The Friends of Twin Lakes is an unincorporated nonprofit association comprised of Town of Warren residents who are working together to raise awareness and advocate for solutions to the imminent threat posed by the expanding waters of the Twin Lakes.

Friends founding member John Kraft has lived in the Town of Warren since 2015. He has been employing his expertise in data analytics to take a comprehensive look the rising lake levels in East and West Twin Lakes in the Town of Warren. The Twin Lakes have been the designated discharge basin for the Village of Roberts Wastewater Treatment Plant (WWTP) since its construction in 1962. Twin Lakes are a pair of shallow, seepage water lakes about 200 acres in size located a mile southwest of Roberts.

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Using information from a detailed study of Twin Lakes hydrology published in the 2009 USGS detailed groundwater study of Polk, St. Croix and Pierce counties, combined with historical rainfall, evaporation, and WWTP discharge data, Kraft has been able to construct a data model which predicts lake elevations which precisely match observed lake elevations over a 42-year period. His calculated rising water trend also matches findings published by the Department of Natural Resources in 1995.

"I was astounded how tightly this USGS simulation data matched our observations over that span of time. That's pretty clear cut to me that the treatment plant has a pretty significant attributable impact on lakes levels over this period of time," said Kraft.

The crux of the issue as Kraft sees it, is that rising lakes levels, particularly in the last three years, have begun to damage roads and lake properties, some severely. His calculations predict that that trend will continue unless something is done to regulate or discontinue the WWTP discharge into the lakes, the most controllable element in the equation.

In a paper published in January 2018, Kraft frames the Friends' concerns this way.

"A larger issue, which affects the Town of Warren, in which Twin Lakes is located, is the continued rising lake levels, which can be attributed to the wastewater effluent from the Village. Twin Lakes has been on a slow rising trend for more than 40 years as a result of the cumulative effects of the Roberts WWTP wastewater discharge. The lakes do have wide natural level variations that follow annual precipitation. These natural swings have largely masked the slow, average of 4.8-inch per year level increase from the wastewater augmentation documented by the DNR as early as 1995. With the above average rainfall the area has experienced over the last three years, the lakes finally hit a damaging flood stage that has submerged roads, destroyed one lake home entirely, severely damaged others, and has adversely affected many others as the lakes have experienced unprecedented expansion into the valley north of the West Twin."

What adds to Kraft's and the Friends' frustration is the pending contract between the Village of Roberts and CLEARAS Water Recovery to employ new technology at the WWTP that uses algae and photosynthesis to remove phosphorus and other nutrients, solids and heavy metals from the municipal wastewater to a level that exceeds the stringent levels imposed by the DNR in their Wisconsin Pollutant Discharge Elimination System (WPDES) permit set to be enforced starting in 2019. And here it is not the technology that the Friends oppose so much as the cost, some $2 million which Kraft argues could be better used in a solution that solves the lake residents' flooding issue.

Here are some of the sticking points on both sides of the issues.

The Village of Roberts is one of the first municipalities to have to conform to the new stringent phosphorus standard. The Village has considered a number of different solutions to meet the new standard (See the News, Dec. 17, 2015, Roberts Board to submit phosphorus compliance alternatives plan)

The CLEARAS solution not only exceeds the phosphorus standard, it addresses other nutrient, solids and heavy metal contaminants sure to be regulated more stringently by the DNR in the not too distant future. The CLEARAS solution also provides a revenue stream from the sale of the highly desirable medical grade plastic produced as a by-product of the algae process. The high quality of the water product, relative ease with which the system can be added onto the existing plant and the benefit of a practically guaranteed revenue stream helping to pay for the system, made CLEARAS a relatively straight forward choice for the Village (See the News, Oct. 28, 2016, Roberts: Clean water technology could have global impact, Oct. 16, 2016, Village of Roberts pilot treatment plant exceeds expectations)

To have the CLEARAS solution in place in time to meet the 2019 compliance deadline the village will be required to make a choice very soon. That means $2 million the Friends will no longer have access to.

Kraft does offer an alternate solution, though not well delineated, involving the creation of a larger regional municipal waste treatment system potentially expanding along the I-94 corridor to accommodate the wastewater from the Roberts WWTP.

"I am convinced that this is a much larger issue than any one municipality," said Kraft.

The Friends attempt to make the political case that the DNR is railroading the Village of Roberts into a contract with CLEARAS by enforcing the pending compliance deadline in 2019. Again from Kraft's 2018 publication:

"The treatment plant's 5-year DNR WPDES (Wisconsin Pollution Discharge Elimination System) permit expired at the end of 2016. During the renewal process, Town of Warren residents petitioned the DNR for a public hearing, which delayed the permit process until mid November 2017. The DNR dismissed the water level complaints, citing that it does not have the authority to regulate water quantity, only quality. Residents responded by petitioning the DNR for an adjudication hearing before a judge, which was promptly denied by the DNR because the 308-page document was delivered to Madison by FedEx rather than Certified Mail. The Village's WPDES Permit was subsequently reissued, and included new requirements for monitoring water volumes discharged into the lakes. The Village of Roberts is contesting the new requirements on the grounds that they are not necessary, and the DNR has suspended them pending a Contested Case Hearing petitioned by the Village. Despite the significant timeline setbacks, the DNR is insisting on the same aggressive compliance schedule for the Village to meet its tightened requirements. This is a strong indicator that the DNR wants the Village to move ahead with CLEARAS at all costs, before the intensifying lake level issues become significant legal problems for the Village, which appears to be inevitable."

Roberts Public Works Director John Bond has been dealing with the discharge and corresponding rising lake levels almost since the opening of the plant in 1962. He remembers an exhaustive search conducted at the time of the implementation of the new plant in 1962 and the Twin Lakes basin was the most reasonable, affordable solution. That research included study of the idea of building and tying into a larger regional system. Bond recalled at the time, the cost and political coordination of such a system were prohibitive. Today those numbers promise to be considerably higher and in the time it could take to design, approve, fund and construct such a system, the properties on the lakes could be gone. Bond appreciates the predicament of the lake property owners but also has a responsibility to the residents of the village. Bond recalled a sizeable grant being available to study the issue and look for alternative ideas a number of years ago, but it required both the Village of Roberts and Town of Warren to apply together and the town was unwilling to apply. He recalls it as an opportunity missed.

"I have nothing but respect for John Bond," said Kraft. "He has been heavily involved in all of our conversations. Admittedly a lot of this, it comes up a foot, goes back down, comes back higher, has to do with the fact we've had a major, an above average rainfall over the last three years. So what we have been fighting is, 'Well, it's all the rain,' but it's not. It's all the rain on top of a long-term trend," said Kraft.

To be clear, none of the solutions that the Village of Roberts has explored to resolve the current phosphorus regulations or previous DNR regulations including dredging, micro filtration and trading, would have solved the water levels issue for residents of the Twin Lakes. CLEARAS has drawn the attention of the Friends mostly because of the imminent expenditure of $2 million.

Here are the latest developments according to Kraft.

As of late February, the DNR has not yet granted Robert's petition for a Contested Case Hearing, which would potentially allow them to eliminate the requirement for the village to supply progress reports on managing the Lakes. The DNR has also assigned Water Resource Management Specialist Alex Smith to get involved with Twin Lakes issues after the Friends successfully reached out to DNR Secretary Dan Meyer.

Including the on-again, off-agai, issue of monitoring the affluent flow and impact on the lakes, there is a good amount of additional supporting information pertaining to this story, more than can be shared here, available at the following websites for readers interested in exploring the issues further.

Friends of Twin Lakes -

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Water Recovery - " target="_blank">