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St. Croix Chippewa
Indians of Wisconsin
Nonpoint Source Management Plan
Draft – June 2026
Table of Contents
Acronyms and Abbreviations...................................................................................................... 3
1 Overview ................................................................................................................................. 4
2 Introduction ............................................................................................................................. 6
2.1 Goals and Objectives........................................................................................................ 6
2.2 Watersheds of Focus ........................................................................................................ 7
Sand Lake-Yellow River HUC12 (070300010501) .............................................................. 9
Big Sand Lake-Yellow River HUC12 (070300010502) .......................................................10
Loon Creek HUC12 (070300010505) .................................................................................10
Buffalo Lake-Yellow River HUC12 (070300010506) ...........................................................11
Sand Creek HUC12 (070300010803) ................................................................................11
Clam Lake-Clam River HUC12 (070300010904)................................................................11
Black Brook-Clam River HUC12 (070300010906)..............................................................12
Hay Creek-Saint Croix River HUC12 (070300011202) .......................................................12
Straight River HUC12 (070300050702) ..............................................................................12
2.3 Tribal Authority for Implementing the NPS Management Program ...................................13
3 NPS Management Plan Implementation.................................................................................15
3.1 Implementing the NPS Management Program with St. Croix Tribal Governance .............15
3.2 Existing Tribal Plans, Ordinances, & Policies ...................................................................16
3.3 Key Partners for NPS Program Implementation ...............................................................16
3.4 NPS Funding Sources .....................................................................................................19
3.5 NPS Management Program Monitoring & Assessment ....................................................19
3.6 NPS Management Program Coordinating & Reporting ....................................................21
4 Management Program Summary ...........................................................................................22
4.1 BMP Selection .................................................................................................................24
Forestry .............................................................................................................................25
Wetland/Riparian Areas .....................................................................................................26
Agriculture..........................................................................................................................27
4.2 Schedule for BMP Implementation...................................................................................28
Long-term Implementation .................................................................................................29
5 Public Notice & Comment ......................................................................................................30
6 References ............................................................................................................................31
Appendix A: Attorney Certification for CWA Section 319 Eligibility ............................................32
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Acronyms and Abbreviations
BIA
BMP
CPRG
CWA
ENRD
HSG
HUC8
HUC10
HUC12
mg/L
NPS
POWTS
QAPP
SWCD
TAS
TP
mg/L
USACE
USDA
USFS
USFWS
WIDNR
WRWAM
Bureau of Indian Affairs
Best Management Practice
Climate Pollution Reduction Grant
Clean Water Act
Environmental and Natural Resources Department
Hydrologic Soil Group
8-digit Hydrologic Unit Code
10-digit Hydrologic Unit Code
12-digit Hydrologic Unit Code
Milligrams Per Liter
Nonpoint Source
Private Onsite Wastewater Treatment System
Quality Assurance Project Plan
Soil and Water Conservation District
Treatment as a State
Total Phosphorus
Milligrams Per Liter
U.S. Army Corps of Engineers
U.S. Department of Agriculture
U.S. Department of Agriculture, Forest Service
U.S. Fish and Wildlife Service
Wisconsin Department of Natural Resources
Wisconsin Rapid Wetland Assessment Methodology
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1 Overview
The St. Croix Chippewa Indians of Wisconsin (St. Croix) are actively pursuing grant eligibility
under the federal Clean Water Act (CWA) Section 319 to address nonpoint source (NPS)
pollution within tribal boundaries. To qualify for Section 319 funding, tribes must meet four
criteria (USEPA 2010):
1. Be a federally recognized tribe
2. Complete an approved CWA Section 319(a) NPS assessment report
3. Complete an approved CWA Section 319(b) NPS management program
4. Be CWA Section 518(e) approved for Treatment in a Similar Manner as a State
(“treatment as a state” or TAS)
In 2026, the St. Croix completed a NPS Assessment report that summarizes and characterizes
the condition of tribal water resources. This document describes the NPS Management Program
Plan that uses the information from the NPS Assessment report to identify specific activities
which the St. Croix, supported by technical and financial assistance from non-tribal partners,
would like to implement to address NPS pollution and improve tribal water quality.
The NPS Assessment Report characterized water quality within the St. Croix’s tribal boundary
as shown in Figure 1. There are an extensive number of waterbodies and wetlands on St. Croix
lands. Waterbodies on the St. Croix lands are included in one of three Hydrologic Unit Code
(HUC) 8 watersheds: Lower St. Croix, Upper St. Croix, and Red Cedar. The St. Croix Tribal
Environmental and Natural Resources Department (ENRD) manages a surface water quality
program that is 100% funded through grants from the Environmental Protection Agency Clean
Water Act Section 106 Program. Their Clean Water Act (CWA) Section 106 program has
historically monitored water quality of tribal waterbodies at up to 18 monitoring stations,
although only 8 stations are currently monitored on a rotating basis due to funding and capacity
limitations. There is still a significant need to further assess waterbodies associated with St.
Croix lands and refine assessment methodologies to be consistent with other stakeholders.
Section 319 Program funding will support assessment activities and continued development of
assessment methodologies to address NPS pollution. This NPS Management Plan covers
waters of concern with regard to water quality threats and needed improvements, as well as
high-quality surface waters and strategies that protect these waters.
The primary NPS pollutants affecting the St. Croix, as described in the NPS Assessment
Report, include nutrients (phosphorus (P), nitrogen (N)), and sediment (S). WIDNR assessment
data often indicates that many stream reaches qualify as impaired due to total phosphorus and
sediment while not always showing impairment in the biological communities that are present.
Most waterbodies in the State of Wisconsin are contaminated with mercury, representing health
concerns to the St. Croix communities that consume fish and other foods and medicines from
these waterbodies. The NPS Assessment Report identified two HUC8 watersheds of focus for
NPS issues, the Upper St. Croix and the Lower St. Croix. In these two watersheds, ten HUC12
watersheds in the Upper St. Croix and one HUC12 watershed in the Lower St. Croix had
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pollutants of concern, stressors or causes of NPS pollution, and NPS category focus areas
identified. The main NPS category focus areas from the Assessment Report are:
1. Wetland/Riparian Areas
2. Forestry
3. Agriculture
In conjunction with the NPS Assessment Report and ongoing compilation of TAS
documentation, approval of the Management Plan will allow the St. Croix to pursue federal grant
funding to implement structural and non-structural best management practices (BMPs) and
reduce NPS pollution impacts.
Figure 1: HUC8 watersheds with St. Croix lands
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2 Introduction
The St. Croix Chippewa Indians of Wisconsin’s primary goal is to expand the capabilities of their
water quality program to address polluted runoff impacts and minimize NPS pollution on their
lands. In addition, the St. Croix wishes to assess and track the condition of tribal water
resources and achieve attainment of water quality targets and goals within their lands. This NPS
Management Plan covers a period of five years from time of approval.
The NPS Management Program will focus implementation activities on trust lands or upstream
fee simple lands that have a nexus to trust lands through an approach that understands
pollution sources originate from both tribal and nontribal land. The management plan’s intent is
to outline measures that will benefit the watershed as a whole.
Where NPS pollution sources impacting St. Croix waters originate on private or non-trust land,
program staff will work with non-tribal resource agencies, stakeholders, and property owners to
develop workable solutions to the NPS challenges identified. Where funding is needed (i.e.,
where landowners or cooperators are unable to implement NPS control measures using their
own resources), St. Croix NPS Program staff will work cooperatively with Tribal and non-tribal
entities to identify relevant and available funding sources that can be leveraged to address NPS
issues regardless of where they are found.
2.1 Goals and Objectives
The St. Croix Chippewa Indians of Wisconsin are striving to assess, protect, and restore water
quality within and adjacent to the St. Croix Reservation and territory. It is the goal of the St.
Croix to reestablish waters of the reservation to more closely resemble pre-European settlement
conditions. Non-point sources in the watershed continue to release pollutants into the tributaries
and the lakes, and changes in forestry practices and agriculture are priority water quality
concerns. Tribal members utilize water resources for everyday needs including recreation,
cultural practices and as a source of food, particularly Manoomin (wild rice, Zizia palustrus) and
Ogaa (walleye, Sander vitreus). The St. Croix continually works to preserve the culture of their
people and is therefore dedicated to protecting and improving water quality within their lands.
Tribal leaders and members are keenly interested in assessing on a continuing basis the
impacts of these pollutants and the chemical and biological quality of the waters.
To begin development of the NPS Management Program and initiate work to address
overarching NPS pollution reduction goals, the St. Croix NPS Management Program proposes
using its Section 319 funding to address the following objectives:
●
Establish a baseline of surface water quality on selected tribal lands to identify waters
that cannot meet or maintain water quality goals or thresholds for nutrients, bacteria, and
sediment without control of NPS pollution; the state of Wisconsin water quality standards
have been adopted by the St. Croix as interim water quality goals until such a time that
St. Croix water quality standards are implemented.
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●
●
●
●
●
Determine extent to which surface water quality is changing over time related to NPS
pollutants including nutrients, bacteria, and sediment.
Identify problem areas with poor surface water quality and/or the potential to degrade
surface water quality stemming from NPS pollution and the causes and sources of those
pollutants.
Identify those tribal waters meeting water quality goals and thresholds to identify if
protection measures are needed and at what level.
Continue and expand current monitoring and reevaluation as necessary.
Expand staff monitoring capacity by hiring additional field technicians.
Section 4, Management Program Summary, includes further detailed goals and objectives
based on the results of the NPS Assessment report findings and stakeholder input. The St.
Croix NPS Management Program focuses on BMP implementation and strategies to address
NPS pollution affecting St. Croix waters within trust lands. However, as noted above, the St.
Croix recognizes the need to collaborate with non-tribal partners to ensure that NPS pollution
upstream of tribal waters is also effectively addressed.
2.2 Watersheds of Focus
The St. Croix have determined that for the first five-year Management Plan they will place initial
focus, when it makes sense to do so, on water resources in the following HUC12 watersheds.
These HUC12s were chosen based on review of available water quality data, cultural priorities,
tribal NPS pollution concerns, high-quality natural resources and habitat to protect, and best
distribution of St. Croix resources and capacity.
As identified in the St. Croix Section 319 Assessment Report, surface water monitoring
conducted on St. Croix waters has identified NPS pollutants and potential sources in the focus
HUC12s identified in the following table. NPS pollutants of concern include nitrogen (N),
phosphorus (P) and sediment (S) as shown in Table 1. Goal attainment categories are
referenced from the Assessment Report Section 5.2 Summary of Water Quality Data (pp 59-60)
and defined below. Each focus HUC12 may include a combination of impacted/threatened and
protection activities.
●
●
●
Impacted – River/stream sites that had at least three pollutants with data in exceedance
of the goal are considered Impacted by NPS pollution.
Threatened –. Rivers and streams that had one to two pollutants with data in
exceedance of the goal are considered Threatened by NPS pollution.
Protection – Rivers/streams without any goal exceedances are identified solely for
Protection activities.
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Table 1: Focus HUC12s and associated key water resources
Upper St. Croix HUC8 07030001
HUC12 Watershed
Pollutants
of
Tribal Waters
Concern
Gaslyn Lake
Sand Lake-Yellow River
070300010501
S, N
Yellow River
(County H)
Gaslyn Creek
Big Sand Lake-Yellow River
070300010502
Loon Creek 070300010505
Buffalo Lake-Yellow River
070300010506
Sand Creek 070300010803
S, N
S, N
S, N
S, N
S, N, P
Big Sand Lake
Loon Creek
Yellow River
(North & South)
Goal
Attainment
NPS Focus
Areas
Threatened
Removal of streamside
vegetation, timber
Threatened
harvesting, road
construction/use,
wetland & riparian loss
Threatened
Wetland /
Riparian
Areas,
Forestry
Removal of streamside
vegetation, timber
harvesting, road
Threatened
construction/use,
wetland & riparian loss
Wetland /
Riparian
Areas,
Forestry
Removal of streamside
vegetation, timber
harvesting, road
Threatened
construction/use,
wetland & riparian loss
Wetland /
Riparian
Areas,
Forestry
Removal of streamside
vegetation, timber
harvesting, road
Threatened
construction/use,
wetland & riparian loss
Wetland /
Riparian
Areas,
Forestry
Sand Lake
Removal of streamside
vegetation, timber
Threatened
harvesting, road
construction/use,
wetland & riparian loss
Wetland /
Riparian
Areas,
Forestry
Clam Lake
Impacted
Removal of streamside
vegetation, timber
harvesting, road
construction/use,
wetland & riparian loss,
agricultural runoff,
erosion
Wetland /
Riparian
Areas,
Forestry,
Agriculture
Impacted
Removal of streamside
vegetation, timber
harvesting, road
construction/use,
wetland & riparian loss,
agricultural runoff,
erosion
Wetland /
Riparian
Areas,
Forestry,
Agriculture
Clam Lake-Clam River
070300010904
S, N, P
NPS Stressors
Clam River
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Black Brook-Clam River
070300010906
Hay Creek-Saint Croix River
070300011202
S, N, P
None
Impacted
Removal of streamside
vegetation, timber
harvesting, road
construction/use,
wetland & riparian loss,
agricultural runoff,
erosion
Wetland /
Riparian
Areas,
Forestry,
Agriculture
St. Croix River
Protection
Limit removal of
streamside vegetation,
limit ag/development
impacts near the river,
protect existing
riparian/wetland areas
Wetland /
Riparian
Areas,
Forestry
Straight River
(North & South)
Legacy P loading from
Big Round Lake,
removal of streamside
vegetation, timber
harvesting, road
Threatened
construction/use,
wetland & riparian loss,
agricultural runoff,
erosion, streambank
erosion
Wetland /
Riparian
Areas,
Forestry,
Agriculture
Big Round Lake
Legacy P loading,
removal of streamside
vegetation, timber
harvesting, road
construction/use,
wetland & riparian loss,
agricultural runoff,
erosion, streambank
erosion
Wetland /
Riparian
Areas,
Forestry,
Agriculture
Clam Lake (Pike
Bend)
Lower St. Croix HUC8 07030005
S, N
Straight River 070300050702
S, N, P
Impacted
Sand Lake-Yellow River HUC12 (070300010501)
This HUC12 is ranked by the state of Wisconsin for ecological health in the top third of 36
HUC12s identified as the top 30% healthiest watersheds within the St. Croix HUC6 (includes
Upper and Lower St. Croix HUC8s). This HUC12 is specifically noted by WIDNR for its highquality lakes and rivers.
Gaslyn Lake was categorized by the St. Croix in 2022 as mesotrophic, meaning it typically has a
moderate supply of nutrients, experiences moderate algal blooms, and has occasional oxygen
depletions at depth. Phosphorus trends over the last five years of sampling at Gaslyn Lake and
Gaslyn Creek show some minor fluctuations in total P within the lake year to year, but no
significant trending increases or decreases. However, significant exceedances of nitrogen and
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sediment (turbidity) were noted in the sampling data, so further monitoring and sampling is
recommended to determine trends and potential issues.
It is worth noting that there is very little residential development along Gaslyn Lake.
Development is restricted along the entire east shoreline due to County Highway H, and only
one house is directly on the lakefront while less than 10 houses are within 500 feet of the
shoreline. This lack of lakefront development is likely contributing to Gaslyn Lake’s trophic
status, and protection/natural enhancement of the remaining undeveloped shoreline along
Gaslyn Lake and the forest canopy cover along Gaslyn Creek should be a priority to maintain
water quality. The Yellow River riparian corridor within this HUC12 is mostly undeveloped, with
a large percentage flowing through county owned forest land. Sampling in the river shows
elevated levels of phosphorus compared to Gaslyn Lake and Gaslyn Creek, with a slight upward
trend over the last five sampling years. This may be the result of increasing P sources further
upstream in the watershed. Further monitoring is recommended, as well as minimizing removal
of streamside vegetation and other actions (timbering, further development in the riparian area)
that could increase nutrient and sediment loading.
Big Sand Lake-Yellow River HUC12 (070300010502)
The Big Sand Lake-Yellow River HUC12 is ranked by the state for ecological health in the
middle third of 36 HUC12s identified as the top 30% healthiest watersheds within the St. Croix
HUC6 (includes Upper and Lower St. Croix HUC8s). Big Sand Lake is classified by WIDNR as a
Deep Seepage lake, an Outstanding Resource Water, and an Exceptional Resource Water.
Past trophic state index calculations by St. Croix classified the lake as mesotrophic.
While the lake is attaining state phosphorus criteria, sediment is a local concern, and the
nitrogen levels from tribal sampling exceeded USEPA criteria. Shoreline stabilization in various
locations along the lake has been performed by St. Croix in the past to prevent excessive
sediment from washing into the lake. Tribal members fish for a variety of species in Big Sand
Lake including bluegill, black crappie, walleye, largemouth bass, yellow perch, and northern
pike, so protection of fisheries is a priority. Areas of wild rice also exist on Big Sand Lake and
historically were larger. Continued shoreline protection and enhancement actions to protect and
restore native lakeside vegetation including wild rice is recommended to maintain the lake’s
water quality.
Loon Creek HUC12 (070300010505)
The Loon Creek HUC12 includes one tribal sampling station on Loon Creek, which is a small
tributary of the Yellow River. The creek contains gravel/cobble substrate at the sampling
location but shifts to sand and silt in other locations. Total P sampled at this location across all
sampling years showed zero exceedances of the WIDNR total P criteria, and less than half of
the samples exceeded the USEPA total P criteria. However, the site showed exceedances of
turbidity and nitrogen from past tribal sampling. Tribal sampling at this location has included
macroinvertebrates, which showed a high degree of taxonomic richness with almost 80% EPT
taxa, a strong indication of good water quality and reinforced by the total P data. The HUC12 is
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ranked by the state for ecological health in the lower third of 36 HUC12s identified as the top
30% healthiest watersheds within the St. Croix HUC6 (includes Upper and Lower St. Croix
HUC8s), a further indicator of good water quality. NPS recommendations for this HUC12 include
continued stream monitoring and protection of existing riparian cover and adjacent wetlands,
and implementation of best practices for forestry management.
Buffalo Lake-Yellow River HUC12 (070300010506)
The Buffalo Lake-Yellow River HUC12 is ranked by the state for ecological health in the lower
third of 36 HUC12s identified as the top 30% healthiest watersheds within the St. Croix HUC6
(includes Upper and Lower St. Croix HUC8s). The HUC12 includes two tribal monitoring
stations, Yellow River-North and Yellow River-South, both situated along the Yellow River. The
drainage area consists of mostly forested wetland and upland with a very low level of
development, which contributes to the HUC12’s overall good water quality. While the Yellow
River is not impaired from phosphorus following state criteria in this location, tribal sampling
indicated exceedances of USEPA criteria for phosphorus, nitrogen, and turbidity, so nutrient and
sediment levels should continue to be monitored. NPS recommendations for this HUC12 include
protection of existing riparian cover and adjacent wetlands, implementation of best practices for
forestry management, and other best practices that reduce nutrient and sediment loading.
Sand Creek HUC12 (070300010803)
The Sand Creek HUC12 contains Sand Lake, which is classified as a Deep Lowland, ORW, and
ERW by WIDNR and it is fully attaining both its Aquatic Life and Recreational uses. It is
considered a high-quality body of water with a good fishery; muskellunge, panfish and walleye
are fished by tribal members and the lake is stocked with walleye fingerlings by the St. Croix, so
protection of existing fisheries is a priority. While sampling does not show excessive phosphorus
following state criteria, phosphorus, nitrogen and sediment exceedances of USEPA criteria were
noted from tribal sampling. Exceedances of the USEPA phosphorus criteria occurred in all
phosphorus sampling years. Nitrogen sampling years had exceedances of the USEPA criteria in
the four most recent sampling years (2017, 2018, 2023, 2024). Turbidity exceedances were
consistent throughout all sampling years. NPS recommendations for this HUC12 include
continued monitoring and protection of existing riparian cover and adjacent wetlands around the
lake, and implementation of best practices for forestry management.
Clam Lake-Clam River HUC12 (070300010904)
The Clam Lake-Clam River HUC12 includes two tribal monitoring stations, Clam Lake and Clam
River-Lynch Bridge. Clam Lake is listed as impaired by WIDNR for excess phosphorus due to
excess algal growth and eutrophication. In contrast, the Clam River is identified by WIDNR as
an Outstanding Resource Water and is currently attaining its cold water Aquatic Life Use.
Algae blooms are noted by the St. Croix as a priority concern at Clam Lake, likely influenced by
nutrient loading, and the Clam River is showing an upward trend of phosphorus and nitrogen
loading. Continued monitoring of both waterbodies is recommended to stay on top of NPS
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trends. Clam Lake is also likely affected by upstream agricultural use in the Clam River
headwaters. St. Croix priorities for Clam Lake are to restore wild rice, water quality, fisheries,
and waterfowl populations. Wild rice acreage at Clam Lake is considered to be one of the best
in Northwest Wisconsin, so protection of existing acreages by reducing nutrient and sediment
loading along with restoration and enhancement of the shoreline is both a water quality priority
and a cultural priority for the St. Croix.
Black Brook-Clam River HUC12 (070300010906)
The Black Brook-Clam River HUC12 includes the furthest downstream outlet of Clam Lake on
Clam River. As mentioned earlier, the Clam River is identified by WIDNR as an Outstanding
Resource Water and is currently attaining its cold-water Aquatic Life Use, with parts of the river
being class I and III trout water, however, tribal sampling in this part of the Clam River shows
elevated phosphorus, likely influenced from the upstream Clam Lake. NPS recommendations
for water quality are therefore tied to the recommendations in the Clam Lake-Clam River
HUC12, as well as protecting and restoring adjacent riparian and wetland areas along the Clam
River downstream of Clam Lake.
Hay Creek-Saint Croix River HUC12 (070300011202)
This HUC12 is ranked by the state for ecological health in the top third of 36 HUC12s identified
as the top 30% healthiest watersheds within the St. Croix HUC6 (includes Upper and Lower St.
Croix HUC8s). It is specifically noted by WIDNR for its high-quality rivers, including the St. Croix
River. The St. Croix River in this location is classified as an Outstanding Resource Water and as
an Exceptional Resource Water. The entire river is also a national wild and scenic waterway as
designated by the National Park Service. Tribal water quality monitoring shows low phosphorus
levels compared to other monitored rivers. Within tribal lands, NPS activities for this HUC12 are
focused on protection, mainly protecting existing wetland/riparian areas, limiting timbering and
removal of streamside vegetation, and limiting agriculture/development near the river.
Straight River HUC12 (070300050702)
The Straight River HUC12 includes two tribal waterbodies: Big Round Lake and Straight River.
Big Round Lake is impacted from loss of lakeside habitat; over 75% of its lakeshore is
developed. St. Croix lands are located on the northeast corner of the lake. Algal blooms occur at
Big Round Lake annually, and were observationally getting worse in spread as of 2019 per tribal
information. Internal phosphorus loading is suspected to be an issue at Big Round Lake, and
alum has been discussed as a treatment with the surrounding lake associations. Small, remnant
crops of wild rice are located on and adjacent to the tribal lands on the northeast shore. Given
the level of lakeside development, it may be difficult to restore additional wild rice populations,
but the tribe is interested in preserving existing wild rice populations. In addition to wild rice,
tribal members spear and fish Big Round Lake and the lake is known for its waterfowl habitat.
The lake is currently not attaining its state Fish and Aquatic Life or Recreational uses due to
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algal blooms and eutrophication. A long-term NPS-focused lake management plan is
recommended to directly address the legacy phosphorus in the lake sediments and manage the
lakeshore to minimize further nutrient and sediment inputs.The Tribe will need to work with
adjacent landowners and lake associations to collaborate on the management plan.
The Straight River, in contrast, is listed by WIDNR as a trout water and is in attainment of its
Cold Water Fish and Aquatic Life use, but despite being overall a high-quality river, the river in
this location is likely heavily influenced by the excess phosphorus in Big Round Lake. NPS
recommendations to improve water quality are therefore tied to the recommendations for Big
Round Lake, as well as protecting and restoring adjacent riparian and wetland areas along the
Straight River upstream of Big Round Lake.
2.3 Tribal Authority for Implementing the NPS Management
Program
The legal authority for the administration of the St. Croix Chippewa NPS Management Program
is based on a June 18, 1934 decision under the Indian Reorganization Act that established
lands and a legal federal tribal status for the St. Croix Chippewa Indians of Wisconsin. The Tribe
adopted a Constitution and Bylaws on August 29, 1942, which was approved by the
Commissioner of Indian Affairs on November 12, 1942. Article II, Section 2 of the Constitution
and By-Laws of the St. Croix Chippewa Indians of Wisconsin reads:
The jurisdiction of the St. Croix Chippewa Indians of Wisconsin shall extend to all the land and
water areas within the territory of the Tribe and, further, for the purpose of exercising and
regulating the exercise of rights to hunt, fish, trap, gather wild rice and other usual rights of
occupancy, such jurisdiction shall extend to all lands and waters described in treaties to which
the Tribe was a party, which treaties provide for such rights.
The St. Croix Chippewa NPS Management Program will be administered by the Environmental
and Natural Resources Department (ENRD). The ENRD has been managing the tribal Section
106 program since 1996 and is responsible for managing the following tribal programs:
●
●
●
●
●
●
Surface water quality monitoring
Indoor air quality monitoring
Walleye and sturgeon restoration
Wild rice management
Recycling
Examining lands potentially containing hazardous substances
They also oversee the tribal General Assistance Program and management of tribal Geographic
Information Systems (GIS) data, which help inform watershed-based planning and
implementation. There is no specific tribal ordinance related to nonpoint source management;
however, tribal documents that help guide decisions on nonpoint pollution management issues
include:
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●
●
●
St. Croix Reservation Natural Resources Code
Quality Assurance Project Plan (QAPP) for Surface Water Quality Assessment 20232028 (updated every 5 years)
St. Croix Chippewa Indians of Wisconsin Tribal Water Monitoring Strategy 2021-2026
(updated every five years)
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3 NPS Management Plan Implementation
This section describes how the St. Croix Chippewa intends to implement the NPS Management
Plan, including the structure of implementation within the context of the existing tribal
government, monitoring and assessment activities, and anticipated partnerships with nontribal
partners. As described in Section 2.2, the Tribe will focus activities in priority HUC12
watersheds on trust lands during the first five years, dependent on staff and funding availability.
Where appropriate, nontribal partnerships would allow for implementation of NPS control
measures outside of St. Croix trust lands. The St. Croix Chippewa are looking to implement
projects to improve or protect water quality on tribal waters such as the installation of Best
Management Practices (BMPs); road culvert replacements; comprehensive forestry
management, stormwater management; riparian/wetland restoration and projects to improve
habitat for biological communities like fish and wild rice.
As part of their NPS program, the St. Croix are planning to implement a total phosphorus
reduction practice by August 2027 following recommendations and information gathered during
the St. Croix Assessment Report development process. This is described in more detail in
Section 4, Management Program Summary.
3.1 Implementing the NPS Management Program with St. Croix
Tribal Governance
The St. Croix Environmental and Natural Resources Department will have primary responsibility
for implementation and administration of the NPS Management Program. Several other St.
Croix departments will support this work in their respective areas such as Communications,
Intergovernmental Affairs, Grants, and Roads. Open communication and cooperation across
tribal departments and divisions will be essential during the implementation process. The ENRD
plans to hire additional staff to assist with NPS program implementation and coordination across
tribal departments and programs.
Table 2: Anticipated tribal entities involved in implementation of the Tribal NPS Management Program
Tribal Department
Description
Environmental and Natural Resources Primary responsibility for implementation and administration of the NPS
Department
Management Program.
Tribal Communications Department
Responsible for positive, consistent messaging and strategies involving
policies and procedures, narratives, and public relations between the Tribal
government departments, clients, employees, and funding agencies. Assist
with public outreach and comment for NPS planning purposes.
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Tribal Intergovernmental Affairs
Department
Consultation, coordination, and collaboration with government partners
and agencies on a municipal, county, state, and federal level. Work to
support and preserve government-to-government relationships and
enhance access to programs and services available to the St. Croix Tribe,
tribal organizations, tribal programs, and community members.
Tribal Grants Department
Works with tribal departments, program directors, staff, and community
members to plan program initiatives, design projects, and identify funding
opportunities. Assist programs with grants administration and help insure
grant compliance.
Tribal Roads Department
Oversees the maintenance, construction, and safety of the roads that
reside in the St. Croix Tribal reservation communities. Work with
neighboring municipalities, county, and state agencies and the federal
government to provide St. Croix communities with safe, passable, and
well-maintained roads.
3.2 Existing Tribal Plans, Ordinances, & Policies
The St. Croix have been involved with several existing planning and policy efforts which have
supported ongoing tribal water quality work, and which will continue to support NPS
Management Program implementation. This work has been supported financially by the St.
Croix and partnerships and funding from governmental programs.
Examples of planning efforts and policies include:
● Water-resources-related information for the St. Croix Reservation and vicinity, Wisconsin
● St. Croix Chippewa Indians of Wisconsin CPRG Priority Climate Action Plan
● Feasibility Study for Biomass Electrical Generation on Tribal Lands
● St. Croix Forest Inventory, Planning, and Climate Change Susceptibility Project
● Natural Resources Code
● Brownfields Rehabilitation Ordinance
● Off-Reservation Conservation Code
● Solid Waste Management and Recycling Ordinance
● Water and Wastewater Utility Ordinance
3.3 Key Partners for NPS Program Implementation
The St. Croix Chippewa intends to collaborate with multiple local, state and federal partners to
help address sources of NPS pollution. Collaboration will provide technical assistance, aid in
education and outreach efforts, implement demonstration projects and possibly provide financial
assistance to promote implementation as identified in Section 3.4. The nature of this
collaboration may depend on the NPS category, the type of BMP, and the geographic location
targeted for implementation. Table 2 presents the participants, the mission of each agency, and
their potential roles in NPS Program implementation. Core participants in program
implementation are highlighted.
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Table 3: Partners, Mission and role in BMP selection for Tribal trust lands
Partner
Mission
Role in BMP selection
St. Croix Chippewa Indians of Wisconsin
Tribal Council
Legislative and Executive Branch
of the St. Croix Chippewa
government
Make and enact laws, including codes,
ordinances, resolutions and statutes
related to Tribe's lands, interests in lands,
management of those lands. Regulate
activities on lands within Tribal jurisdiction.
Authorize expenditures by law and
appropriate funds
Environmental and
Natural Resources
Department (ENRD)
Responsible for the development
of expansion, management, and
protection of environmental
resources on Tribal lands
Lead role in BMP selection,
implementation, and coordination
Tribal Communications
Promote positive, consistent
messaging and strategies involving
policies and procedures,
Spearhead public outreach and
narratives, and public relations
communication on NPS issues and projects
between the Tribal government
departments, clients, employees,
and funding agencies
Tribal Intergovernmental
Affairs Department
Consultation, coordination, and
collaboration with government
partners and agencies on a
municipal, county, state, and
federal level. Work to support and Facilitate communication with federal
agencies on NPS issues and
preserve intergovernmental
relationships and enhance access implementation
to programs and services available
to the St. Croix Tribe, tribal
organizations, tribal programs, and
community members
Works with tribal departments,
program directors, staff, and
community members to plan
program initiatives, design projects,
Assist with NPS project funding
Tribal Grants Department
and identify funding opportunities.
Assist programs with grants
administration and help insure
grant compliance
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Oversight of the maintenance,
construction, and safety of the
roads that reside in the St. Croix
Tribal reservation communities.
Work with neighboring
Tribal Roads Department
municipalities, county, and state
agencies and the federal
government to provide St. Croix
communities with safe, passable,
and well-maintained roads
Coordinate with ENRD on NPS best
practices during road projects
NGO, Local, State, Federal Partners
WI Tribal Conservation
Advisory Council
(WTCAC)
Provide a forum for the 11 Native
American Tribes in Wisconsin to
identify and solve natural resource
issues on tribal lands.
Environmental nonprofits
and foundations (i.e.,
Nature Conservancy,
Various conservation efforts and
Sauk Prairie
funding programs provided at
Conservation Alliance,
national, state, and local level
Valley Stewardship
Network, Wisconsin
Wetlands Association)
Technical assistance with identification of
resource concerns and selection of BMPs;
BMP engineering services and oversight
during construction
Partner in NPS Program implementation as
needed and potential source of funding,
technical expertise and support
Towns, Cities and
Townships
Local environmental, land, health
and road management
departments serving St. Croix
communities.
Partner in BMP selection, land-use
planning, stormwater management and
other urban area activities
County Land
Conservation and
Highway Departments
Develop strategies, implement
programs, and provide technical
assistance related to land and
infrastructure
Partner in watershed planning, BMP
selection and implementation; provide costsharing for conservation practices.
Technical assistance and support related to
highway infrastructure
WI Dept. of
Transportation
Provide safe and effective
transportation infrastructure
Technical assistance, partner in BMP
selection and ROW management
WI Dept. of Natural
Resources
Assist tribes with water resources
issues
Partner in watershed planning, technical
and financial assistance, water quality
monitoring technical assistance
Bureau of Indian Affairs
Maintain government to
government relationships with
Tribes
Technical assistance and provide funding
for BMP installation
U.S. Environmental
Protection Agency
(USEPA), Region 5
Administers the Section 319
Nonpoint Source Management
program
Partner in watershed planning, technical
assistance, BMP selection, funding for
BMP installation, stormwater management
U.S. Army Corps of
Engineers (USACE)
Assist tribes with water resources
issues
BMP selection and implementation,
permitting, funding, technical assistance
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USDA-NRCS
Deliver conservation solutions so
agricultural producers can protect
natural resources and feed a
growing world.
Partner in identifying resource concerns,
BMP selection and implementation; provide
cost-sharing for conservation practices
U.S. Fish and Wildlife
Service
Provide assistance for programs
related to fish and wildlife
resources.
Technical and financial assistance,
permitting/review for T&E species, BMP
selection for fish passage
3.4 NPS Funding Sources
The following sources of funding may be used to assist the NPS Management Program with
meeting the identified goals and objectives under this plan and future efforts:
● USEPA CWA Section 106 grants
● USEPA CWA Section 319 (competitive and non-competitive grants)
● USEPA Wetland Program Development Grants (WPDGs)
● CWA Tribal Set-Aside Program, Wastewater Infrastructure
● USEPA Environmental Education grants
● USEPA Clean Water State Revolving Fund Program (CWSRF) grants
● U.S. Fish and Wildlife Service (USFWS) North American Wetlands Conservation Act:
U.S. Standard grants
● USFWS Tribal Wildlife grants
● NRCS Environmental Quality Incentives Program (EQIP)
● NRCS Conservation Stewardship Program (CSP)
● NRCS Healthy Forests Reserve Program
● Farm Service Agency Conservation Reserve Program (CRP)
● Farm Service Agency Conservation Reserve Enhancement Program (CREP)
This list is not comprehensive, and other sources of funding may also be used as they are
identified or become available. Additional information on funding sources and associated
programs can be found in the St. Croix Chippewa Indians of Wisconsin NPS Assessment
Report Section 8 Existing NPS Control Programs (p. 73).
3.5 NPS Management Program Monitoring & Assessment
The St. Croix Chippewa Indians of Wisconsin are striving to assess, protect, and restore water
quality within and adjacent to the St. Croix Reservation and territory. It is the goal of the St.
Croix to reestablish waters of the reservation to more closely resemble pre-European settlement
conditions. Non-point sources in the watershed continue to release pollutants into the tributaries
and the lakes, and changes in forestry practices and agriculture are priority water quality
concerns. Tribal leaders and members are keenly interested in assessing on a continuing basis
the impacts of these pollutants and the chemical and biological quality of the waters.
The St. Croix NPS Assessment Report indicates where some NPS pollution problems occur, but
additional monitoring and assessment is needed to further assess waterbodies using
methodology in alignment with other stakeholders such as the WIDNR. The St. Croix need
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continuing information regarding water quality conditions of the reservation and the surrounding
territory to identify trends within the reservation and determine if they support the needs of the
tribal community. Currently, the St. Croix is rotationally monitoring four lakes and four river
sections per year between three different counties, and their Section 106 budget has either
remained static or decreased over the past 26 years. More funding is sorely needed to boost
staffing and time to increase monitoring frequency and locations. Due to the high number of
water bodies associated with St. Croix lands and lack of program funding, the Tribe is limited in
the number of water bodies that can feasibly be monitored each year.
Additional water quality monitoring at existing sites on a more frequent basis and the addition of
more robust biological monitoring is needed to assess the effectiveness of the NPS
Management Program and focus future implementation activities in priority areas. General
monitoring will continue using CWA Section 106 funds, but increased frequency and the
addition of parameters will require additional sources of funding. Monitoring and assessment
under the NPS Program will also assist with refinement and/or development of water quality
goals and threshold with which to assess and track the condition of tribal waters. This will
support the development of federally approved water quality standards for St. Croix waters.
Once final water quality standards have been approved, CWA Section 319 program funds would
be directed to project monitoring and assessment to determine impairments against approved
standards; determine BMP effectiveness; and to assist with prioritization of NPS Program
activities.
Funding plays a crucial role in the ENRD’s ability to monitor, assess and manage resources
associated with Tribal land. Currently, all water quality monitoring is funded by the 106 Program
which has severely limited monitoring activities. Continued reliance on outside sources of
funding (including CWA Section 106) for NPS Management Program implementation is
expected. Table 3 provides an overview of the St. Croix NPS Management Program monitoring
and assessment activities planned.
Table 4: NPS Management Program monitoring and assessment activities
Activity
Frequency
Continuing and Expanding WQ Monitoring
Annually
Review and Update Program Priorities
Annually
Monitoring Effectiveness of BMPs
Project and Site Specific
Assessment of WQ data against goals and thresholds Every 5 years
Review and Revise NPS Management Program
Every 5 years
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3.6 NPS Management Program Coordinating & Reporting
The St. Croix ENRD will be primarily responsible for coordinating NPS program implementation
between various Tribal departments and non-tribal partners. Staff responsibilities will be to
develop a tracking and reporting approach that involves relevant Tribal departments with a role
in program implementation. ENRD’s current effort documenting water quality monitoring and
delineated wetlands will be expanded to include NPS implementation activities along with
documentation of spatial data in the St. Croix GIS including locations of existing and proposed
BMPs. In addition, the tribe will, for the purposes of consistency of this Nonpoint Source
Program, review other federally funded projects (such as individual assistance applications or
development projects) which the Tribe intends to implement to ensure those projects are
consistent with the program.
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4 Management Program Summary
Non-point sources in the watershed continue to release pollutants into the tributaries and the
lakes, and changes in forestry practices and agriculture are priority water quality concerns.
Tribal members utilize water resources for everyday needs including recreation, cultural
practices and as a source of food, particularly Manoomin (wild rice, Zizia palustrus) and Ogaa
(walleye, Sander vitreus). Water quality in St. Croix territory is primarily affected by Forestry,
Agriculture, and Wetland/Riparian Areas NPS categories. Major pollutants of concern within the
initial five-year management plan HUC12s are phosphorus and nitrogen (nutrients), which are
drivers of algal blooms in lakes, and sediment (turbidity) which degrades lacustrine and riverine
habitat.
The overall goal of the management program is to control or prevent NPS impacts and improve
water quality on St. Croix lands. Goals to increase monitoring sites and frequency, as well as
establish water quality standards, ensure that the Tribe can effectively observe water quality
trends and ensure that all water sources meet water quality standards for their designated uses.
The nonpoint source pollution management program, in conjunction with other St. Croix
programs will contribute to this objective. General program milestones are listed below.
Table 5: General program milestones
Activity*
Frequency/End Year
Submit NPS Assessment Report to USEPA
2026
Submit Management Program to USEPA
2026
Submit application for Treatment as a State for CWA Section 319
2026
Propose NPS Management Plan to Tribal Council
2026
Implement phosphorus reduction BMP
2027
Update management program as needed and review with ENRD and Tribal
Council
Annually
Submit annual status reports to USEPA
Annually
ENRD review projects and overall program and set priorities for next fiscal year
Annually
Incorporate priorities into work plan for NPS program and submit to funding
agencies
2026 and beyond
*Completion of nonpoint source activities will be contingent on program funding.
The St. Croix Chippewa Assessment Report lists categories of nonpoint source pollution that
have been confirmed or are potential sources, as shown in the below table. The specific
management programs for these categories will focus on prioritizing locations of NPS,
identifying appropriate BMPs, and implementing BMP demonstration projects. If the NPS
impairment source is not within Tribal lands, implementation will only occur within the watershed
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with nexus to Tribal waters. The following considerations will be used in making final
management decisions regarding priorities and BMPs:
●
●
●
Severity of pollution problem and extent of impairment of beneficial uses
Potential for effectively addressing the pollution problem, given technical and financial
constraints (i.e., optimizing economic benefits)
Public participation and landowner cooperativeness
Table 6: Categories of NPS and their applicability to the St. Croix Chippewa
NPS issue in St. Croix Trust
Waters
EPA NPS Category
Confirmed
Impairment
Possible (using
Source
visual
Primarily From
documentation) Nontribal Land
Forestry
Erosion from logged areas
X
Removal of streamside vegetation
Forest management planning
X
X
Culverts
X
Logging road construction/maintenance
X
Wetland/Riparian Areas
Wetland quality assessment
X
Protection of high-quality riparian & wetland areas
X
Increase riparian buffer quality and size
X
Degradation of shoreline & streambank habitat
X
Agriculture
Row cropping
X
X
Grazing sources
X
X
Urban Areas
Shoreline development
X
Stormwater runoff from impervious surfaces
X
Erosion & Sedimentation
X
X
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4.1 BMP Selection
As the St. Croix NPS Management Program will be the primary responsibility of the ENRD, they
are expected to lead the activities identified in this section, sometimes sharing that responsibility
with relevant ENRD departments and programs. Coordination with non-tribal partners and other
tribal divisions will occur as needed. The St. Croix will make every attempt to leverage existing
planning efforts and funding for implementation activities. ENRD also recognizes that additional
assessments, inventories, partnership development, and outreach activities are essential first
steps to addressing NPS pollution within the timeframe of this NPS Management Plan.
The St. Croix will undertake the following process for evaluating and selecting BMPs to address
NPS pollution. The Tribe will coordinate with the agencies listed below in Section 3.3 as well as
interface with the public in order to select target BMPs. The process to select BMPs include:
●
●
●
●
●
●
Review monitoring data, recent watershed planning work, and other resources and use
best professional judgment for determining which locations will be areas of initial focus.
Consult with tribal partners regarding prioritization list, key NPS pollutants, relative
magnitude of pollutants in each subwatershed, and opportunities for implementation.
Identify applicable BMPs appropriate for the type and source of NPS pollution, with the
technical assistance and consultation of partners.
Narrow and rank the list of applicable BMPs using evaluation factors of estimated
performance and feasibility.
Identify BMPs that have the potential for collaborative, coordinated implementation with
key partners.
Pursue funding for approved suite of BMPs with tribal council, tribal member, and public
support.
Education and outreach activities are also priorities for the St. Croix NPS Management Program
in order to protect and improve the many high-quality resources of the St. Croix (Table 4).
Education is needed that focuses on the effects of NPS pollution, the necessary changes in
behavior to reduce NPS pollution, and the wide array of benefits generated through BMP
implementation. The ENRD will collaborate with the Tribal Communications Department to
develop and implement education and outreach strategies. The BMPs presented under each
NPS category will be successful when key stakeholders are educated and motivated to change
NPS-related behavior.
Table 7: NPS education and outreach activities
Activity
Target Audience
Develop and conduct tribal staff training on general NPS pollution
St. Croix staff, various
Depts/Divisions
Collaboration with outside agencies on agriculture NPS and BMP
education training (cover crops, no-till, buffers, grassed waterways,
highly erodible land, nutrient mgmt)
Agricultural landowners within
target HUC12s
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Land Management NPS and BMP education training (forestry, erosion
BMPs, soil and erosion control, native plantings)
St. Croix staff and tribal
landowners
Wetland/Riparian NPS and BMP (wetland disturbance avoidance &
minimization, protecting buffers, restoration of degraded habitat)
Tribal landowners, members,
and adjacent nontribal
communities and associations
The following sections provide details on the goals, objectives, and activities that will address
the NPS categories in this document and in the NPS Assessment Report. Lead entities,
partners, and suggested locations are also identified. As the St. Croix NPS Management
Program will be the primary responsibility of the ENRD, they are expected to lead the activities
identified in this section, sometimes sharing that responsibility with relevant Tribal departments
and programs. Non-tribal partners and other tribal divisions will be consulted as needed. In
addition to the Tribal guidance described earlier, regional, state, and federal guidance exists to
help select BMPs. Current examples include the NRCS’s Wisconsin-specific Field Office
Technical Guide, the Forest Service Manual, and the USEPA Tribal Water and Natural
Resources Conservation Guide.
Forestry
Deciduous forest and woody wetlands comprise the majority of St. Croix forested lands, with
mixed forest and evergreen forest making up smaller percentages for a total of 69.5% forested
cover. Timbering activities have historically been restricted by the Tribe; however, recent mass
tree clearing due to storm damage has raised concerns about the need for planned forestry
management on Tribal lands, particularly in ways that minimize NPS pollution. Forest harvest
and management activities can increase stream temperatures, bank erosion, siltation and
sedimentation of surface waters, and damage nearby vegetation. Impacts from forestry are
most significant along forest roads and in areas near sensitive ecosystems and important
resources. Construction, maintenance, and heavy use on forest roads can result in erosion,
sedimentation, removal of vegetation, and soil compaction. Harvesting practices can reduce
shade provided to aquatic habitats, which often leads to increased water temperatures,
impacted food sources, and other negative impacts to aquatic species and habitats (USEPA
2022). Seasonal ponds and wetlands are especially sensitive to these impacts. Soil compaction
along forest roads can disturb fragile roadside wetland ecosystems, leading to increased
overland flows and greater erosional potential and sedimentation of waterbodies. Improper
management of forested areas can also impact groundwater quality and quantity.
The St. Croix’s long-term goal is to minimize the NPS pollutant contributions from managed
forest associated with Tribal lands by reducing potential sources of sediment and nutrients to
nearby waters. Near-term objectives and activities are presented below.
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Table 8: Near-term objectives and activities Forestry NPS category
Activity
Lead
Suggested Effectiveness
Partners
Entities
Location
Measure
Funding
Objective 1: Identify and restore cleared areas.
Inventory and map
problem areas with
erosion
Restore cleared areas to
native forest
ENRD
ENRD
N/A
Locations that Mapped and
were logged inventoried GIS WIDNR, EPA,
from past
layer of extent CWA Sec 319
storm events of logged areas
Areal cover of
Locations that restored
EPA, CWA Sec
WIDNR, were logged location,
319, USFS,
NRCS from past
quantity and
USDA-NRCS
storm events type of planted
species
Objective 2: Develop forest management plan.
Develop forest
management plan for St.
Croix lands
ENRD
Tribal
Council
All tribal
lands, initial
focus on
HUC12
priority
watersheds
Approved forest
EPA, CWA Sec
management
319, USFS
plan
Wetland/Riparian Areas
Many waterbodies within or with a nexus to St. Croix lands are considered high quality, both in
their biological and physical characteristics as well as their cultural importance. The protection
and restoration of wild rice as well as the maintenance of fisheries are essential foundations of
St. Croix Chippewa life. Degradation of lakeshore and stream habitat and excessive nutrient
and sediment loading to high quality and/or culturally important waterbodies are priority
concerns for the Tribe. Some waterbodies such as Gaslyn Lake, Gaslyn Creek, Loon Creek,
Sand Creek, and the St. Croix River are high quality and benefit from very low population and
high percentages of riparian cover in their HUC12s. These areas should be prioritized for
protection of existing riparian and wetland areas. Others like Big Sand Lake, Clam River, and
Yellow River are still high quality but have noted issues related to lakeshore erosion (Big Sand
Lake), loss of historical wild rice areas (Big Sand Lake), and monitored increases in nutrient
loading (Yellow River, Clam River). These areas should be examined for potential nutrient and
sediment reduction BMP implementation as their water quality may be degrading. Clam Lake
and Big Round Lake are both listed in nonattainment of their state water quality criteria due to
eutrophication (nutrient loading) and algal blooms. Implementation of lake management plans,
restoration of shoreline habitat, and protection of existing good habitat are recommended
activities under this NPS category. Coordination with nontribal landowners and associations on
management plans will be necessary for successful long-term implementation.
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The St. Croix’s long-term goal for the Wetland/Riparian Areas NPS category is to restore and
protect hydrologic and habitat conditions to reduce sediment and nutrient loading and
improve/maintain water quality, especially with regards to wild rice and fisheries.
Table 9: Near-term objectives and activities Wetland/Riparian Areas NPS category
Activity
Lead
Entities
Partners
Suggested
Location
Effectiveness
Measure
Funding
Objective 1: Assess, characterize, and rank wetland/riparian areas and key waterbodies.
Complete lakeshore &
streambank erosion
inventory for tribal
ENRD
surface waters within
HUC12 priority
watersheds
WTCAC,
USDA-NRCS,
WIDNR,
County LCDs
Completed field
inventory with
streambank erosion
HUC12 priority
sites mapped and
watersheds
incorporated into tribal
GIS with bank erosion
values
Complete inventory of
wild rice populations
Nontribal lake
associations,
WIDNR
Completed field
All tribal lands,
inventory with wild rice CWA Sec
initial focus on
populations mapped for 106, 319,
HUC12 priority
coverage and density WTCAC
watersheds
in tribal GIS
ENRD
CWA Sec
106, 319,
WTCAC
Objective 2: Protect existing high-quality water resources.
Identify existing buffers
or lack of buffers
ENRD
adjacent to HCN
streams and wetlands.
Completed GIS
All tribal lands,
USDA-NRCS,
assessment of stream
initial focus on
County LCDs.,
buffers on tribal lands
HUC12 priority
WTCAC
in HUC12 priority
watersheds
watersheds.
CWA Sec
106, 319
Objective 3: Restore degraded or degrading water resources.
Implement phosphorus
load reduction BMP
(BMP selection will be
ENRD
driven by selected
watershed for
implementation)
USDA-NRCS,
County LCDs.,
WTCAC,
HUC12 priority
NGOs,
watershed
USFWS,
ACOE
Successfully
implemented
phosphorus reduction
BMP
CWA Sec
319
Agriculture
Agricultural uses, including cultivated row crops and hay or pasture, make up approximately 4%
of the St. Croix lands. While it is a relatively small overall coverage of St. Croix land, agriculture
27 | P a g e
is a priority NPS focal area for tribal members due to the potential for nutrient and sediment
loading, including from nontribal sources.
NPS pollution sources in these watersheds include runoff from row crop agricultural fields and
barnyards, and overgrazing or poor grazing practices such as lack of exclusionary fencing on
stream corridors. These sources contribute to high levels of sedimentation, nutrient loading and
bacteria levels that are exacerbated by extreme runoff events and have the potential to
contribute pesticides including herbicides, insecticide and fungicides. These pollutants are
conveyed to surface waters through overland flow in these watersheds and are primarily from
upstream nontribal sources. As such, short-term activities will involve coordination with local
partner agencies on education and outreach to non-tribal landowners in priority watersheds as
resources allow. This activity is identified in the Education and Outreach activities in Table 10.
4.2 Schedule for BMP Implementation
The initial five years of the St. Croix NPS Management Program will focus on conducting
inventories and assessments, strengthening partnerships and collaboration between tribal
departments and non-tribal partners, and implementation of a demonstration phosphorus
reduction BMP. Inventories and assessments are expected to be implemented within the first 5
years for all NPS categories in order to determine direction for future work, education,
implementation of projects where and when funding permits and continuation of water
monitoring. The St. Croix and their local implementation partners will work with an adaptive
management approach in mind, sampling from the CWA Section 106 monitoring program will
serve as a basis for assessing improvements in water quality and will also serve as the basis for
the need for additional implementation activities in the future. During Year 5 of the NPS
Management Program, NPS Program staff will work with tribal and non-tribal partners to
conduct a comprehensive review of the overall program and will adjust where needed.
Table 10: Near-term BMP implementation schedule by NPS category
BMP/Activity
NPS Management Program
Year
Year Year Year Year Year
1
2
3
4
5
NPS Education and Outreach Activities
Develop and conduct tribal staff training on general NPS pollution
X
Collaboration with outside agencies on agriculture NPS and BMP
education training (cover crops, no-till, buffers, grassed waterways,
highly erodible land, nutrient mgmt)
Land Management NPS and BMP education training (forestry,
erosion BMPs, soil and erosion control, native plantings)
Wetland/Riparian NPS and BMP (wetland disturbance avoidance &
minimization, protecting buffers, restoration of degraded habitat)
X
X
X
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NPS Category Forestry
Objective 1: Identify and restore cleared areas.
X
Inventory and map cleared areas with erosion
X
Restore cleared areas to native forest
X
X
X
X
X
X
Objective 2: Develop forest management plan.
X
Develop forest management plan for St. Croix lands
X
NPS Category Wetland/Riparian Areas
Objective 1: Assess, characterize, and rank wetland/riparian areas and key waterbodies.
Complete lakeshore & streambank erosion inventory for tribal
surface waters within HUC12 priority watersheds
Complete inventory of wild rice populations
X
X
X
X
X
X
X
X
X
Objective 2: Protect existing high-quality water resources.
Identify existing buffers or lack of buffers adjacent to St. Croix
streams and wetlands.
Objective 3: Restore degraded or degrading water resources.
X
Implement phosphorus load reduction BMP
Long-term Implementation
The St. Croix have proposed additional NPS activities for Wetland/Riparian Areas that they wish
to pursue in the long-term. These and other long-term activities will be evaluated, updated if
needed, and integrated into the near-term schedule as other near-term activities are completed.
Table 11: Proposed long-term implementation activities
NPS Category Wetland/Riparian Areas
Activity
Lead
Entities Partners
Suggested
Location
Effectiveness
Measure
Funding
Objective 1: Assess, characterize, and rank wetland/riparian areas and key waterbodies.
Develop tribal
water quality
standards
ENRD
Perform
comprehensive
ENRD
bioassessment of
streams and lakes
WIDNR, Tribal
Council
All tribal lands,
initial focus on
HUC12 priority
watersheds
Adoption of tribal water
quality standards
WIDNR
All tribal lands,
initial focus on
HUC12 priority
watersheds
Regular programmatic
monitoring for
CWA Sec
macroinvertebrates, fish 106, 319,
species, and aquatic
USEPA
plants
CWA Sec
106, 319,
USEPA
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Perform
comprehensive
wetland
monitoring
ENRD
Develop lake
management
ENRD
plans for
nonattaining lakes
Baseline wetland quality
monitoring performed on
all delineated tribal
wetlands
CWA Sec
106, 319,
WTCAC,
USEPA
N/A
Delineated
tribal wetlands
Nontribal lake
associations,
Tribal Council,
WIDNR
WIDNR,
EPA, CWA
Approved 9 Key Element
Clam Lake, Big
Sec 319,
NPS lake management
Round Lake
USEPA,
plan for Clam Lake
WTCAC,
USDA-NRCS
Objective 2: Protect existing high-quality water resources.
Enact riparian and
wetland protection
ENRD
legislation on tribal
lands
Tribal Council
All tribal lands,
initial focus on
HUC12 priority
watersheds
Passed legislation
CWA Sec
protecting riparian areas
106, 319,
and wetlands on tribal
WTCAC
lands
5 Public Notice & Comment
The St. Croix will be conducting public notice concurrently with the USEPA Regional review of
the NPS Management Plan. The draft Management Plan and the Tribe’s Attorney Certification
for CWA Section 319 Eligibility (Appendix A) will be posted on the St. Croix website for at least
30 days for members to review and provide comments. Comments received will be incorporated
into a response document and provided to USEPA.
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6 References
Bloomquist, Jeremy, 2021. St. Croix Chippewa Indians of Wisconsin Tribal Water Quality Monitoring Strategy 20212026.
Saad, D.A., and Robertson, D.M., 2000. Water-resources-related information for the St. Croix Reservation and
vicinity, Wisconsin: U.S. Geological Survey Water-Resources Investigations Report 2000-4133, v, 65 p.,
https://doi.org/10.3133/wri004133.
St. Croix Chippewa Indians of Wisconsin, 2024. St. Croix Chippewa Indians of Wisconsin CPRG Priority Climate
Action Plan (PCAP). Prepared under the U.S. EPA Climate Pollution Reduction Grant Program.
St. Croix Chippewa Indians of Wisconsin, 2026. Nonpoint Source Assessment Report.
St. Croix Chippewa Indians of Wisconsin, 2023. Revised Constitution and By-Laws of the St. Croix Chippewa Indians
of Wisconsin. Available online at https://stcroixojibwe-nsn.gov/government/constitution/.
St. Croix Chippewa Indians of Wisconsin, 2026. Various codes and ordinances. Accessed online at
https://stcroixojibwe-nsn.gov/government/judiciary/codes/.
St. Croix Environmental and Natural Resources Department, 2023. Quality Assurance Project Plan (QAPP) for
Surface Water Quality Assessment, 2023-2028.
St. Croix Tribal Council – St. Croix Chippewa Indians of Wisconsin, 2003-2005. Feasibility Study for Biomass
Electrical Generation on Tribal Lands. DOE Award DE-FG36-02GO1321, A000.
USDA (U.S. Department of Agriculture) Natural Resources Conservation Service. 2002. Wisconsin Field Office
Technical Guide. Available online at https://www.nrcs.usda.gov/resources/guides-and-instructions/wisconsinengineering-resources.
USEPA (U.S. Environmental Protection Agency). 2010. Handbook for Developing and Managing Tribal Nonpoint
Source Pollution Programs Under Section 319 of the Clean Water Act. (EPA 841-B-10-001).
USEPA (U.S. Environmental Protection Agency). 2022a. Types of Nonpoint Source Pollution. Available online at
https://www.epa.gov/nps/types-nonpoint-source-pollution.
USEPA (U.S. Environmental Protection Agency) Office of Water. Office of Wastewater Management. 2006. Final
Guidance on Awards of Grants to Indian Tribes under Section 106 of the Clean Water Act for Fiscal Years
2007 and Beyond. EPA 832-R-06-003.
USEPA (U.S. Environmental Protection Agency). 2024. Tribal Water and Natural Resources Conservation Guide.
Available online at https://www.epa.gov/nps/tribal-water-and-natural-resources-conservation-guide.
WDNR (Wisconsin Department of Natural Resources). Wisconsin’s Nutrient Loss Reduction Strategy. Available
online at https://dnr.wisconsin.gov/topic/SurfaceWater/NutrientStrategy.html.
WDNR (Wisconsin Department of Natural Resources) Division of Forestry. 2009. Wisconsin’s Forestry Best
Management Practices for Invasive Species. PUB FR-444-2009. Available online at
https://councilonforestry.wi.gov/Pages/InvasiveSpecies/Forestry.aspx.
WDNR (Wisconsin Department of Natural Resources) Division of Forestry. 2010. Wisconsin’s Forestry Best
Management Practices for Water Quality Field Manual. PUB FR-093 2010. Available online at
https://dnr.wisconsin.gov/topic/forestmanagement/bmp
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Appendix A: Attorney Certification for CWA Section
319 Eligibility
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St. Croix Chippewa Indians of Wisconsin
4264 Admin Road • Webster, WI 54893 • (715) 349-2195 •Fax (715) 349-5768
June 23, 2026
Anne Vogel, Regional Administrator
U. S. Environmental Protection Agency, Region 5
77 West Jackson Boulevard
Chicago, IL 60604
RE:
St. Croix Chippewa Indians of Wisconsin Attorney Certification for Section
319(b)(2)(D) of the Clean Water Act
Dear Administrator Vogel:
Please accept this letter as the attorney certification required by the Clean Water Act
(“CWA”) Section 319(b)(2)(D) in connection with the St. Croix Chippewa Indians of
Wisconsin (the “Tribe”) for determination of eligibility to participate in programs under
CWA Section 319. I am the Assistant General Counsel for the Tribe and have worked with
the Tribe since May 2018. The Tribal Council is the duly elected governing body in
accordance with Article IV of the Tribe’s Revised Constitution and By-Laws. These
authorities are adequate to implement such management programs as provided in CWA
section 319 and implementing regulations.
Please do not hesitate to contact me at my contact information below if you require any
additional information.
Sincerely,
Ashley Duffy
Assistant General Counsel
WI #1101496
MN# 0506335
St. Croix Chippewa Indians of Wisconsin
4264 Admin Road
Webster, 54893
715-349-2195
aduffy@stcroixojibwe-nsn.gov
Conrad St. John
Chairman
Big Sand Lake
Richard Benjamin
Vice-Chairman
Danbury
Leslie Billy
Secretary/Treasurer
Big Sand Lake
Thomas Fowler
Representative
Maple Plain
Lester Merrill
Representative
Round Lake
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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.