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1 � <br /> such as reed canary grass, as the primary plant cover type, As written, the <br /> rule would require the Park District to remove this estabiist�ed vegetation on <br /> 1lterally hundreds of acres of parkland when projects such as trall renovatfons <br /> occur. This would result in significant disturbance to the park natural <br /> environment and have very limited success. <br /> At the mornent, control of species Ilke reed canary grass, garlic mustard and <br /> buckthorn on a large scale Is an unrealistic objective. The recent trail <br /> renovation project in Carver Park Reserve resulted in the deslgnation of over <br /> 100-acres of the park as buffer areas. Controi of non-native species over this <br /> large of an area would be virtually impo5sible. Although the Park District is <br /> activefy investigating strategies to control these invasive species, and is <br /> encouraging efforts by the University af Minnesota, the MN DNR and others to <br /> develop controf practices, the Park Dlstrict rec�gnizes that the tools far <br /> control do nat currently exist. The Park Distrlct therefore recommends that <br /> the draft rule be revised to allow maintenance of un-mowed, establlshed <br /> vegetation on areas designated as buffers, even if the existing vegetation <br /> contalns more than 75% non-natfve species, <br /> Section 7, (b) (3) Required exhibits This proposed rule change appears to <br /> require Three Rivers Park District ta camplete wetland delineations on all <br /> wetlands in a park when a project is proposed. Large parks such as Baker <br /> and Carver, contain hundreds of wetlands, spread over thousands oF acres, <br /> and this requfrement would be a significant and unnecessary burden to the <br /> Park District. Three Rivers Rark District recommends revising the draft <br /> language to require delineation of affected wetlands only for proposed <br /> projects, rather than all wetlands on the property. <br /> Section 8, Wetland Buffer Monitoring - The Park Distrid believes that the <br /> draft rules need to be revised to lirnit buffer monitorfng to areas re-vegetated <br /> following disturbance during project constructian, As the attached map <br /> shows, the Park District provided over 100-acres of wetland buffer for the <br /> recently completed hike/bike trail project in Carver Park Reserve. All of these <br /> areas were covered wfth established un-mowed vegetatlon, that was not <br /> disturbed by the praject. Complyfng wfth the monito�ing provlsions over thls <br /> extensive area as required by the draft rules would constitute an onerous <br /> burden to the District. Simply providing photographs of representative buffer <br /> areas throughout the park reserve would take at least an entire day. <br /> Accurately samplfng the percent vegetative cover and dominant species could <br /> take many weeks. Llmiting the bufFer monitoring requirements to areas <br /> newly planted after projed completion would meet the MCWD objective of <br /> ensuring adequate buffer establishment without the excessive burden. Areas <br /> with existing natural vegetation should not need to be monitored as long as <br /> they rernain undisturbed. <br /> Thank you for your consideration of these comments, <br /> Sincerely, <br />