Agenda - Planning Commission - 02/02/2017

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protects the major bluff systems. Figure 4 shows the analysis for a portion of the Highwood neighborhood in St. Paul. Similar results were found when analyzing other sites in six other local governments across the MRCCA. After many analytical iterations and field verification, it was determined that a bluff defined as a feature with an 18% slope rising 25 feet over a 25 foot width would provide the best balance between resource protection and minimizing the creation of new nonconforming structures. This definition (as shown in green in Figure 4) eliminated most minor topographic variations such as grading for driveways, yet encompassed the iconic bluffs that characterize the river corridor, as well as natural vegetation and habitat systems. Before advancing this definition for inclusion in the MRCCA rules, DNR staff conducted field visits to understand how different bluff definitions might affect topographic, ecological, and scenic resources. Examples of structures located on 18% slopes with a vertical rise of at least 10 feet (indicated by the red outlined structures overlapping the purple shaded area in Figure 4) are shown below in Figures 5 and 6. Figure 5: Example of property on 18% slope rising at least 10 feet. Figure 6: Example of property on 18% slope rising at least 10 feet. These properties are in established urban neighborhoods, on isolated 18% slopes with little natural vegetation. These properties have very similar topography and vegetation to other nearby properties that are not in the MRCCA. The DNR did not find any significant erosion risks in these areas or ecological or scenic resources to protect. Most of these properties are not visible from the river; however, some are located within 40 feet of bluffs as defined by the proposed definition, and would need to meet the bluff setback requirements set forth in proposed Minn. R. 6106.0120 or would be considered nonconforming. 25