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• Section 4 (a) is problematic. Is this to suggest any land requiring any of the listed <br /> pernuts is subject to wetland buffer requirements on all down gradient wetlands <br /> on the properiy?To require all wetlands on a praperty to be buffered according to <br /> the proposed rules for any stormwater management or waterbody crossing permit <br /> seems aver(y restricrive.A remedy would be to mare narrowly define which <br /> wetlands would be subject to buffering(for example,those for which the permit is <br /> being requested). <br /> • Secrion 7 (h) requires a five year rnonitoring and maintenance plan for every <br /> wetland required to be buffered(which according to Section 4(a) is alt <br /> downgradient wetlands on a subject property).This will require significant <br /> appiicant investment and staff follow up. Section 7 (h) 2 requires the applicant to <br /> inspect, identify,monitor, and eradicate invasive species germination and <br /> establishment,which is a difficult measure that has not been achieved even <br /> though the significant research effort put forth by the University of Minnesota. <br /> Furthermore, Section 8 {b) a requires significant expertise to conduct and will <br /> inevitably create a hardship for the applicants trying to meet the rule. Section 7 <br /> (g) and(h} and Section 8 regarding buffer monitori.ng and maintenance should be <br /> reserved for only the most pristine wetlands in the most important circumstances. <br />