1999-05-21 WSWCD Wetland Fill Permit
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WRIGHT SOIL AND WATER CONSERVATION DISTRICT
306e Brighton Avenue
Buffalo, Minnesota 55313
Telephone (612)682-1933
682-1970
Fax (612)682-0262
May 21, 1999
Linda Goeb
City Administrator
Albertville City Hall
5975 Main Ave NE
PO Box 9
Albertville MN 55301
RE: ALBERTVILLE-CROSSING CASCADE n WETLAND FILL PERMIT APPLICATION,
LOCATED WITHIN THE CITY OF ALBERTVILLE WRIGHT COUNTY MINNESOTA.
I>ear Ms. Ooeb:
Thank you for submitting the replacement plan application for the above mentioned project.
I have reviewed the information submitted and have the following comments and concerns which I feel
are important and need to be addressed.
. Wetland impact (Wetland SA) proposed for Block 6 Lot 2 shows a building be constructed in a
wetland, we recommend this impact be avoided.
. Plan indicates proposes stormwater ponding credits. However at least one stormwater pond is located
in wetland SA and will impact it with a berm. First NPDES permitting will not allow stormwater
ponds in a wetland. Second both the Wright SWCD and Board of Soil and Water Resources would
not allow PVC for this pond. Also it appears all ofwetland A is to be used as a storm",ater pond.
NPDES permitting requlres pretreatment of stormwater runoffbefore it gets into the wetland. If PVC
is not allowed for the stormwater ponds the proposed wetland creation and banking is not enough to
satisfy the 2: I replacement requiroments. "
. PVC credits cannot be allowed for "restoring" wetland A because Mr. Marx chose to drain this area
under an exemption, therefore it ca11not be used as replacement fur at kast ten years.
. I also have questions about allowable de minimus. Mr. Marx chose to drain wetland A under au.
exemption therefore he may have used up the exemption allotment and no de minimus exemption will
be allowed.
. If Phase 2 is entirely owned by a different developer then tbis would not be considered as one project.
However, if the goal is to phase and request additional exemptions this would not be allowed.
. Proposal indicates one to one replace~nt via wetland creation with other replacement coming from
banking a1Ui PVC credits, the Wright SWCD and BWSR would like to see more of the replacement.
conducted on-site to reduce the risk of flooding to downstream landowners. .
. Proposal is requesting sequencing flexibility. The Wetland COl1$Crvation Act requires a function and
value assessment reviewed and approved, by the TEP for both the impacted andrep1acement wetland.
I
On page 5 of the replacement plan application the applicant indicatestbat even if the wetlands fills
were avoided the activities conductt(Hn the upland WQuld inadvertently reduce tbe watersbed to d1~
wetlands by 80% therefore eliminating these wetlands. The Wetland Conservation Act states,
diverting the watershed from a wetl~d is the same as draining the wetland. therefore, it would be
considered an impact. Grading should be done in manner so water is not diverted frOnt these
wetlands, thus maintaining there bydrology.
. . Proposal indicates phase two will result in wetland impacts, however, it does not provide any
replacement for these "inevitable" impacts.
. Finally One suggestion, you may want to consider is to utilize upland buffers for Public Value
Credits.
These are the numer~ questions which the Wright SWCD and BWSR have. These must be addressed
before the replacement Pian application is approved.
Please feel free to contact this office if you have any questions and concerns regarding this matter.
Sincerely,
#a-(' ,P(<t~
Mark McNamara
Resource Conservationist
Wri,ght SWCD
cc: Pete Carlson, City Engineer Albertville
Keitb Grow, Board of Soil and Water Resources
Keith Cberryhomes, Minnesota Pollution Control Agency