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Page 10 <br />PRINCIPLE 6. Industrial land uses should not be codified semi -permanently in Critical <br />Area districts. <br />We do not see any reason to grant industrial land uses any special recognition within the Critical Area <br />Districts. Certainly, existing industrial uses can continue to exist, and new ones can be implemented in <br />appropriate areas <br />RECOMMENDATION 6.1. All land in Draft Districts G and H should be reclassified <br />as District F in urbanized areas, and B in rural areas. <br />We think the standards of District F can provide for new industrial uses away from the <br />riverfront; and allow for new industrial uses on the riverfront as long as they require a <br />riverfront location. We also believe industrial uses in the more rural parts of the corridor can <br />continue to be accommodated within District B. As such, we don't believe that Districts G and <br />H are needed, and support folding them into District F and District B. <br />Among the major industrial sites in the southern, rural part of the corridor, Aggregate <br />Industries is identified as B, while Flint Hills Resources is identified as G. We suggest that both <br />of these areas shoud be zoned in B or a similar rural district to ensure the high quality natural <br />features and habitat of these sites are protected and do not get overdeveloped in the future <br />PRINCIPLE 7. Respond appropriately to protect the resources and uniquely diverse <br />conditions found in the Combined District F/G/H. <br />Again, here, it is impossible to look at districts without getting somewhat into standards. And <br />developing a common height standard to apply to all of these areas seems fraught with challenges. For <br />example, in the West Side Flats area, the City of St. Paul has established 60 feet as a key threshold in <br />helping protect the viewscape around the massive river basin that defines the city's core area. But a 60 - <br />foot height limit throughout the Ford Motor Company site would likely produce buildings that are highly <br />visible from landmark locations such as the viewing platform at Fort Snelling, Wabun Park, and <br />Minnehaha Park. This is at odds with the mandate the DNR was given in crafting rules. <br />Many, and probably most of the areas in District F are those that require special attention to protect <br />their scenic qualities. Such areas include: <br />• Ford Motor Company Site in St. Paul's Highland Park Neighborhood <br />• St. Paul's Victoria Park neighborhood along West Seventh Street <br />• St. Paul's West Side Flats area <br />• Stockyards area in South St. Paul <br />Thus, in order to adequately protect the scenic amenities of the corridor, there is a lot of variation in <br />standards that will be required. As we move forward, particularly through the process of developing <br />standards, we hope the DNR and other stakeholders maintain an open mind about how to best <br />accomplish our aims. There are a couple of approaches to this area, and we think one or more of these <br />approaches should be integrated into the rules; they are not necessarily mutually exclusive. <br />