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• Private residential and commercial water access and use facilities: There are limited <br />exceptions for private residential and commercial activities. <br />o Private roads. Private roads serving three or more lots may be constructed in the bluff <br />impact zone if doing so is the only means of accessing level land on a terrace or at the <br />foot of the bluff. This exemption, however, applies only to roads serving three or more <br />lots — i.e., subdivisions — not individual parcels. <br />o Access paths. Access paths, stairways, lifts, and landings are permitted within the <br />shore impact zone and bluff impact zone as necessary to permit private land owners to <br />enjoy the amenities of their property. This exemption is consistent with the access <br />exemptions permitted by Minn. R. 6120.3300, subp. 3 I (2015), which permits <br />shoreland property owners to construct access paths, stairs, lifts and landings within <br />the shore impact zone. <br />o Water -oriented accessory structures. Water oriented accessory structures such as <br />gazebos, decks, patios, fish houses, screen houses and pump houses are often used by <br />private land owners to enjoy the amenities of the MRCAA corridor and are exempted <br />from certain requirements of the proposed MRCCA rules. These exemptions are <br />consistent with the requirements in the state shoreland rules, chapter 6120.3300, <br />subp.3.H. (2015). <br />Conclusion <br />Based on the foregoing, the proposed rules are both needed and reasonable. <br />Date: December 9, 2015 <br />/s/Tom Landwehr <br />Commissioner <br />69 <br />