5.2. SR 05-16-1994 - Laserfiche WebLink

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e e e Stephen Rohlf April 4, 1994 Page 3 or to backfill pits? Dredged material from settling basins may be considered mine waste and could potentially have some application in reclamation as top dressing. Page 3-1, paragraph 6 This section should clarify the legal and endangerment status of elements identified through the County Biological Survey (CBS). Although natural communities other than Calcareous fens are not currently protected by law in Minnesota, the Natural Heritage Program has classified natural plant commumties and ranked them based upon their relative endangerment in the state. The special concern status of the Mixed Oak Woodland community refers to the status of this natural community type in the entire state, and as such, it is not a site specific status. CBS sites #227 and #239 consist of Dry Oak Forest communities. Section 3.1 and Figure 3.1-1 incorrectly state that these sites have no DNR status. The Dry Oak Forest community type found in CBS sites #227 and #239 has been designated as threatened in the state by the Natural Heritage Program. Both CBS sites #239 and #227 are found within the gravel mining district, and both should be mentioned in this section. Section 3.1.d (Mitigation), pages 3-6 and 3-7 Alternative B is presented as the most likely scenario to occur. There should be more discussion on ways to mitigate the concerns associated with Alternative B. For examtlle, although the natural heritage sites are mentioned in several locations with no diSCUSSIon on possible mitigation or alternatives to mining. The Natural Heritage Pro~amspecifically recommends avoidance of impacts if possible because it would be very difficult to effectively mitigate the impacts of a gravel operation to the natural communities rresent in the district. Of the two sites initially identified as being of concern by the Natura Heritage Program, (#194 and #240), it appears that CBS site #194 will be impacted by the proposed gravel operations. Impacts to this site should be considered in the larger planning context noted above. True protection of these resources requires that they be considered at the city, township, and county level simultaneously; we believe that the current situation provides an opportunity for local planning efforts to include the protection of CBS site #194 as parkland or open space. Similarly, the loss of 40 acres of agricultural land of "statewide SIgnificance" is mentioned as an outcome but there is no discussion on how that loss might be compensated. We recognize that perhaps there are not reasonable ways to mitigate or avoid these losses. Final reclamation to restore elements that were initially on the site may be the only way available to mitigate their loss. If that is the intention, the EIS should explicitly make this statement. In recognizing Elk River's growth potential'; the size of the mining district, the proposer's willingness, and the progressive attitude of the city, there is an unparalleled opportunity to create an exceptional final land use plan for the gravel minin~ district. Final end use, thou~, is not addressed in the DEIS other than to state that It will be compatible with existing city zoning ordinances, mainly residential. Creation of final landforms such as wetlands, open bodies of water, and upland contours are more cost-effective during active mining. WIth forethought, these final landforms can be more interesting than simply 4:1 slopes and square holes. The reclamation plan, for example, should examine the feasibility of establishing such amenities as public parks or green spaces, a golf course, a trail network, or playgrounds. These kinds of features are not only compatible with the proposed residential housing but would enhance the overall community value of the final development. Some type of public space within the 2,700-acre mining district would seem