The preserve Camp Coldwater Coalition is deeply concerned by the memorandum from the Minnesota Board of Water and Soil Resources (BWSR), dated May 10, 2000.

In this memorandum the area north of the Highway 62 and Highway 55 interchange, including the Coldwater Spring outlet is recommended to be part of the Minnehaha Creek Watershed District (MCWD). However the immediate area south of Highway 62 and the highway itself was recommended to go to the Lower Minnesota River Watershed District (LMRWD).

Preserve Camp Coldwater Coalition believes that there is a significant chance that the underground water flows that feed the Coldwater Spring run underneath Highway 55 and 62. Furthermore the natural hydrology boundary is indeed south of Highway 62.

In the May 10 memorandum, BWSR states, "Surface water hydrology has in the past been the primary determinant for the setting of a district's boundary. We believe surface water hydrology should again be the primary determinant of the expanded district boundaries.

Parcel configuration, commonality of land use, and the desires of land occupiers should be given consideration, however each is less important than surficial hydrology is in setting the boundary. Where possible BWSR should accommodate land occupiers as long as it does not impose an inappropriate boundary."

The final recommendation by BWSR is to break up a natural hydrology boundary. Also the memorandum dated May 10th does not follow what the public was told on April 27th, that public testimony will be accepted until 12 noon May 11th.

Preserve Camp Coldwater Coalition understands the desire to keep storm sewers and all airport property within one watershed for convenience of present and future projects, but believes that protection of the Camp Coldwater Spring is paramount over convenience, and that the natural hydrology boundary MUST be within one watershed.

The artificial political boundary that has been recommended has caused the MCWD, the only watershed with groundwater regulations, to try and withdraw their petition to the area on the grounds that if they cannot regulate construction of the highway 55/62 interchange and associated storm sewers that run under the highway, they do not want to be responsible for the resultant outflow of water at the Coldwater Spring outlet.

The preliminary storm sewer construction, that has required jack hammering into the limestone and bedrock, already has damaged or destroyed underground water supplies or springs to the Minnehaha Creek valley. Given that no hydrology study or dye tracings have been done to determine water source(s) or route(s), it is very likely that continued construction WILL damage the Coldwater Spring.

Placing Highway 62/55 interchange into LMRWD will not carry out BWSRs mission statement that they "assist local governments to manage and conserve their irreplaceable water and soil resources." The LMRWD does not currently have the groundwater regulations necessary to adequately protect the groundwater flow to the Coldwater Spring.

The MCWD has revised their regulations to accommodate groundwater to try and protect the spring. By not allowing the potential recharge area around the Coldwater Spring to receive the newly updated regulations does a grave disservice to watershed quality, and sets a terrible precedence. It may also cause the destruction of the Coldwater Spring itself.

Preserve Camp Coldwater Coalition questions weather it is a conflict of interest to have individuals who serve and represent the Metropolitan Council, Metropolitan Airport Commission Deicing Task Force, and Watershed Boards also serve as the regulating authority of BWSR who oversees the actions of some of the other groups. This is the current situation, and it gives an air of poorly planned self-regulation.

The Coldwater area is in desperate need of adequate watershed protection to ensure that present and future construction projects will not destroy this unique and irreplaceable resource. The area is truly invaluable and completely irreplaceable given the fact that the area is recognized as the birthplace of Minnesota by the State Historical Society, the spring feeds a stream and falls in Fort Snelling State Park, it is, according to a study by MnDOT, likely Traditional Cultural Property and a Sacred Site under Executive Order 13007 due to it's extensive connections to the Dakota and Ojibway Indians.

However the recommendation of BWSR places the LMRWD in a position that they are ill equipped to deal with. If this recommendation is followed construction of Highways 55 and 62 will likely have proceeded and possibly be completed long before the LMRWD could ever produce the regulations necessary to adequately protect Coldwater Spring and recharge area, which is in fact, outside of LMRWDs natural hydrology boundary.

Due to the delicate nature of the area and that ample evidence exists from the hydrology study of Kelton Barr, hydrologist and, preliminary construction that proves current plans have seriously damaged water flow to Minnehaha Creek valley, Preserve Camp Coldwater Coalition believes that the current recommendation runs directly against BWSR mission to conserve irreplaceable water resources.

Preserve Camp Coldwater Coalition strongly recommends and requests that the Coldwater area go to the MCWD up to the natural hydrology boundary. We also recommend in the strongest possible terms, that under no circumstance, the Coldwater area is continued to be left out of any watershed protection whatsoever due to infighting between BWSR, LMRWD and, MCWD.

We ask that you do all that you can too ensure proper and adequate protection to Camp Coldwater and surrounding area.

Thank You,