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2000-09-05 EAW Balfany WRIGHT SOIL AND WATER CONSERVATION DISTRICT 306e Brighton Avenue Buffalo, Minnesota 55313 Telephone (612)682-1933 682-1970 Fax (612)682-0262 September 5, 2000 Linda Goeb City Administrator 5975 Main Ave. NE P.O. Box 9 Albertville, MN 55301-0009 / ~ . ~ RE: BALty RESIDENTIAL DEVELOPMENT EA W. Dear Ms. oeb: Thank. y u for the opportunity to review the above mentioned EA W. Upon review, I have several concerns. According to NPDES rules, outletting untreated storm water runoff directly into Basin 6 would be considered an impact and would then be subject to sequencing under the Wetland Conservatio t (WCA). Watershed acreage of all wetlands should be analyzed pre- and post- development. A significant reduction in a watershed will cause an indirect impact to the wetlands and may require mitigation. Specific plans should prove no wetland impacts will occur with the construction of the boat slips, docks, and storm sewer outfalls. Avoidance issues will be more closely scrutinized during the WCA process, especially regarding wetlands 3, 4, and 5. Excavating in Type III wetlands are subject to sequencing. Also, it appears that wetlands 4 and 5 are to be impacted merely for convenience or to attain additional lots. Without extensive knowledge of the site, I believe that wetlands 5 and 2 and possibly others could be easily restored with small earthen dams and/or tile breaks as an alternative. Another concern is that all proposed storm water treatment ponds will tap into the groundwater and thus provide a direct conduit for contamination. It should also be noted that the southernmost storm water treatment pond must be entirely separated to the to-year storm event prior to outletting into the proposed mitigation pond.