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�DEPARTMENT OF <br />NATURAL RESOURCES <br />Division of Ecological and Water Resources <br />Region 3 Headquarters <br />1200 Warner Road <br />Saint Paul, MN 55106 <br />January 12, 2023 <br />Zachary Carlton, Planning Director <br />City of Elk River <br />13065 Orono Parkway <br />Elk River, MN 55330 <br />Dear Zachary Carlton, <br />Transmitted by Email <br />Thank you for the opportunity to review The Foster Property Development Environmental Assessment <br />Worksheet (EAW) in Sherburne County. The DNR respectfully submits the following comments for your <br />consideration: <br />1. Page 5, Zoning. It is not clear from the EAW if the subdivision does comply with R1D zoning. <br />This section says the site is, "zoned as R1D Single Family Residential. The Plan defines the <br />purpose of R1D districts as follows: 'This district is intended to accommodate single-family <br />residential dwellings with large lots and higher quality housing within the municipal sewer and <br />water access area. This district is explicitly for areas that possess significant natural features and <br />is intended to encourage the design of subdivisions that protect these natural features."' <br />Based on this zoning description and intent to protect natural features, the destruction of <br />nearly 148 acres of forest, along with nearly four acres of wetland impacts does not seem <br />consistent with this intent. It is unclear if the site will be mass graded in such a way that <br />removes nearly all existing natural features from individual lots. It is also unclear what attempts <br />at tree preservation will be made, such as conducting a tree inventory and identifying high <br />quality resources to preserve during the development process, and/or offsetting tree <br />destruction through compensatory tree planting/restoration efforts. <br />2. Page 5, Zoning. It appears that portions of the proposed development will be located within <br />300 feet of Trott Brook, a public water. It is unclear how the project will comply with local <br />shoreland ordinances regarding setbacks, impervious surfaces, and vegetation removal. <br />3. Page 10, Stormwater. Blanding's turtles, a protected state-listed threatened species, have been <br />documented within the vicinity of the project. Stormwater features may be colonized by <br />Blanding's turtles in the area, therefore we recommend incorporating measures to avoid <br />impacting this species into stormwater management. In years when the stormwater features <br />will be dredged to remove excess sediment, please draw down water levels by September 15th <br />in order to allow turtles to find overwintering habitat elsewhere. <br />