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2001-01-12 Permit Application Comments -..,..-... , ;<:: Ei; -/--;:'~I ~':.- - /../. 'Y3 U6-v .E:"t..C/.41 ~ r- / , /' - / Z -0/ (!? ". "fii~ /1.,;/ Pennit Applicatic'oA CUrlIrderlt5 ,,~. '" 0' . I Basin 3 is currently a w..:dand, which will be vartially excavated and self mitigating. > There is an expectation ht::r~ to get mitigation credit for conversion of one wetland type to another. Based on the plan and the wetland permit there is no '<new" wetland being created here only wetland type conversion. At a minimum, what they are attempting to do here needs further explanation. Basin 3 is a type 2/3 wetland that still maintains some native vegetation. By disturbing this wetland through filling and excavation it is very likely that the native vegetation will be removed or at least highly impacted. Basin 3 is the one wetland area of the project site that maintains a native vegetation population and this vegetation should continue to be maintained if not enhanced by no impacts. It is contradictory to say that the proposea project will increase public value of wetland areas by creating planted wetland areas while a wetland with some native vegetation is impacted. The natural Type 3 wetland with native vegetation should be protected and avoided. Basin 4 - It is unclear why this basin needs to be impacted (other then lot arrangement). If the same argument holds true that the hydrology will be affected for this basin, how could the mitigation area, being over twice the area of the existing basin have enough hydrology to support it (as stated on Page 5 of the application)? Basin 5 - this wetland is adjacent to a proposed park and could be incorporated into the parkland by rearranging the lots in the area. This would avoid wetland impacts and still provide some hydrology to the wetland. There is substantial open space (i.e. "green space") "in the development which is good to see. However, this is not addressing why impacts to the existing resources (wetlands) are occurring. To trade more open space (manicured parkland) for existing wetland resources doesn't meet the requirements of the regulations. There is no direct discussion on this issue. Why impacts to the existing resources cannot be avoided or minimized other then they were "avoided or minimized to the extent practicable" as stated on page 5. I would question this since there is so much open green space shown on the plans. It appears that the open space is preferred over trying to protect the existing resources from being impacted in order to create the preferred design. This is not sufficient and does not meet the avoidance/minimization criteria. This project does not meet the required avoidance or minimization to the maximum extent practicable as required under the LOP standard conditions section. The wetland areas could all be incorporated as open space by redesigning the project. Based on the proposed plan it does not appear that some of the lots meet the State of Minnesota setback requirements for lots in the Shoreland Protection Zone of 125 feet. In fact the developer has been granted a variance from the City of Albertville Shoreland Ordinance being contingent upon MNDNR approval which has not given their approval at this point. I ;'DO UOVICS S€H~c..