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Page 9 <br />RECOMMENDATION 5.1. Draw the boundary of District E to conform to the <br />proposed definition given for District E. <br />When District E is used on or near a bluff face, it generally stands in contradiction to the draft <br />definition provided for District E. That draft definition suggests that, "land in this district is not <br />readily visible from the river surface or opposite bank." Clearly, however, some areas <br />designated as District E do not fit this definition. The bluffs of places like the Mississippi River <br />Gorge and St. Paul's Highwood Hills and West Side neighborhoods are clearly visible from the <br />river, but these areas have been included in District E. <br />Comprehensively, the areas that currently are in District E that do not fit this proposed <br />definition are found in Cottage Grove's River Acres and Mississippi Dunes Golf Course, Inver <br />Grove Heights (above Concord St), Lilydale, Maplewood's Fish Creek area, Mendota, Mendota <br />Heights, Minneapolis and St. Paul's Gorge neighborhoods, St. Paul's Highwood Hills <br />neighborhood, Mounds Park neighborhood, West Seventh neighborhood, West Side <br />neighborhood, as well as the blufflands in South St. Paul. If necessary, we could provide <br />photographic evidence that most of these blufflands are "readily visible from the river surface or <br />opposite bank". <br />RECOMMENDATION 5.2. Establish a clear threshold: all parcels within one-tenth <br />of a mile of a bluff or the river's edge should be ineligible to become District E. <br />We propose that District E should be redrawn to encompass only those areas that have little <br />unique impact on the river corridor's ecological, cultural, and scenic resources. Even the <br />blufftops of many areas have very significant impacts on the river's resources – think of the view <br />of Lilydale from Crosby Farm Regional Park. <br />Even Minneapolis — which has among the most incomplete Critical Area codes — delineates a <br />different height standard for areas within 100 feet of a blufftop, than for areas outside of the <br />bluff. We believe that all lands within a tenth of a mile of the blufftop should in no case be <br />placed in District E. Rather, District E should be reserved for those areas which clearly do not <br />impact our ability to protect corridor resources. <br />In rural areas such as Ramsey and Dayton, this would mean the land beyond Dayton River Road <br />and US 10 should become District E. As described under Principle 2 above, bringing District E <br />any closer to the river than that will upset a delicate and critical long-standing balance <br />surrounding open space preservation that has existed in Ramsey and Dayton. Instead, most of <br />Draft District E should become District B in these areas, as described above. <br />In urbanized areas including Champlin, Anoka, Coon Rapids, and the Gorge through Minneapolis <br />and St. Paul, the areas of District E that are within I/10th of a mile of bluffs or the river's edge <br />should generally either become District C, or alternately District A. <br />