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

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From: Steve Minn To: Berg Jeffre J.DNR); Rulemaking MRCCA DNR); Wooden, Rebecca A (DNRJ; Shillcox Jennifer (DNR) Cc: James Vaale; matt.anfanq@bomastoaul.ora Subject: RE: MRCCA urban west work group meeting June 23rd Date: Wednesday, June 30, 2010 3:11:34 PM Greetings, DNR MRCCA Rulemaking Team: Please accept the following additional written comments into the record, pursuant to the Urban West work group discussion of June 23, 2010: I note that I was the only representative in attendance from the landowner/developer/construction/homebuilder constituency. I offer comments on my own as an adjacent landowner to the river, and on behalf of the broader coalition, with whom I have consulted in preparing these remarks. 2. I emphasize that the mere frequency of repetition of anti -development suggestions by the "Friends of the Mississippi" coalition does not constitute a majority of opinion. Several members of the work group who have self -identified as "representing themselves" are in fact affiliated with open space, anti -development or river park advocacy groups, this includes: Schlichting, Tucker and Pierson, who are strongly allied with Jones and Brazaitis. The Commissioner should take this into account when reviewing comments and have the necessary perspective on how their comments are effectively of one interest group. Where additional protections are noted — they lack specificity and clarity. There are a host of stormwater Best Management Practices (BMPs) that can suffice in many instances. These also stay ahead of slow-moving regulations by allowing for inclusion of technology or methods to attain water quality goals. We prefer local BMP policy over state regulation. 4. Vegetative buffers serve a legitimate water quality purpose, but their performance diminishes at a given point depending on site characteristics. Buffer establishment should rely on local or watershed guidance that has scientifically justified the buffer widths — or clarify that this analysis will be done based on site characteristics and not established in an arbitrary fashion. 5. DNR overlay on existing local rules, watershed rules should be accounted for in these districts to avoid confusion and duplication. 6. The comprehensive planning done by metro cities and reviewed by the Metropolitan Council should guide much of the land in question. 7. General responses to proposed MRCCA Land Use Districts A & B — In areas where there is dedicated storm sewer service, regulatory controls for stormwater management will be guided by best management practices, and not unique requirements that are not specified in local ordinance. b. The attempt to insert "A" Districts within a "D" or "Y District general area