6.4. SR 05-20-2002 - Laserfiche WebLink

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habitat and could provide nesting areas for Blanding's turtles, and we believe this would provide for a better centrally-located park. We would not object to pile-supported foot bridges crossing the wetland from residential areas to access the park. In evaluating the three concepts outlined above, please consider several of the sequencing principals outlined in the Minnesota Wetland Conservation Act administrative manual, Minnesota Rules Chapter 8420, and the sequencing findings of fact checklist: 1. That the applicant is required to attempt to modify the size, scope, configuration, or density to minimize wetland impacts. One mechanism to accomplish this is to reduce the number of lots. If 93 lots are required for an economic return, one has to question whether this is then a suitable site for such a proposal. Other mechanisms are to redesign the layout of roads, or build in alternative areas. (See Minnesota Rules Chapter 8420.0520, Subpart 4(A)(7)(a)). 2. That the applicant is required to attempt to remove or accommodate site constraints including zoning, access, infrastructure, or natural features. (See Minnesota Rules Chapter 8420.0520, Subpart 4(A)(7)(b)). We believe this includes the option of requesting a variance for cul-de-sac length. The WCA administrative manual on page IV-5, section D.4, discusses the option of applying for a variance in order to avoid or minimize wetland impacts as an expectation of public transportation projects. 3. That the applicant is required to attempt to confine impacts to the fringe or periphery of the wetland. (See Minnesota Rules Chapter 8420.0520, Subpart 4(A)(7)(c)). Additionally, we recommend that the roads be built with no curbs or that curbs sloped be sloped at 3:1, rather than built with shear curbs. Blanding's turtles, especially hatchlings, cannot climb shear curbs and thus frequently get trapped on roads and killed by vehicles. At fill area A, oversized elliptical or box culverts should be installed to provide for turtle passage. A 50-foot wide natural buffer should be lei~ around the wetland to the maximum extent possible, especially in park areas and undeveloped areas. Attached is a copy o£our Blanding's turtle guidelines. We believe these should be incorporated into the project approval in order for the project to be compatible with Minnesota Rules Chapter 8420.0540 Subpart 9 (A) and (C). Thank you for the opportunity to review the wetland replacement plan. If you have any questions, please contact staff ecologist Michael North at 218-828-2433. Sincerely, / C.B. Bylander Regional Administrator CCi S. Colvin D. Norris P. Diedrich P. Perry K. Grow REAT