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, �r,��,� _.a,� ,: <br /> � � � <br /> ��.x�� - ' ,�� .. ;� <br /> �,�' . , <br /> November 30,2009 <br /> Minnehaha Creek Watershed Disirict <br /> Dear Mr. Wisker and the MCWD Board of Managers; <br /> Thank you for the opporiunity to comment on the proposed changes to Rule D: Wetland <br /> Protection.We applaud the District's efforts to update the rule, and we believe a crirical <br /> companent of ensuring the effectiveness of the rule is to consider input from alI <br /> stakeholders including cities,developers,citizens,and other governmental agencies. <br /> Below.you will find bullet paints of staffcomments regarding the revisions. Please <br /> consider our comments when formulating your final revisions. <br /> • You do not define what you wiil be considering a wetland under your jurisdiction. <br /> Due to the proposal to include all wetlands,regazdless if they are subj ect to WCA <br /> rules, it is necessary to determine how you will be defining a wetland(ie. <br /> incidental or stormwater ponds, etc). <br /> • There should be an opportunity for applicants to do further study{beyond the <br /> original functional values assessment conducted by the watershed)to determine <br /> the relative value level of a wetland(Preserve,Manage,I,II,III). Over time, <br /> wetland characteristics may change, or the entire wetland may not have been field <br /> verified.Applicants should have the option of providing the district information to <br /> re-classify a wetland, if needed. <br /> • Section 3 (b} (1)requires a 2 to 1 replacement,but says"ratio of 2 acres <br /> replacement...for each acre of impacted..."Is the implication that at least one <br /> acre would need to be impacted before this would apply? If not, the language <br /> could be revised to indicate a replacement rati�of 2 to 1,regardless of the size, <br /> • Section 3 (b) (2) (c) will come into play in a significant way for road projects. <br /> Oftentimes, large road projects cannot fmd wedand replacement in tlie metro. A 4 <br /> to 1 replacement requirement will significantly add higher costs to already <br /> expensive road projects. <br /> • Section 3 (c) refers to"excavation performed by a public entity for public <br /> benefit..."The definition of public benefit needs to be specif cally defined, Also <br /> in the same secrion"degraded wetland"should be defined as well. <br />