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If Banking is used, the replacement ratio would be 2:1 if credits are purchased within the Bank Service Area, BUT the first half must come from the Seven County Metro area AND within the 50-80% wetland area, which means they must come from Anoka County. The other half would need to come from the larger Bank Service Area. The bank credits from Anoka county would likely be very expensive. A few ways to deal with this: • Reduce the amount of wetland to be impacted, reducing the needed replacement. • Create mitigation on -site, or within the major watershed area and in Anoka County. Restoration of drained or filled wetland is preferred over creation. If one of the other farmed wetland that was proposed to be impacted under the existing permit were actually used as mitigation, that would have the added effect of reducing impacts, and thus the needed mitigation for the existing permit (fewer bank credits needed). • Try to get the TEP to agree that the WNW wetland is "agricultural land". This would reduce the required replacement ration to 1:1. This may be a tough sell since the site has not been farmed for a number of years. • When the new application is prepared, perform a new wetland delineation to show that the size of the wetland is smaller than what was originally delineated (reducing the amount of wetland that needs to be replaced). The TEP may argue that the smaller size is actually the result if indirect impacts caused by a change in land use. We could counter with the fact that drainage to the wetland has not changed, no grading around the wetland has occurred, and that the only land use change was the abandonment of farming, therefore they should either approve the new delineation, or declare the wetland to be Agricultural Land (1:1 replacement ratio). There is a lot of information here, so give me a call if you have questions. I will be traveling Friday and Monday, so call me on my cell phone (952-292-8489) if you have questions. --Tony Tony Kaster Senior Wetland Scientist URS Corporation Fifth Street Towers 100 South Fifth Street, Suite 1500 Minneapolis, MN 55402 612-373-6319 tony_kaster@urscorp.com This e-mail and am attachments contain 1JRS Corporation confidential information that may be proprietary or privileged. if you receive this message in error or are not the intended recipient, you should not retain, distribute; disclose or use any of this information and you should destroy the e-mail and any attachments or copies 2