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Actively eroding and/or failing bluffs have also been identified as problems by citizens and government <br />officials in the Lilydale, Mendota, and Mendota Heights area. Heavy rains over the past decade - <br />including those in June 2014 - led to significant erosion and the failure of some bluffs within the MRCCA, <br />including failures off Highway 13 in Mendota Heights (see Figure 3) and below Fairview University <br />Hospital in Minneapolis. With FEMA funding, the DNR <br />conducted an investigation' of these and other bluff <br />failures associated with the June 2014 rain events in <br />the Mississippi and Minnesota River valleys'. The <br />structural geologist conducting this evaluation found <br />that all failed bluffs within the MRCCA had slopes had <br />been modified for building foundations, stormwater <br />management facilities, or road construction, and that <br />these modifications contributed to bluff failure. In <br />these particular instances the bluff failures also <br />resulted in significant damages to built infrastructure. <br />Figure 3. Highway 13, Great Rivers Trail failure in Mendota <br />Heights. Photo from http://www.myfoxtwincities.com/ <br />story/25740202/mudslide-closes-highway-13-in-mendota. <br />Bluffs also need protection because they provide wildlife habitat and support native plant communities. <br />As illustrated by Minnesota's Land Cover Classifications System (MLCCS), a GIS-based classification <br />system, there is a greater occurrence of native flora and fauna along bluffs and steep slopes'° <br />Better corridor -wide management practices addressing structure placement and vegetation, land <br />alteration, and stormwater management can reduce the risk of soil erosion and bluff failure as well as <br />economic loss and human injury. <br />Current Regulatory Status <br />Executive Order 79-19 does provide special protection of "bluffs with a slope greater than 18 percent," <br />but does not define the term "bluff." Executive Order 79-19 does, however, define a bluffline as "a line <br />delineating the top of a slope connecting the points at which the slope becomes less than 18 percent" <br />and establishes a 40 foot structure setback from the bluffline. Executive Order 79-19 also limits certain <br />vegetation and land alteration activities within the bluffline setback and prohibits new structures on <br />slopes 18 percent or greater. <br />An examination of local ordinances within the MRCCA indicates that currently bluff definitions and <br />standards vary widely across communities, as does administration of those requirements in local zoning <br />ordinances. Many communities simply define a bluff as any slope greater than 18 percent, while others <br />define them as slopes ranging from 12 percent to 40 percent. Some communities have specified the <br />spatial extent of bluffs through use of minimum horizontal and/or vertical distances over which the <br />8 Jennings, C. 2015. <br />http://www.dnr.state.mn.us/mlccs/index.html <br />10 http://www.dnr.state.mn.us/mlccs/index.html <br />23 <br />