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January 15,2010 <br /> Mr. James Wisker <br /> MCWD <br /> 18202 Minnetonka Blvd. <br /> Deephaven,MN 55391 <br /> RE: Minnehaha Creek Watershed District Rule F and D Comments <br /> Dear James: <br /> Mn/DOT has the following comments on the draft Minnehaha Creek Watershed Distr�ct <br /> Rules F and D. Some of our same comments were also made in rega.rd to the Minnehalia <br /> Creek Watershed District draft Management Plan back in November 20, 2006;I have <br /> attached a copy of that transmittal for your reference. <br /> Rule D Wetland Protection: <br /> l. Please add to this Rule that Mn/DOT is the WCA LGU on land that it owns. <br /> 2. "Impact"is not defined. Do temporary impacts require full mirigation? <br /> 3. Mitigation(Rule 3 b 2)is problematic. The replacement ratios in the rule provide <br /> a disincentive to using BWSR's local road bank. Mn/DOT is not a part of the <br /> local road projects that would be able to.access the BWSR road bank without the <br /> penalties listed in the rule(ratios, location etc.} and it is not clear in the rule that <br /> this option is available. <br /> 4. Banking(Rule 3 b 4}is very problematic. Page 6 of the SONAR references use of <br /> BWSR bank. Mn/DOT transfers funds to BWSR to create wetlands and a bank of <br /> wetland credits from which Mn/DOT can draw for future Mn/DOT projects with <br /> wetland impacts has been established. This is separate from and different than the <br /> Local Government Roads Wetland Replacement Program(Mn/DOT is not a part <br /> of the Local Roads Frogram). It should be clarified that Mn/DOT needs to have <br /> the same privilege as athers. Mn/DOT has an existing agreement with$WSR and <br /> has paid BWSR far wetland replacement Mn/DOT should be able to continue to <br /> use the bank without the WD's increased ratios and penalties and this should be <br /> made clear in the Rule. <br />