Agenda - Council - 08/24/2010 - Laserfiche WebLink

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x� F � � � Jw A. . �x l (x , . f ,xx. s)n� . f xx � P t �x max . U: HA E -I ll77 1 0si ::: ,... ti... v. June 30, 2010 Jeff Berg Minnesota Department of Natural Resources, Waters Division 500 Layfayette Road St. Paul, MN 55155 Dear Mr. Berg, Friends of the Mississippi River (FMR) is a local non-profit organization that works to protect and enhance the natural and cultural assets of the Mississippi River and its watershed in the Twin Cities. We have 1,400 active members and 3,200 volunteers who care deeply about the river's unique resources. Today, we share our comments on the new draft of Critical Area Districts, released by the DNR and MNRRA in June. Thank you as always for the opportunity to share our reactions and insights. As we write our comments, we are hopeful the new Districts will conform to the intent of Minnesota Statutes § 116G. 15, subd. 4 which provides that, The guidelines and standards for each district shall include the intent of each district and key resources to be protected based upon paragraph (b)... (b) The guidelines and standards must protect or enhance the following key resources and features: (1) floodplains; (2) wetlands; (3) gorges; (4) areas of confluence with key tributaries; (5) natural drainage routes; (6) shorelines and riverbanks; (7) bluffs; (8) steep slopes and very steep slopes; (9) unstable soils and bedrock; (10) significant existing vegetative stands, tree canopies and native plant communities; (1 1) scenic views and vistas; (12) publicly owned parks, trails and open spaces; (13) cultural and historic sites and structures; (14) water quality. On a large scale, FMR had hoped that the districts would not so much be based upon land uses, as they would respond to the unique geomorphology, natural systems, scenic viewsheds, and cultural resources of the river corridor, as guided by the language in § 116G. 15. It was our expectation that the district descriptions would include an intent or purpose that is directly tied to resource protection based on the list in paragraph (b) above. Writing standards to protect key resources for districts that do not tie back to those key resources will be challenging and possibly less defensible. Rather than codifying temporal land use patterns, districts based on geomporphology, natural systems, scenic viewsheds and cultural resources would respond to the most immutable characteristics of the corridor — the very characteristics the Critical Area and MNRRA were designed to protect.