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Ceil Strauss <br /> March 29, 1994 <br /> Page 2 <br /> Proposed Redefinition of "Top of Bluff" <br /> The following facts and premises seem critical to us in the discussion of bluffs: <br /> • "Steep slopes" are those exceeding 12%. <br /> • DNR has chosen 30% as the slope that defines a bluff. <br /> • DNR has chosen a 50' segment of slope less than 18% as not being part of a <br /> bluff, and has used slopes of 18% or more for 50' segments that define the lower <br /> and upper points of a bluff. <br /> • Clearly, DNR feels that 18% is a key slope percentage, above which we should <br /> be concerned about the impacts of very steep slopes, as opposed to those steep <br /> slopes of 12-18% which are of somewhat lesser concern. <br /> We propose to redefine the "top of bluff" as "that point on the cross-section of a bluff below <br /> which the slope becomes more than 18% and above which the average slope for a distance of <br /> 50' or more is 18% or less". This 18% "breakpoint" can be easily defined using standard 2' <br /> contour topographic maps which the City has readily available. Actual field topographic survey <br /> work by an applicant's licensed surveyor would also be accepted. <br /> The intent of having slope average 18% or less for distance of 50' is consistent with the <br /> exception for buildable area in a mid-bluff setting already in the DNR regulations. <br /> While the proposed definition may ultimately be found to have its flaws, we feel that it meets <br /> the DNR's intent for bluff protection, results in a more consistent and reproducible "top of <br /> bluff" determination, and yields a quantifiable facsimile of the "common sense" definition. <br /> We would appreciate if you could give this definition your consideration, and advise us if you <br /> find it acceptable. This revision is scheduled for a public hearing at the April 18 Planning <br /> Commission meeting. <br /> As always, please contact me at 473-7357 if you have questions. <br /> Sincerely, <br /> Michael P. Gaffron <br /> Assistant Planning & Zoning Administrator <br /> MPG/lsv <br /> cc: Jeanne A. Mabusth, Building & Zoning Administrator <br /> Ron Moorse, City Administrator <br />