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To the MCWD Board of Managers: <br /> Thank you for allowing me to comment on Rule D. <br /> I have the following two concerns relating to Section 2 and 3 of the Rule. <br /> Regarding Section 2, I am concerned that this change will eliminate the wildlife habitat <br /> exemption allowed under the Wetland Conservadon Act. <br /> From the Minnesota Interagency Wetlands Group{attachment provided): <br /> 'The purpose of the wildlife habitat exemption is to allow some wetland impact(filling for <br /> all weUand types and excavation for the permanent and semi-permanently flooded <br /> portions of Types 3,4,and 5 wetlands)to occur without replacement as long as the net <br /> effect of the project is to improve wildiffe habitat. if the intent of a project is something <br /> other tha�wildllfe habitat improvement,such as improved aesthetics,or to gain access <br /> through the wetland,then the project does not qual'rfy for the habitat exemption." <br /> In the Watershed District, many wetiands are degraded due to land use practices and invasive <br /> species. One such invasive species, reed canary grass, is creating large dead zones for wetland <br /> wildlife. Given that reality, I think it is important to have the wfldlife habitat exemption available as a <br /> tool for land owners to use to restore and improve habitat. The exemption is well written with <br /> detafled guidelines that spell out what is permissible and ailow the Watershed to prope�fy permit and <br /> regulate such projects. <br /> Although the Metro Area wili not attract large amounts of migrating wildlife on its wetlands, with <br /> wildlife habitat improvement there 1s opportunity for intreasing arnphibian life, improving local nesting <br /> duck success and attracting ather species that depend on the vitality of a wetland. Lastly a successful <br /> habitat improvement wfll be an amenity and an ongoing wildlife educatfonal study for the Watershed <br /> citizens. <br /> Regarding Sectfon 3 {c): E have a concern that only allowing excavation by public agencies to be self- <br /> replacing is an unfair applicatlon of control over prlvate property and an unfair advantage of <br /> government permission. This limits the abillty of the land owner to conduct posslble Improvements to <br /> one's land unless he Is willing to concede the work and possible ownership characteristics to a publlc <br /> agency. This also gives public agencies an adva�tage to conduct an activity on private land with an <br /> inherent advantage (no mitigation) that is unavailable to the land owner. <br /> As a past member of the Gitizens Advisory Committee of the MCWD, I am appreciative of the time <br /> spent in formulating these rule changes for the Watershed. These are complex fssues and I thank you <br /> for giving me the opportunity to weigh in on some of the changes. <br /> L(li McMfllan <br />