Laserfiche WebLink
5. Buf�'ers Section 4(a): Buffer requirements for wetlands downgradient of our <br /> projects that we are not disturbing is a big problem. Why is this in the new <br /> Rules? What happens when the wetland is not on our property? How far is <br /> "downgradient"? What happens when our stormwater is not even discharging to <br /> the wetland area and is piped in a different direction? The buffer requirements <br /> should only apply when the wetland is actually being excavated or filled in some <br /> manner. <br /> b: Buffers Section 4{b}: What does"A buffer on public land or right-of-way may be <br /> documented in a written agreement executed with the District in place of a <br /> recorded instrumenY'mean? Mn/DOT roadway tumbacks are only made ta other <br /> public entities such as cities and counties, so why is this agreement necessary <br /> when the plan set should suffice? <br /> "7. Section 4(c): Monuments/signing requirements are impractical for linear projects. <br /> Mn/DOT will nat be able to place buffer monuments at the edge of the wetlands <br /> . due to safety reasons. Ftush mounted monuments are not visible. In most <br /> instances,Mn/DOT praperty has access control and is fenced, so it is unclear why <br /> they would be needed on Mn/DOT facilities in the first place. Permits are also <br /> required for any excavation activities on Mn/DOT right-of-way. <br /> 8. Section 5- Buffer width requirements are impractical for linear projects, Due to <br /> limited right-of-way, in many instances,Mn/DOT will have a hard time meeting <br /> the buffer width requirements. Given the size of the buffer width requirements, <br /> this will impact being able to replace the wetland on-site. I have attached an <br /> email I sent to you on this subject back in September 2008, James,when <br /> Hennepin County and Mn/DOT met with you back in May 2009, we talked about <br /> the problematic nature of the buffers with you. {I have attached the notes form <br /> that meeting to this letter.) Flease add an exemption to the Rules for linear <br /> entities. <br /> 9. Section 6- Mn/DOT has spec�c maintenance requirements for our right-of-way <br /> in our IRVM(Integrated Roadside Vegetation Management)Plan that requires <br /> mowing for both safety and aesthetics. In many instances, due to limited right-of- <br /> way,this area will include the wetland buffers. <br /> 10. Section 7(a}—Required E�chibits: The timeframe for delineatians has aiways <br /> been April 15�'to October 15�',not May 1. <br /> 11. Section 7(h) and Section $Wetland Buffer Monitoring: The maintenance plan <br /> that Mn/DOT will use on its' right-of-way is the IRVM plan mentioned above in <br /> comment 9. This will need to suffce to meet the requirements of section 7(h)and <br /> section$. <br />