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As an alternative to the proposed buffer widths, I recommend that the base buffers be <br /> kept the same as proposed,with the exception af reducing the Preserve buffer width to 50 <br /> feet. Reductions in width should then be allowed in flatter buffers(less than 15 percent) <br /> and hydrologic soil groups of grades less than C. Such buffer widths will be adequate to <br /> protect water quaIity in all cases, assuming that buffer vegetation management is <br /> implemented consistent with proposed Section 6. Whiie the wider buffers currently <br /> proposed provide increased funcrions for such things as open space and wildlife,I believe <br /> it is beyond the authority of MCWD to require that upland is set aside for such purposes. <br /> The proposed rules also fail to address how buffers will be implemented on currently <br /> developed sites. Small renovations or additions to existing properties may trigger buffers <br /> due to excavation volume or erosion control requirements. Requiring a 20—75 foot <br /> buffer on a residential property that is adding a swimming pool, sport court,or a family <br /> room is a real issue that should be considered. Undoubtedly there are many other aspects <br /> of the rules that are problematic in already developed areas. The rules need to be flexible <br /> enough to allow for reasonable requirements in such areas. <br /> Another real and significant issue not addressed in the praposed rules is the interpretation <br /> and application of buffer requirements for wetland fringes of Lake Minnetonka and other <br /> lakes in the District. Except in cases of steeply sloped, eroded,or rip-rapped shoreline, <br /> nearly all shoreline will have some amount of wetland fringe or lacu.strine submergent or <br /> floating-leaf wetland. Is it the intention of the MCWD to require buffers adjacent to lake <br /> shore? If not,the District should consider some language to exempt such lalce fringe <br /> wetland azeas &om t�uf�'er requirements,possible by defaulting to shoreland zoning <br /> requirements within a specified distance from the OHWL of a lake. <br /> The District should also look into more effective ways to reduce the adverse effects of <br /> agricultural land use on water quality within MCWD. I am disappointed to see the <br /> MCWD rules specifically exempting agricuitiiral uses from their regulations,basically <br /> iguoring the tons af sediment,nutrients, and animal manure that run aff crapfields and <br /> pastures into the west end�f Lake Minnetonka. It is obvious why that portion of the lake <br /> consistently has the lowest water quality ratings of all bays, even worse than water <br /> quality in the lake near most developed areas. The District should aggressively evaluate <br /> its legai options to acquire regulatory authority over agricultural uses. Given that a <br /> majority of the District is already developed,that is not unreasonable to consider. If that <br /> is not possible, effective incentives should be developed to promote more <br /> environmentally-friendly farming practices such as organic, no-till,and reduced till <br /> cultivation;promorion of hay crops over row crops; fencing livestock out of wetlands and <br /> creeks; and establishment of buffers, even before development. There is no doubt that <br /> improvements in these areas would result in significant benefits to water quality in Lake <br /> Mumetonka and Minnehaha Creek. <br /> I am appreciative of the efforts that MCWD is making to protect water quality within its <br /> jurisdiction. As a resident of Shorewood,I regularly use area lakes for swimming, <br /> fishing, and boating and I have seen first hand the benefits of those efforts. That said, I <br /> believe that the proposed rules place an unfair burden on developers and small project <br />