1999-03-08 MNDNR EAW Review
Minnesota Department of Natural Resources
500 Lafayette Road
51. Paul, Minnesota 55155-40JQ
March 8, 1999
Linda Goeb
City Administrator
P.O. Box 9
Albertville, MN 55301
RE: Albertville Crossing
Commercial/Retail Center, Multi-Family Townhomes and
Single Family Residential Lots
Environmental Assessment Worksheet (EA W)
City of Albertville, Wright County
Dear Ms. Goeb:
The Minnesota Department of Natural Resources (DNR) has reviewed the EA W for
Albertville Crossing consisting of a commercial/retail center, multi-family townhomes
and single family residential lots in Wright County. We offer the following comments
for your consideration.
General Comments
The project proposes a high density oftownhomes in a small area along the proposed
Lachman and Lambert avenues. The proposed density creates a large amount of
impervious surface, totally isolates the large wetland in Block 4 and will likely disturb or
eliminate wildlife species that periodically require access to uplands for completing part
of their annual or life cycle. Elimination of Lot 22 would preserve a large area of
wetland. Also a reconfiguration of Lot 1 in conjunction with moving townhomes 2-5 to
the west and slightly south (i.e. off the street front) would avoid impacts to the
northeasterly wetland and eliminate having to mitigate its loss. This is significant
because the Wetland Conservation Act (WCA) requires replacement of wetland functions
and values, not just replacement of lost acreage.
The EA W does not adequately quantify wetland impacts and impacts present are not
fully mitigated. We are concerned that WCA sequencing requirements have not been
met. Reconfiguring the proposed layout of the development and reducing density in
order to maintain a buffer strip around the wetland would greatly minimize the loss of
wetland functions and values. If revising the layout is not acceptable, then we
recommend that project approval be conditioned on 1) the applicant assessing wetland
functions and values to be lost, 2) the applicant mitigating lost functions and values
through the WCA review process, and 3) mitigation at greater than a 2:1 ratio to fully
replace lost functions and values. This should occur in conjunction with the WCA
Technical Evaluation Panel and Minnesota DNR's Regional Environmental Assessment
Ecologist (Michael R. North, 218-828-2433).
DNR Information: 651-296-6157 · 1-888-646-6367 · TTY: 651-296-5484 · 1-800-657-3929
An Equal Opportunity Employer
Who Values Diversity
.I'f,. Printed on Recycled Paper Containing a
.., Minimum of 10% Post-Gonsumer Waste
Albertville Crossing
March 8, 1999
Page 2
Section 10 - Cover Types
The before and after wetland cover type values are inconsistent with other EA W
information. The "after" total for wetlands reflects 2:1 mitigation for 3.4 acres of
impacts, but 2.8 acres of this mitigation are proposed to occur off-site (Section 12).
Therefore, the "after" total for the wetlands on-site would be 13.0 acres. From the
figures listed in Section 10 and 12, it is unclear if wetland mitigation will be off-site or
on-site. We recommend as much mitigation occur on-site as possible.
Section 11 a - Fish, Wildlife, and Ecologically Sensitive Resource
We disagree with the statement that since no lakes are on site, there will be no impacts to
fish. DNR Fisheries staff inspected the site and noted there is a small intermittent stream
with a narrow band of riparian reed canary grass. Values of intermittent streams to
fisheries potentially include: 1) being a source of invertebrates, detritus, and forage
fishes (e.g., fathead minnows, brook sticklebacks) that form the basis of the food chain
for larger game fish, and 2) spawning sites for northern pike. They can also be a conduit
for transporting pollution downstream to valuable aquatic habitats. Our Fisheries staff
recommend that Best Management Practices for runoff and erosion control be utilized
during construction, and that silt barriers and erosion control devices be maintained
throughout the construction phase of the project.
Section 12 - Physical impacts on Water Resources
DNR fisheries staff concurred that the proposal to treat stormwater on-site before it is
discharged to wetlands for polishing is desirable. We recommend that stormwater ponds
be irregularly shaped and designed to function in conjunction with the remaining wetland
areas.
Thank you for the opportunity to review this project. We look forward to receiving your
record of decision and response 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. Please contact Gail Fox of my staff at (651) 296-0731 if you have questions
regarding this letter.
Sincerely,
~--Z .~_<L-~ YC?~
Thomas W. Balcom, Supervisor
Environmental Review and Assistance Unit
Office of Management and Budget Services
c:
Bob Hance
Bret Anderson
Paul Diedrich
Jon Larsen, EQB
Mark McNamara, Wright County SWCD
Con Christianson
Mike North
Charles Kjos, USFWS
Marly Glines, Cascade II
990272-01
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