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F <br /> � J <br /> ; � ' <br /> Ms. Barbara Walther <br /> Mr. James Wisker <br /> Mr. John Smyth <br /> December 17, 2008 <br /> Page 5 <br /> result of site grading for the proposed stormwater pond. The applicant has made an effort to <br /> minunize wetland impacts by shortening the pond length, � <br /> Impact Rectification <br /> The wetland impacts for the proposed development are not temporary and therefore cannot <br /> be rectified at the completion of the project. <br /> Impact Reduction and Elimination Over Time � <br /> Best Management Practices (BMP),which conform to City�County/State erosion and <br /> sediment control specifications,will be employed during construction activities. Silt fencing <br /> will be placed along the upland side of all wetland boundaries as a measure to eliminate the <br /> potential of sediment enteri.ng the wetlands. Disturbed areas will be revegeta.ted within 14 <br /> days of fmal grading. <br /> MNRAM Assessment � • � <br /> MFRA completed a MNR.AM assessment of the proposed impact area and the wetland <br /> mitigation basins. Based on the results of the assessment,which are attached to this report, <br /> the proposed mitigation basins will exhibit greater wetland functions and values than that of <br /> the proposed impact area. <br /> Sequencin�Flexibilitv <br /> Based on the I���R.AM assessment of the proposed impact areas and mitigation basins, <br /> sequencing flexibility is applicable to the proposed project.According to Chapter 8420.0520, <br /> Subpart 7a of the WCA, sequencing flexibility can be implemented if alternatives have been <br /> considered and the proposed replacement wetland is certain to provide equal or greater <br /> functions and public values. With the provided alternatives and the l��INRAM assessment, <br /> which demonstrates that the replacement wetlands will indeed exhibit greater wetland <br /> functions and values,the applicant would like to apply sequencing flexibility toward the <br /> proposed project. <br /> WETLAND MITIGATION PLAN <br /> The applicant is proposing to provide in-kind and in-place wetland credits,but not in-advance. <br /> Therefore the applicant will be required to provide wetland credits at a 2.25:1 replacement ratio in <br /> order to satisfy the WCA mitigation requirements. In addition,the applicant inadvertently impacted <br /> 1,663 SF of Wetland 1 during the 2008 growing season. Because this impact occurred without a <br /> permit,the MCWD is requiring that mitigation be provided at a 4:1 replacement ra�io for the non- <br /> permitted impact area. The proposed impact to Wetland 1 equals 24,041 SF,which will be replaced <br />