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Spring Hill Golf Club Wetland Replacement Plan Application Revised December 5, 2012 Page 5 of 8 ' be inconsistent in terms of its difficulty as compared to the remainder of the golf course. ' Over the past fourteen years of operation, as the club's members get older, staff consistently hears the complaint that the course is becoming too difficult to play. This comment is tied directly to the 13th hole as it is ' the toughest for the average golfer to play. Over the last ten years, minor changes have been made to make the course easier to play, yet keeping it a challenge for the better players. The height of the rough grass has been ' lowered to reduce the penalty for missing the fairway. Tee locations have been moved to aid the higher handicap golfers in clearing hazards with their tee shots. Sand hazards in direct line of play have been removed to ' avoid an additional penalty a golfer would incur with a bad tee shot. Consistently, the golfers comment negatively regarding the difficulty in playing the 13th hole. 1 Sequencing Flexibility ' The TEP has reviewed and approved sequencing flexibility for this project (Notice of Decision attached with permit application forms). ' The value of the wetland proposed to be impacted must be taken into account when considering whether or not the proposed project is in the ' public interest. The existing hydrologic interaction of the wetland would not be disrupted at the northern fill since a pipe would be placed to accommodate normal exchange of water from the small portion of wetland ' on the east to the larger body of the wetland to the west. The northern fill area is primarily dominated by invasive cattail and reed canary grass. The southern fill area is dominated by reed canary grass and invasive cattail. For this project, the question of sequencing flexibility comes down to two basic questions: 1) Is the quality of the wetlands proposed for impact demonstrably degraded such that mitigation would result in a certain gain in wetland function and value and 2) Do the mitigation wetlands provide a certain gain in wetland function and value. We believe that the proposed wetland impact areas are obviously degraded based on their vegetative t composition and that the MnRAM analysis bears this out. We further believe that the mitigation wetlands provide clearly higher functions and values and therefore that flexibility in the sequencing steps is warranted in ' this case. Please see the "MnRAM Analyses" discussion that follows.