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il'i <br />^ L; <br />' ,ili ib <br />- L-J li <br />cr? <br />I <br />ljCeil Strauss <br />March 22, 1994 <br />Page 2 <br />Proposed Redefinition of "Too 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 blufr 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 />blufr determination, and yields a quantifiable facsimile of the "cormnon sense" definition. <br />We would appreciate if you could give this definition your consideration, and advise us if you <br />find it acceptable so that we can add this to our list of Shorelaiid Ordinance revisions which I <br />anticipate will be acted on sometime this year. <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