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4. Page 21, Rare Features. This section states that minimal tree removal will be required as part of the project, however, Table 3: Cover Types shows that the project proposes to remove over seven acres of trees, which is a large impact in such a developed area and near a river corridor. Even if significant trees are replaced, it will take decades for new trees to grow enough to provide the same ecological benefit. We strongly encourage the proposer to preserve as many trees as possible. We recommend that any revegetation plan for the site utilize native plants to the greatest degree possible. Please be aware that turf grass does not provide any ecological benefits and requires more maintenance, inputs, and irrigation than native species. 5. Page 21, Rare Species. This section states that no impacts to Blanding's turtles are anticipated because the project will not be impacting wetlands. That is incorrect since Blanding's turtles also use upland sites and can travel great distances. The EAW should identify which fact sheet recommendations the proposer is willing to commit to in addition to the required avoidance measures. The Blanding's turtle fact sheet contains several measures regarding wetland buffers, roads, utilities, and landscaping that are pertinent to this type of project. The DNR recommends a wider buffer than the proposed 16.5' wetland buffer as well as the use of surmountable curbs. Please also refer to the required avoidance measures for Blanding's turtle that were provided in the July 7, 2023 Natural Heritage letter and have been copied below: Blanding's turtles (Emydoidea b/andingii), a state -listed threatened species, have been documented in the vicinity of the proposed project. Blanding's turtles use upland areas up to and over a mile distant from wetlands, waterbodies, and watercourses. Uplands are used for nesting, basking, periods of dormancy, and traveling between wetlands. Factors believed to contribute to the decline of this species include collisions with vehicles, wetland drainage and degradation, and the development of upland habitat. Any added mortality can be detrimental to populations of Blanding's turtles, as these turtles have a low reproduction rate that depends upon a high survival rate to maintain population levels. This project has the potential to impact this rare turtle through direct fatalities and habitat disturbance/destruction due to excavation, fill, and other construction activities associated with the project. Minnesota's Endangered Species Statute (Minnesota Statutes, section 84.0895) and associated Rules (Minnesota Rules, part 6212.1800 to 6212.2300 and 6134) prohibit the take of threatened or endangered species without a permit. As such, the following avoidance measures are required: • Avoid wetland and aquatic impacts during hibernation season, between September 15th and April 15th, if the area is suitable for hibernation. • The use of erosion control blanket shall be limited to 'bio-netting' or 'natural -netting' types, and specifically not products containing plastic mesh netting or other plastic components.