanchfield Lake’s elevation would likely continue rising for several days until the previously released, 10 cfs
output fully seeps into the lake. Major rain events during this response lag will further contribute extended
periods of record high Stanchfield Lake levels.

Many of my property’s lakeside trees are already exhibiting signs of high water stress due to Stanchfield Lake’s
current high water levels. The EAW’s does not assess the impact of elevated Stanchfield Lake levels,
throughout the growing season, on privately owned trees surrounding Stanchfield Lake. Additionally, its
Operation and Maintenance Plan does not include a precautionary buffer to insure that the combined water
inputs from pumping and major rain events do not exceed the lake’s established ordinary high water level for
extended periods during the growing season.

Stanchfield Lake also supports a population of state-threatened Blanding’s turtles, which my family and I
occasionally observe in the late spring, as the female turtles travel to their upland nesting sites. Blanding’s
turtles, along with many of the lake’s other reptiles and amphibians, hibernate in Stanchfield Lake’s shallow
marsh areas. The lake’s relatively stable wintertime water level protects these animals from dessication and
freezing temperatures.

The EAW’s Operation and Maintenance Plan entails pumping into the late fall or early winter of each year,
depending on weather and freeze up conditions. Discontinuing pumping at the onset of freezing conditions
will result in receding Stanchfield Lake water levels after Blanding’s turtles and other reptiles and amphibians
have begun hibernating and are unable to move to deeper water. The EAW does not address this project’s
impacts to Stanchfield Lake’s wildlife from a substantial, post-freeze up decrease in the lake level.
Furthermore, the EAW does not address this project’s potential to create extensive

Lake Shamineau High-Water Project Page 28 April 10, 2020

shelf-ice in Stanchfield Lake’s shallow marsh areas and the resultant safety hazard for trappers and other
winter lake users.

I am also very concerned about this project’s impacts to the unnamed, 8 ft wide creek which flows northwards
from the Stanchfield Lake Dam. This shallow creek passes through a broad, shrub swamp wetland and a
narrow, forested valley on my property. The swamp’s streambed and banks are comprised of peat and sand,
while the valley’s streambed and banks are comprised of sand. I often visit a special, south-facing hillside
overlooking this creek to take family photos or reflect. The EAW’s Operation and Maintenance Plan may
irreparably damage this creek if sustained unnaturally high water volumes erode its channel and banks.

Based on the Stanchfield Dam Flow Capacity Analysis Memo located in Appendix M of the EAW, water is
flowing over the dam at a rate of 36.9 cubic feet per second (cfs) when the lake is at its ordinary high water
elevation of 1255.80 ft. The dam’s record flow rate of 58.8 cfs occurred on May 13, 1971 when Stanchfield
Lake reached its highest recorded elevation of 1256.2 ft. This was likely a relatively short duration flood event
during the spring runoff.

The EAW’s Operation and Maintenance Plan entails continuous pumping of Lake Shamineau water into
Stanchfield Lake’s groundwater source from mid-May through early November, with a pumping volume
reduction only if Stanchfield Lake’s elevation exceeds 1256.3 ft. At this elevation, 64.8 cfs, or nearly twice the
ordinary high water mark volume (36.9 cfs), would likely flow into the creek from mid-May through early
November during multiple years. One inevitable consequence of this flow rate doubling will be channel and
bank erosion as the creek widens to accommodate this higher water volume. The EAW does not assess how
the creek’s channel, banks, and the surrounding vegetation would be impacted by this prolonged, record high
streamflow.

Additionally, the EAW does not assess how the eroded creek channel and bank sediments will impact the
downstream shrub swamps and the large fen, where these sediments will largely be deposited by floodwaters.
Wild rice grows in the beaver flowages located near the confluence of the creek and large fen. These rice beds
are particularly vulnerable to sedimentation.

I sympathize with the Lake Shamineau property owners who are impacted by the lake’s high water levels and
am willing to partner with the Lake Improvement District to address these high water issues. As a prerequisite,
I ask the District to fully assess the environmental impacts of discharging Lake Shamineau water into
Stanchfield Lake and its downstream waterbodies. The EAW states: “It is the intent of the project not to
negatively affect any downstream land owners if a significant manner.” Please insure that this project does
not harm Stanchfield Lake, the creek, and this area’s wildlife, too.

Sincerely,

Bill Peterson 505 Nordic Ln. Slinger, WI 53086

Lake Shamineau High-Water Project Page 29 April 10, 2020

 MORRISON SOIL AND WATER CONSERVATION DISTRICT
16776 Heron Road * Little Falls, Minnesota 56345
(320) 631-3553 - www.morrisonswcd.org

Rick Rosar
LSLID EAW Manager
Lake Shamineau Lake Improvement District
P.O. Box 394 Motley, MN 56466
Email: Rick@RapidGlass.com

Mr. Rosar,

In regards to the Environmental Assessment Worksheet for the Lake Shamineau High Water Project
the Morrison SWCD has the following comments:

Page 4 Groundwater Mounding

The groundwater level is 1266’ at the new infiltration basin location. The EAW states the mounding
will be 10’ to 20’ above this. The lake level as of October 2019 was 1277.1’. The groundwater
mounding could potentially be 1286’ to 1276’ which is above the lake level now. This mounding could
potential flow back to the lake rather than to the east.
Page 9 Hydrogeologic Investigation Report (HIR)
Written in May 2019 for the original gravel pit site and not the current proposed site to the east.
Without a HIR for the new location assumptions are being made for the new infiltration site. The
groundwater flow may be different from the new site to the old site. How was the groundwater
mounding calculated? There is no mention of the model used. The locations of the old basins and the
new basins are almost half mile apart and 20 feet in elevation difference.
Appendix C New Infiltration Area Characteristics Memo
Well Drillers misidentified Clay Layer. The proposed EAW assumes the drillers misidentified the soil
layers. What is to say they did in fact identify it correctly and the proposed EAW has it wrong? More
borings with samples collected from these may be needed.
No Comments Regarding Water Quality in the Adjacent Areas to the East
The LID and EAW states homes are rotting and septic systems are over flowing or flooded. What
precautions are taken to safe guard the otherwise okay wells and water quality to the east? The EAW
does not comment on the concerns regarding water quality to the east. O & M Manual – IV
Operations
The pumping operation will continue if the lake is over the OHWL and will stop when the elevation
goes below the OHWL. Our concern is at what elevation below the OHWL does the pump get turned
off?

Lake Shamineau High-Water Project Page 30 April 10, 2020

This office feels this EAW does not adequately gauge the possible environmental impacts of the
current project and an Environmental Impact Statement (EIS) should be supplied before permitting is
allowed.

Shannon Wettstein
District
Manager
Morrison
SWCD office:
320-631-
3553 cell:
320-547-
1651 16776
Heron Road
Little Falls, MN 56345

Mission: To provide leadership and direct assistance for conservation management of soil and water.

Lake Shamineau High-Water Project Page 31 April 10, 2020

Division of Ecological and Water Resources
Region 3 Headquarters
1200 Warner Road
Saint Paul, MN 55106

March 25, 2020

Lake Shamineau LID

Rick Rosar, LID EAW Manager
P.O.Box 394
Motley, MN
56466

Dear Mr. Rosar,

Thank you for the opportunity to comment on the Lake Shamineau High Water Project EAW in Morrison
County. The DNR has reviewed the EAW and respectfully submits the following comments:

I. General Remarks

A. Project Scope

Over the past 20 years, Minnesota has experienced above normal precipitation and associated increases in the
groundwater table and surface waters. We sympathize with the residents who live along Lake Shamineau and
have experienced flooding, erosion, and property damage.

The impacts of increased precipitation are occurring throughout the project vicinity, with some downstream
wetlands already approaching elevations of one to two feet above their historic Ordinary High Water Level
(OHWL). This project could shift existing problems occurring on Lake Shamineau to downstream wetlands,
streams, and waterbodies, and exacerbate the high water problems those areas are already experiencing.

The project is presented in the EAW as a two-year solution to a short-term problem, and argues that
hydrologic and ecologic impacts will be minimal and only seasonal in nature. This claim is not supported by an
ecological knowledge-base, nor by the practical expertise of DNR staff who manage area wetlands and lakes,
especially the outlet structure on Stanchfield Lake. Based on the demonstrated long-term climatic trend
toward increasing annual precipitation during the growing season, it is likely that the pumping rate or duration
will be reduced due to monitored wetland impacts. There is also a possibility that the amount of water to be
removed from Lake Shamineau has been underestimated. Therefore, we have concluded that this project is
unlikely to be shortterm in nature and will take longer than two years causing potentially large hydrologic
changes to downstream public waters and non-public water wetlands.

Lake Shamineau High-Water Project Page 32 April 10, 2020

B. Project Size

The sizing of the project overestimates how much the lake level will be lowered by assuming that no additional
water will flow into the lake. Based on this assumption, the lake level could be lowered by 1.5 feet in one year
if the lake was pumped at a rate of 7.1 cfs. This is the maximum rate that can be pumped due to the limitations
of the infiltration basin (page 3). It would take at least two years to lower the lake to the OHWL at this rate.
However, it is unrealistic to assume that no additional water will flow into the lake as the water is removed.
The water table in the area is essentially being lowered with the lake level. The water table extends beyond the
surface of the lake such that the volume of water that must be pumped in order to lower the lake level is more
than what has been calculated as being present within the Lake Shamineau basin itself. The EAW does not
include this additional water in total volume calculations, nor does it note that the estimated time to lower the
lake is conservative.

C. Pumping Rate

The initial pumping rate was based on the volume required to lower the lake level 1.7 feet, which is the
maximum amount the lake has increased in a year. It would require pumping 24 hours a day at a rate of 8.2 cfs
for 150 days (the entire pumping season) to remove this volume of water. This volume was calculated based
on a lake surface area of 1,434 acres. However, the DNR states the lake area is 1,453 acres, indicating that a
greater volume would need to be pumped. If the rate of water entering the lake exceeds that being pumped
out, the predicted target lake level will not be achieved. The proposed rate was increased to 10 cfs to account
for downtime and maintenance. This downtime was not accounted for in the new pumping rate of 7.1 cfs
(3,200 gallons per min).

The infiltration rate used for different pumping rates varies throughout the EAW and Operations and
Management Plan, but there is no explanation as to how these rates were determined. For example, a
downtime of 4.5 hours a day would occur if the infiltration rate at 10 cfs was the same as the pumping rate of
8.2 cfs. However, in the Operations and Maintenance Plan, the infiltration rate used is 2.8 feet per day when
pumping at 10 cfs, which results in no downtime. At 8.2 cfs, the infiltration rate used is 2.2 feet per day while
at 5 cfs, the infiltration rate used is 1.4 feet per day. More information on these calculations should be
provided and there should be more consistency in how these rates are used throughout the EAW and
supporting documents.

II. EAW Comments

A. Page 4. The EAW states that the intent of project operation is to not negatively affect other
land owners. The avoidance of impacts to natural resources should also be a stated purpose and
priority.

B. Page 4. The survey datum used throughout the EAW and project documents to report
elevations is inconsistent and not always specified making it difficult to evaluate and compare
statements and measurements. The EAW states on page 4 that the groundwater level below the
infiltration basins is at 1261 feet approximately 30 to 40 feet below the infiltration basin surface.

Lake Shamineau High-Water Project Page 33 April 10, 2020

 However, on page 11 the groundwater level is listed at an elevation of 1264 feet at a stated 45 feet
below the infiltration basin surface.

C. Page 6. Although the applicant will be required to get a Public Waters permit and not a Water
Appropriations permit from the DNR, it is recommended that the volume, rate, and times that water is

pumped is reported. This information will be crucial in future analysis of the project should impacts
occur and changes need to be made.

D. Page 9. The EAW states, “Six soil borings were completed within the project area (Appendix I).
These soil borings show that the project area is underlain by sand and gravel, with limited amounts of
silty sand.
The six soil borings and WSS describe a similar soil profile.”

1. This statement is misleading as only one soil boring was completed for the new
infiltration basin location.

E. Page 13. The EAW states, “The potential impacts to wetlands will be addressed in the DNR
Public Waters Permit, that will specify what impacts to the wetland will be allowed and how they can
be reduced.”

1. All potential impacts need to be addressed by securing flowage easements from the
impacted property owners.

F. Page 13. The EAW states, “…such that the removal will not affect the amount of surface water
or groundwater resources in the area.”

1. The EAW identifies both groundwater and surface water impacts related to this
project.

G. Page 18. The EAW states, “Increased groundwater flow is expected as a result of the project
and operating limits will be set to mitigate the impacts to downstream wetlands.”

1. Impact to neighboring surface water features must be addressed by flowage

easements, and will not be allowed without landowner consent. It will be necessary to apply
to the DNR for a flowage easement regarding the proposed flow and impact to the Stanchfield
Lake Wildlife Management Area (WMA). Please contact DNR Lands and Minerals to apply for
an easement at:
https://files.dnr.state.mn.us/lands_minerals/easement/easement_application.pdf

H. Pages 13-14. Surface Waters

1. Surface water elevations are already well above normal in the wetlands that would
receive additional water from the proposed infiltration basins. This includes basin 130P
(Ramdown Slough; already more than one foot above its OHW) that straddles the boundary of
Stanchfield Lake State Wildlife Management Area (WMA), as well as Stanchfield Lake itself

Lake Shamineau High-Water Project Page 34 April 10, 2020

 which has been experiencing flooding of shoreland and private roads despite more aggressive
lake management and beaver control in recent years at the outlet.

2. Increased supply of water will aggravate current high water issues in all these basins,
and will result in permanent changes to the hydrology of shallower wetlands (including several
nonpublic water wetlands on the WMA), with concomitant changes to their ecology and
aquatic plant and animal community.

3. Specifically, increases in water depth (which could approach two feet in some
wetlands), will likely affect aquatic plant diversity & abundance (especially wild rice), reduce
the amount of emergent habitat, reduce the attractiveness of the wetlands to waterfowl,
negatively impact waterfowl hunting, and cause fundamental changes in the food web within
most basins by permanently converting them to a deeper state.

4. Higher surface waters resulting from the project will also affect access in adjacent
uplands, some adjacent upland forest habitat, and thereby affect forest management
activities on both the WMA and adjoining private lands.

5. In addition, flooding of the public access on Stanchfield Lake within the WMA is
common due to the low elevation gradient at the access, making it difficult to access the lake
at times. The proposed project would exacerbate this, and may reduce the capacity of the
parking area.

6. The Division of Fish and Wildlife’s WMA policy directives prohibit new drainage onto
or through a WMA unless it provides benefits consistent with the purpose of the WMA and
normal hydrology of the habitats on the unit. Since negative impacts from the project to
wetland and forest habitats on Stanchfield WMA are expected (due to significant growing
season-long increases in baseline water levels), with associated impacts to recreation and
management, drainage from the project onto the WMA would not be allowed by the Section
of Wildlife without a flowage easement. The project, as described in this EAW, would likely not
meet conditions necessary to issue such an easement.

7. There should be more research conducted on the outlet stream channel to determine
the projected increase in capacity and its consequent impact to the channel. While an
additional 1030 cfs in the short term does not seem like much, the longer term nature of the
project stands to increase erosion potential of the channel itself downstream of the dam
structure. All Dimension, Pattern, Profile, Connectivity and Chemistry of the affected stream
needs to be considered. Increasing capacity of the outlet by more than 10%, in a less than
three square mile watershed, will have some negative impacts on erosive potential.

I. Page 15-17. Rare Features

1. Red-shouldered hawks and Blanding’s turtles are not invertebrates.

Lake Shamineau High-Water Project Page 35 April 10, 2020

 2. An avoidance plan for Blanding’s turtles is required as described in the Natural
Heritage letter dated February 17, 2020. Project proposers will need to coordinate with the
DNR Regional Nongame Specialist. Please note that an increase to water levels in wetlands
within the project vicinity could be considered an impact if it alters or degrades wetland plant
communities and habitat.

3. Please check any trees planned for removal for Red-shouldered hawk nests and
comply with the recommendations listed in the Natural Heritage letter.

4. Due to entanglement issues with small animals, use of erosion control blanket should
be limited to ‘bio-netting’ or ‘natural netting’ types, and specifically not products containing
plastic mesh netting or other plastic components. These are Category 3N or 4N in the 2016 &
2018 MnDOT Standards Specifications for Construction. Also be aware that hydro-mulch
products may contain small synthetic (plastic) fibers to aid in its matrix strength. These loose
fibers could potentially re-suspend and make their way into Public Waters. As such, please
review mulch products and do not allow any materials with synthetic (plastic) fiber additives in
areas that drain to Public Waters.

5. Only use native seed mixes for re-vegetation that are “noxious weed-free”.

J. Page 20. The EAW states, “According to the manufacturer, the expected noise generated by the
pumps will be 65 dB when uncovered and in operation. The typical noise standard for a Noise Area
Classification
(NAC) 1 area at night is 50 dB and 60 dB in the day per Minnesota Rule 7030.0040. As the noise

generated by the pumps will approximately 65 dB at 5 feet from the pumps when they are uncovered,
the pumps will be submerged under water in an underground concrete sump, and vegetative plantings
are planned around the pump station, the proposed project is expected to be within state noise
standards.”

1. The actual decibel level once installed and submerged should be provided. Neighbors have
expressed concerns over noise issues, and a solid number should be provided.

III. Hydrogeologic Investigation Report

A. Site Evaluation

The project proposal and discussion in the EAW is based largely on the Hydrogeologic Investigation Report
(May 2019) found in Appendix B. This investigation was conducted for an entirely different site than the
infiltration basin location proposed in the EAW. A single boring (NS-B3) was conducted in February 2020 to
evaluate the new location and was included as an attached memo to the May Report. The findings of the new
boring dismiss data already presented in the Hydrogeologic Investigation Report. Cross Section A-A’ shows
DNR Observation Wells 528964 and 769083, the closest to the new proposed infiltration site, as being located
in clay or encountering silty clay at a depth of 40 feet below the surface. Piezometer 3 (PZ-3), the closest of the
Lake Shamineau High-Water Project Page 36 April 10, 2020
original borings to the new infiltration site also encountered finely textured soils and gray sand (indicative of a
depleted matrix and high water table). The new boring described sand with some silt at 35 feet below the
surface and noted that mottling was present. Mottling is an indication of consistently saturated conditions.

The memo dismissed these other observations of finer textures as the result of not using a rotosonic drilling
technique. This claim is crucial to the success of the project, but is not discussed further. No location for this
boring is provided in the boring logs or in any figures. The new boring shows a water table at 42.9 feet below
the surface (1298.43), which is consistent with other observations of a finer textured limiting layer at a depth
of 30 to 45 feet below the surface. A groundwater level at 1278 feet in elevation was observed in a boring
located approximately 700 feet south of the proposed infiltration basin. This is more than 10 feet higher than
the water levels measured in the borings below the initial infiltration basin or in Piezometer #2 located
approximately 500 feet south of the initial infiltration basins. These new water level measurements make it
less clear as to what direction local groundwater is flowing. Clearly, further investigation of the newly
proposed infiltration site is warranted in order to make claims about its suitability for the project.

There are other claims made by the Hydrogeologic Investigation Report based on assumption rather than data.
PZ-3’s well installation log shows that this boring only goes to a depth of 8 feet below the surface, and yet
rather than describing the soil beyond the depth of the boring as unknown, Cross Section B-B’ assumes that
everything below the PZ-3 is sand and that the finer textured material is merely a small sliver extending into
the project area in that one location despite the nearest DNR Observation Wells showing finer textured soils.

B. Groundwater Model

The DNR Groundwater Technical Unit conducted a preliminary review of the Lake Shamineau High Water
Project in the summer 2019 and found several significant problems that were conveyed to the consulting
company via an email dated September 20, 2019. Groundwater staff requested that any additional review of
the model wait until the LSLID had applied for their permit or completed an EAW. They also requested that a
revised model report be signed by a licensed professional and submitted with the model, which to date has not
been done. Without this model, it is not possible to do a complete assessment of how groundwater levels
might affect adjacent properties.

The model is only mentioned briefly with respect to the predicted level of mounding beneath the infiltration
level. The EAW states that the groundwater model shows that pumping at a rate of 5 cfs will not cause more
than 20 feet of mounding at piezometer 3 (page 118). PZ-3 is located approximately 0.4 miles from the initial
proposed location of the infiltration basin and only goes to a depth of eight feet. There is no mention as to why
the location was moved or how the study conducted at the initial location applies to the new location. The
Hydrogeologic Investigation Report indicates that a discharge rate of 7.1 cfs would be required to lower the
water level in Lake Shamineau to the OHWL within two years. However, it does not indicate the degree of
mounding predicted to occur pumping at that rate. If the mounding exceeds 20 feet at a rate of 5 cfs, they will
not be able to pump at a rate high enough to lower the lake as planned.

No concerns were raised that water will seep or flow back to Lake Shamineau. It would be important to know,
based on the groundwater model, the maximum pumping rate that can occur before water will flow back to
Lake Shamineau. Page 4 of the EAW states, “Because the groundwater is at an average elevation of 1266
Lake Shamineau High-Water Project Page 37 April 10, 2020
beneath the basins, it will not flow back to Lake Shamineau because Lake Shamineau is over 10 feet higher in
elevation at 1277.52.” This is not an accurate statement. The “Hydrogeologic Investigation Report” dated May
2019 shows a water table elevation of 1266 at the old site (gravel pit 200’+ to the west). The memo with the
new infiltration site information gives a ground surface elevation of 1,298.43 and states that the water table
was encountered at a depth of 42.9 feet. If 20 feet of groundwater mounding occurred, this could bring the
water table to 1,275.53 feet in elevation or more. The water table fluctuates frequently throughout the
season, and adding 10-20 feet of mounding could result in a water table elevation above the elevation of Lake
Shamineau at times of the year when the water table is higher.

IV. Operation and Maintenance Plan

The Operations and Maintenance Plan is inconsistent with the pumping rates specified in the EAW. According
to the plan, pumping will begin at the lowest possible rate of 5 cfs rather than the 7.1 cfs rate identified in the
EAW. If monitoring thresholds are not crossed at 5 cfs, pumping will be increased to 7.5 cfs, which is 0.4 cfs
greater than the specified maximum volume that the basins can receive. If the thresholds are not exceeded at
7.5 cfs, pumping will be increased to the maximum rate of 10 cfs. This is 2.9 cfs greater than the specified
maximum volume. According to the plan, the pumps can operate between 5 cfs and 10 cfs (page 117).
However, the contingency plan does not indicate what will happen if mounding exceeds the threshold at the
minimum rate of 5 cfs. The plan should also specify how much time should elapse between water level
readings when determining whether pumping should be further decreased once the threshold is crossed.
While it is unclear how the model is being applied to the design of this project, it appears that a trial and error
approach rather than a more technical approach is the basis for when water levels in the basin and beneath
the infiltration basin to trigger changes in pumping rates.

According to the Operations and Maintenance Plan, action levels will be based on water levels measured under
the infiltration basin, in the unnamed wetland northeast of the infiltration basins, in Round Lake and in
Stanchfield Lake. However, no technical basis is provided for establishing the action levels. Please provide an
explanation as to why these levels were determined and how the reduced rates were calculated. This section
also states, “The pumping operation will continue if the lake is over OHWL and will stop when the elevation
goes below the OWHL.” Pumping must stop at or prior to reaching the OHWL. Any reduction below the
OHWL would trigger a Mandatory EAW according to MN Rule 4410.4300, subpart 27. Wetlands and Public
Waters, part A, in addition to this Discretionary EAW.

A. Monitoring

Several concerns have been expressed by WMA staff about potential increases to the already flooding basins in
the WMA located northeast of the proposed infiltration basins. Acceptable high water level thresholds in these
basins do not appear to have been established and the EAW provides no explanation as to why these wetlands
will not be impacted by an increased water level. The Operations and Maintenance Plan indicates that
pumping will be reduced if either a one foot increase is seen in the unnamed wetland northeast of the
proposed infiltration level or if a mound greater than 20 feet is measured below the infiltration basin.
However, there is no explanation as to how or why a one foot increase or a 20 foot mound beneath the basin
was determined to be an action level, nor does it say what the groundwater level model predicted increase in

Lake Shamineau High-Water Project Page 38 April 10, 2020

the unnamed basin would be. The report does note that trees are flooding in the unnamed wetland because
the water level is 1.75 feet above the ordinary high water level. It does not say why this is not considered an
adverse impact nor why an additional increase of one foot is acceptable. There is nothing in the contingency
plan that states what will happen if the basin’s water level is over one foot above the OHWL at the start of
pumping. Would the project refrain from pumping until the wetland levels recede to a level that can receive
water without any adverse impacts? How will natural water level rises in all monitored water bodies be
distinguished from those caused by the project?

The plan states that basin levels in the unnamed wetland will be allowed to increase one foot from where they
are measured prior to pumping. It also states that water levels less than one foot above the OHWL should not
adversely impact the wetland. An actual elevation should be stated. The WMA manager may know the
elevation in the basin where adverse effects will occur. This level should be used for an action item rather than
a one foot increase. The plan also does not explain why a one foot increase in water level would not cause any
adverse impacts to the wetlands down-gradient of the infiltration basins. The WMA manager should be
consulted on acceptable water levels in the basin, and contingency action plans should be based on these
levels rather than assigning an arbitrary one foot increase in water levels.

V. Conclusion
Based on the information provided in the Lake Shamineau High Water Level EAW and supporting documents,
there is insufficient data regarding the proposed infiltration basin site, groundwater mounding, and expected
impacts to downstream surface waters to thoroughly assess the environmental impact of this project.

Thank you for the opportunity to review this project.

Sincerely,

Melissa Collins
Regional Environmental Assessment Ecologist | Ecological and Water Resources
Minnesota Department of Natural Resources
1200 Warner Road
St. Paul, MN 55106
Phone: 651-259-5755
Email: melissa.collins@state.mn.us

CC: Dan Lais, Central Region Manager

Equal Opportunity Employer

Lake Shamineau High-Water Project Page 39 April 10, 2020

 DEPARTMENT OF
ADMINISTRATION
STATE HISTORIC PRESERVATION OFFICE

March 23, 2020

Mr. Rick Rosar

LSLID EAW Manager
Lake Shamineau Lake Improvement District
PO Box 394
Motley, MN 56466

RE: EAW - Lake Shamineau High Water Project

T132 R31 SIO, 11
Scandia ValleyTwp. Morrison
County SHPO Number: 2020-1270

Dear Mr. Rosar:

Thank you for providing this office with a copy of the Environmental Assessment Worksheet (EAW) for the
above-referenced project.

We have reviewed the cultural resources survey report that was prepared for this project. Based on
the results of the survey, we conclude that there are no properties listed in the National or State
Registers of Historic Places, and there are no known or suspected archaeological properties in the
area that will be affected by this project.

Please note that this comment letter does not address the requirements of Section 106 of the
National Historic Preservation Act of 1966 and 36 CFR 5 800. If this project is considered for federal
financial assistance, or requires a federal permit or license, then review and consultation with our
office will need to be initiated by the lead federal agency. Be advised that comments and
recommendations provided by our office for this state-level review may differ from findings and
determinations made by the federal agency as part of review and consultation under Section 106.

Please contact our Environmental Review Program at (651) 201-3285 if you have any questions regarding our
review of this project.

Sincerely,

Lake Shamineau High-Water Project Page 40 April 10, 2020

Sarah J. Beimers
Environmental Review Program Manager

MINNESOTA STATE HISTORIC PRESERVATION OFFICE

50 Sherburne Avenue Administration Building 203 Saint Paul, Minnesota 55155' 651-201-3287 mn.gov/admin/shpo/u
mnshpo@state.mn.us
AN EQUAL OPPORTUNITY AND SERVICE PROVIDER

Lake Shamineau High-Water Project Page 41 April 10, 2020