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Page 2 <br />This is not the path that has been taken thus far. Separately, we have submitted mapping of a possible <br />districting scheme that responded less to land use patterns, and more to the core systems Critical Area <br />is designed to protect. We hope at the very least that the final districting scheme moves decisively <br />toward a districting system not based on land use, but based on the key resources and functions the <br />Critical Area is designed to protect. <br />One of the challenges of a districting scheme that is more rooted in fine-grained land -use patterns is that <br />it raises the question of how districts are to adapt and change as the land uses change. As soon as we <br />identify uses that could change or expand over time, we must build in a mechanism for these districts to <br />grow, change and evolve over time, or we risk the districts becoming stale and out-of-date. <br />One aspect that must be addressed is parkland. One area of parkland poised to grow, for example, is <br />around the Ford Plant site in St. Paul's Highland Park neighborhood (Map 32), where the area currently <br />designated F will likely become parkland in the not -too -distant future, and likely become part of the <br />surrounding regional park. How can this land be protected like the property surrounding it as part of a <br />Zone A? Should we protect this land now, believing it will soon become public parkland? Or will there <br />be a mechanism to review this and other similar changes? <br />We don't have answers for these questions, but we hope the DNR has thought about this issue. <br />Permanently protecting the public values of the river in a growing, changing metropolitan area is the <br />challenge — and the promise of these rules. <br />This process has unfolded quickly, and the stakeholder workshops and intervening days have given us an <br />opportunity to reflect on the districts in their full interrelated complexity. To that end, we offer a <br />cohesive set of comments here, suggesting several changes to the draft districts, based on how well the <br />districts work toward achieving the intent for rulemaking that is set forth in state statutes. <br />There are two parts to our comments. Many of our comments are overarching in nature – questions <br />about the principles and approaches behind the districts, which are incorporated into Part I of our <br />comments. Part I is organized in general to address the districts in the order of their letters. It is <br />organized around a series of principles, under which we provide one or more recommendations or <br />options to help realize those principles. Part II includes more site-specific issues. <br />