Agenda - Council - 02/09/1999 - Laserfiche WebLink

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Mr. Steven Jankowsky Page Three Item II1 C 8: Wetlands (Questions about wetlands impacts and the MPCA's 401 Certification requirements should be addressed to Larry Zdon at 651/297-8219) This Item provides a very short description of the wetland functions of the basins in the area. This description includes a paragraph on stormwater storage and water quality protection. While the two sentences in this paragraph are by themselves not untrue, since they are the only description language on the hydrology function of the wetlands in this document, they tend to paint a very distorted view of the wetlands function in the developed landscape. Wetlands, of course, do provide a function of capturing runoff in the landscape. In developed areas though, any reliance on natural wetlands to handle all the increased runoff from impervious surfaces and the increase pollutants from these areas would probably degrade these wetlands severely. Increased runoff from future development should be treated and entrained pollutants removed to the point that these existing wetlands will not be degraded. These description sentences that are too brief to be completely accurate in this document should have been deleted or this text should have been expanded to really address the hydrologic functions of wetlands in general and these wetlands in specific for the present proposal and for potential future development. Item III C 8 c indicates that wetland mitigation has not yet been finalized and may consist of onsite project specific mitigation and possibly some debit of wetland credit from BWSR Wetland Mitigation Banks. All proposals for onsite wetlafid mitigation should be presented in the EA in order to assess the impacts of that proposal. The proposal to use a debit of wetland credit through the Minnesota Wetland Mitigation Bank may be acceptable, however, the proposer must first evaluate the possibilities to provide compensatory wetland mitigation as a project specific mitigation with priority preference to being onsite and in kind. If these opportunities do not reasonably exist, the use of the mitigation bank in accordance with the Wetland Banking Program in Minnesota Rule is acceptable. This issue should be addressed in the submission to the MPCA of materials for the Agency's Section 401 Certification of the Section 404 Permit. Thank you for the opportunity to review this EAW/EA. We look forward to seeing your response to these comments and your record of decision on the need for an EIS, as required by Minn. R. 4410.1700, subps. 3, 4, and 5. Should you have any questions about this letter, please contact me at 651/296-8643. Eric J. Kilberg Planner Principal Operations and Planning Section Metro Distr/ct EYK:sjs cc: Cheryl Martin, Federal Highway Administration Gregory Felt, Metropolitan Division State Aid Engineer I I I I I I I I i i ! I I I !