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1996-09-25 MN DNR EAWr ~. Minnesota Department of Natural 1Zesources 500 Lafayette Road St. Paul, Minnesota 55155-40_ 10 September 25, 1996 Garrison Hale, City Administrator City of Albertville P.O. Box 9 5975 Main Avenue, NE Albertville, MN 55301 RE: Minneapolis Factory Shoppes Environmental Assessment Worksheet (EAW) Dear Mr. Hale: The Department of Natural Resources (DNR) has reviewed the EAW for the above-mentioned project. We offer the following comments for your consideration. The EAW correctly indicates that wetlands are present onsite, however the EAW understates the associated habitat value of these wetlands for wildlife. The wetland quality as habitat can be rated as locally good to high, which results from their relative isolation from direct human disturbance(being adjacent to I-94). These wetlands provide a desirable mosaic of semi-open water, dense wetland vegetation, and upland nesting cover. This complex likely supports a wide array of wildlife species, and is particularly good for waterfowl, herons, and egrets. Great egrets, Ring-billed gulls, and a Great Blue heron were observed during a brief site visit made recently. Upon review of the site plan provided in the EAW, we agree that the project demonstrates avoidance of wetland impacts. However, we believe it is possible to further limit wetland impacts by locating stormwater ponds to upland areas. If these ponds were located in upland areas, the loss of type 3/4 wetlands and non-reed canary grass type 2 wetland would not occur and impacts to local wildlife populations would be reduced. We also note that Lot 1, as shown in Exhibit 3, is future development and will require approximately one-half acre of wetland fill. Wetland filling should not occur until a specific development proposal exists; filling for speculative development does not meet the sequencing requirements of the Wetlands Conservation Act (WCA) in our opinion. In the wetlands discussion, it is unclear whether the project proposer expects to get wetland mitigation credit from development of the stormwater ponds. We recommend against the granting of credit in this instance because the ponds are to be surrounded on three (3) sides by impervious surface; lost wildlife values will not be replaced. We look forward to reviewing the Wetland Replacement Plan and the proposal for compensating for lost wildlife values. Thank you for the opportunity to review this project. The project does not require preparation of an environmental impact statement (EIS) in our opinion. We look forward to receiving your record of decision and responses to comments. Minnesota Rules part 4410.1700, subparts 4 & 5, require you to send us your Record of Decision within five days of deciding this action. ~~.i~ ?n;t>rm,ation: 512-Z96 6t~7., i-r()i)-7hh b0)t~ a ~`€Y: 6]?-29Ei ~?84, 1-80i`r-55?-392.4 A r~ i d unuy Employer ~ Pr ntcd nn R;. y~ I ~~ Pap i Con~am ug tiro 4u.~Ies i rvt s ty ~~ Vh unum of t~) ~ Post-~onsrr-~~;r~l~'astc 'Garrison Hale, City Administrator September 25, 1996 Page 2 Please contact Bill Johnson of my staff at (612) 296-9229 if you have questions regarding this letter. Sincerely, ~_ c~ ~~~ Thomas W. Balcom, Supervisor Natural Resources Environmental Review Section Office of Planning c: Bob Hance Con Christianson Pete Otterson Ellen Heneghan Lynn M. Lewis, USFWS Gregg Downing, EQB #970045-01 /ER21. SHOPPES.DOC