02-09-2010 Council Work Session Packet

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t � James Wisker Planner/Program Coordinator Minnehaha Creek Watershed District 18202 Minnetonka Boulevard Deephaven, MN 55391 M r. W isker, Thank you for the opportunity to review the MCWO Rule D draft. We offer the following comments for your consideratfon: Section 3. (a) (2), Mitigatfon -The definition of"subwatershed"in the rules needs to be better defined. The rules are not clear as to the subwatershed levei where mftigation needs to occur, In any event, Three Rivers Park Distrlct believes that the rules need to have some flexibility to allow appilcants to locate mitigation sites where the opportunity to create sustainable and functional wetlands is optimized. Forcing mitigatlan onto margfnal locations in the impacted subwatershed may limit the ability of the replacement wetlands to function as an integrated cornponent of the larger hydrologic system. Section 3. (b) (2) Mitigation - Three Rivers Park �istrict supports the cancept of requiring mitfgation in the area where Impact occurs. Nevertheless, there may be instances where the overal) hydralogic system could be improved more by constructing a high quality wetland outside of the MCWD boundaries, than by forcing mitigation onto a poor site wlthin the watershed. The rules should allow the opportunity to pursue such an optfon without the penalty of signlficantly increasing the size, and therefore the cost, of the mitigation. Including a variance or waiver procedure in the rules may provlde this flexlbl l ity. Section 3. {c) Mltigation - Three Rivers Park District recommends that this section speciflcally include a statement that excavation performed by a public entity for the purpose of controlling invasive species (such as reed canary grass, hybrid cattails, or phragmites) in wetlands be deemed self-replacing, It is difficult ta determine if replacernent of these species with a nat'rve species mix wil� change the MNRAM score enough to comply wfth the rule as currently drafted. The Park Distrlct Is considering wetland excavation as an option to attempt wetland restoratlon in Carver Park Reserve. Section b. (a) Wetland Buffer Vegetation - Three Rivers Park District supports the concept of establishing native vegetatlon in buffer areas. The Park District landscape policy requires forest, wetland and grassland planting to utilize native species. When buffers are established over disturbed area, and new vegetation must be planted, we agree that native species should be used. However, when existing, undisturbed natural areas are subsequently designated and recorded as buffers, Three Rivers Park Distrlct believes that the existing vegetation should be allowed to remafn even if It consist of predominantfy non-native species. Many areas around existing wetlands in Carver Park Reserve, Lake Minnetanka Regional Park, and Baker Park Reserve have invasive species