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HomeMy WebLinkAbout5J Meadows of Cleary Lake Wetland Replacement Plan Report Phone 952.447.9800 / Fax 952.447.4245 / www.cityofpriorlake.com 4646 Dakota Street SE Prior Lake, MN 55372 CITY COUNCIL AGENDA REPORT MEETING DATE: DECEMBER 3, 2018 AGENDA #: 5J PREPARED BY: PETE YOUNG, WATER RESOURCES ENGINEER PRESENTED BY: PETE YOUNG AGENDA ITEM: CONSIDER APPROVAL OF A RESOLUTION APPROVING THE WETLAND REPLACEMENT PLAN FOR THE MEADOWS OF CLEARY LAKE DEVELOPMENT PROJECT GOAL AREA AND OBJECTIVE: Environmental Stewardship & Recreation 2. Protect and enhance the quality of Prior Lake’s surface waters DISCUSSION: Introduction The purpose of this agenda item is to consider approval of a wetland replacement plan application for the Meadows of Cleary Lake development project. History On January 18, 1994, the City Council passed Resolution 94-01 adopting the permanent rules of the Wetland Conservation Act (WCA) of 1991. Along with this, the Council also assumed the role of local government unit (LGU) for making WCA determinations for landowners. The purpose of WCA is as follows: 1. Achieve a no net loss in the quantity, quality, and biological diversity of Minnesota’s existing wetlands; 2. Increase the quantity, quality, and biological diversity of Minnesota’s wetlands by restoring or enhancing diminished or drained wetlands; 3. Avoid direct or indirect impacts from activities that destroy or diminish the quantity, quality, and biological diversity of wetlands; and 4. Replace wetland values where avoidance of activity is not feasible or prudent. In accordance with the WCA rules, the City Council must approve all plans for restoration of impacted wetlands before any wetland impact may occur. LGU decisions under the WCA must be made in compliance with Minn. Stat. § 15.99; generally, this means that an application for a WCA decision must be approved or denied within 60 days or it will be deemed to be granted. The applicant (Key Land Homes) submitted a complete WCA application for a replacement plan for the Meadows of Cleary Lake development project on October 22, 2018. The proposed project includes the development of approximately 20 acres of land into 48 residential lots. The project will result in a total of 0.377 acre of wetland impacts. The proposed impacts will result from the construction of the project. The application was noticed to the WCA Technical Evaluation Panel (TEP) on November 7, 2018. The TEP is advisory in nature and makes technical findings and recommendations. TEP members include representatives from the City, the Board of Water and Soil Resources (BWSR), the Scott Soil and Water Conservation District (SWCD), and the Minnesota Department of Natural Resources (DNR). The TEP met on November 15, 2018 to review the application. Comments were allowed until November 30, 2018. The TEP provided comments to the applicant on November 15, 2018. The applicant provided satisfactory responses to the TEP comments on November 26, 2018. Considering these responses, the TEP is supportive of the application. Current Circumstances Key Land Homes is proposing to construct the Meadows of Cleary Lake development project. Construction of the project will result in 0.377 acre of permanent wetland impact. According to the WCA, permanent wetland impact for this project must be addressed by replacing wetlands at a 2:1 ratio. Therefore, a total of 0.754 acre of wetland replacement is required for the project. The wetland application is included as Attachment 1, a memo from the City’s wetland consultant is included as Attachment 2, a draft Notice of Decision (NOD) form is included as Attachment 3, and the TEP comments and applicant responses are included as Attachment 4. Key Land Homes will replace wetlands through the purchase of wetland bank credits from an approved wetland bank within the same Bank Service Area (Area 9), which meets the replacement plan siting requirements of the WCA. The total amount of wetland replacement provided will be at least 0.754 acre. The project meets the requirements for a replacement plan application and proposes to replace 0.377 acre of wetland in accordance with the WCA. The replacement plan should be approved. As a condition of approval, the applicant is required to submit a fully executed Withdrawal of Wetland Credits form to the City and to BWSR. If this replacement plan is approved, City staff will execute the WCA NOD form. ISSUES: If approved, this replacement plan approval constitutes the final step in the WCA process before wetland impacts associated with the Meadows of Cleary Lake development project may occur. The applicant must also comply with the US Army Corps of Engineers wetland impact approval process. The Corps wetland permitting process is separate from the City’s WCA process. FINANCIAL IMPACT: Approving this wetland replacement plan will have no financial impact on the City budget. ALTERNATIVES: 1. Motion and a second as part of the consent agenda to approve a resolution approving the wetland replacement plan for the Meadows of Cleary Lake development project as proposed, or as may be amended by the City Council. 2. Motion and a second to remove this item from the consent agenda for additional discussion. RECOMMENDED MOTION: Alternative #1 4646 Dakota Street SE Prior Lake, MN 55372 RESOLUTION 18-_____ A RESOLUTION APPROVING THE WETLAND REPLACEMENT PLAN FOR THE MEADOWS OF CLEARY LAKE DEVELOPMENT PROJECT Motion By: Second By: WHEREAS, The City Council is the Local Governing Unit responsible for permitting under the Wetland Conservation Act (WCA); and WHEREAS, The wetland replacement plan avoids unnecessary wetland filling on the project to the greatest extent possible; and WHEREAS, Sequencing criteria has been met; and WHEREAS, The proposed impact is 0.377 acre; and WHEREAS, A replacement plan to purchase 0.754 acre of wetland bank credits is proposed to meet the WCA required replacement ratio of 2:1, and WHEREAS, The replacement plan is in accordance with WCA and City of Prior Lake ordinances; and WHEREAS, The applicant must provide the City with a fully executed Withdrawal of Wetland Credits form prior to any wetland impacts. NOW THEREFORE, BE IT HEREBY RESOLVED BY THE CITY COUNCIL OF PRIOR LAKE, MINNESOTA as follows: 1. The recitals set forth above are incorporated herein. 2. The wetland replacement plan for the Meadows at Clear Lake development project is approved. Passed and adopted by the Prior Lake City Council this 3rd day of December 2018 VOTE Briggs McGuire Thompson Braid Burkart Aye ☐ ☐ ☐ ☐ ☐ Nay ☐ ☐ ☐ ☐ ☐ Abstain ☐ ☐ ☐ ☐ ☐ Absent ☐ ☐ ☐ ☐ ☐ ______________________________ Frank Boyles, City Manager WENCK File #7285-0002 September 2018 Prepared by: WENCK Associates, Inc. 1800 Pioneer Creek Center Maple Plain, MN 55359 Phone: 763-479-4200 Fax: 763-479-4242 Prepared for: Key Land Homes [insert company logo if available] 17021 Fish Point Road Prior Lake, MN 55372 Wetland Replacement Plan: Meadows of Cleary Lake Development, Prior Lake September 2018 1 V:\Technical\7285 Key Land Homes\0002 Meadows of Cleary Lake Impact Permitting\Meadows of Cleary Lake Replacement Plan Application_Final.docx WENCK File #7285-0002 September 2018 Table of Contents 1.0 INTRODUCTION .......................................................................................... 1-1 1.1 Project Need and Purpose .................................................................... 1-1 1.2 Compatibility with Existing Land Use ...................................................... 1-1 2.0 PROJECT DESCRIPTION .............................................................................. 2-1 2.1 Current Site Conditions ........................................................................ 2-1 2.2 On-Site Wetlands ................................................................................ 2-1 2.3 Proposed Project ................................................................................. 2-1 2.4 Proposed Wetland Impact Areas ............................................................ 2-1 2.4.1 Impact Summary .................................................................... 2-2 2.5 MnRAM Assessment ............................................................................. 2-2 3.0 ALTERNATIVES AND SEQUENCING FLEXIBILITY ......................................... 3-1 3.1 Alternatives ........................................................................................ 3-1 3.1.1 No Build ................................................................................. 3-1 3.1.2 Alternative Configuration .......................................................... 3-1 3.2 Sequencing Flexibility .......................................................................... 3-1 3.3 Compensatory Mitigation Plan ............................................................... 3-1 FIGURES 1. Site Location Map 2. 2018 Delineated Wetlands APPENDICES A Site Plans B MnRAM Summary Reports September 2018 1-1 V:\Technical\7285 Key Land Homes\0002 Meadows of Cleary Lake Impact Permitting\Meadows of Cleary Lake Replacement Plan Application_Final.docx 1.0 Introduction The applicant, Key Land Homes, is proposing development of 48 single-family residential lots on an approximately 20-acre site in Prior Lake, Minnesota. The site is located at 5516 and 5570 180th Street East in Prior Lake, south of Trail Head Lane and east of Cleary Trail SE (Figure 1). The site was previously a residential lot and rural land used for horse pasture. Vegetation consists of mixed weedy grasses and forbs consistent with disturbed land. 1.1 PROJECT NEED AND PURPOSE The purpose of the project is to provide much-needed options for single family residential housing in a rural setting within close commuting distance of the Twin Cities. This area is growing rapidly and the population increase is creating a demand for additional homes. This need is described in Chapter V of the Scott County 2030 Comprehensive Plan (Plan). The Plan states that 60,000 to 70,000 acres of platted developable land are need ed to accommodate anticipated population growth in the coming years. Much of the unincorporated single family residential areas are located in Spring Lake, Credit River, New Market, and Cedar Lake Townships. Spring Lake Township, where the project is located, is one of the main targets for absorbing this growth in housing development. 1.2 COMPATIBILITY WITH EXISTING LAND USE Both parcels within the site are currently zoned UER, or Urban Expansion Reserve, which were identified in the Scott County 2030 Comprehensive Plan “for logical future extension of urban land uses served by public utilities. This zoning district is intended to preserve these areas of the County in very low rural development densities or clustered residential developments that may be compatibly integrated with future urban development” (Scott Co. Zoning Ordinance, 2001). The site will be incorporated into the City of Prior Lake as part of the platting process. The City of Prior Lake goals for the 2040 Comprehensive Plan indicates a need for increased housing to capture expanding populations in the area, including an average housing density of 3.0 units per acre or higher. The proposed use is compatible with the existing land use within Scott County, but additionally with future land use goals within the City of Prior Lake once incorporated. September 2018 2-1 V:\Technical\7285 Key Land Homes\0002 Meadows of Cleary Lake Impact Permitting\Meadows of Cleary Lake Replacement Plan Application_Final.docx 2.0 Project Description 2.1 CURRENT SITE CONDITIONS The project would involve the development of a site that has been used mainly as a homestead with agricultural land. Currently, the site is primarily open land, with two approximately 10-acre residential parcels each with one single family residence. The site would be served by three access points: one extending from an existing road stub (Mission Trail) from the development to the north, one extending from the Prairie Way road stub to the west, and one access from 180th Street East to the south. Mission Trail and a second internal street would service the development. The topography of the site is moderately sloping, highly variable with localized topography throughout the site. 2.2 ON-SITE WETLANDS Wetlands were delineated in May 2018 and the boundaries of 2 wetlands were identified on site. Additionally, a Level 1 desktop wetland investigation was performed to identify the northern boundaries of Wetlands 1 and 2 on the small outlot parcel at 17744 Mission Trail since access to those areas was not available at the time of field work. Wetlands 1 and 2 were identified as Type 2, PEM1B wet meadow wetlands. During the TEP review of the Level I determination, the TEP revised the offsite boundaries of Wetlands 1 and 2 to show that they are hydrologically connected and thus, are considered one basin. Boundaries of the new wetland basin are shown in Figure 2 – Approved Wetland Boundaries. The basin is considered a Type 2, PEM1B wetland. 2.3 PROPOSED PROJECT The Meadows of Cleary Lake development project would involve the construction of 48 single family residential lots with three associated internal roads. As described above, Mission Trail will be extended south connecting to 180th Street East and Prairie Way will be extended toward the east. An additional unnamed interior road will be developed. The 48 lots would be developed on a net area of 19.32 acres, meeting the density needs of the City of Prior Lake 2040 Comprehensive Plan land use density objectives, which is a minimum of 3 units per acre or higher. 2.4 PROPOSED WETLAND IMPACT AREAS Areas of proposed wetland impact are depicted in Appendix A – Site Plans. Approximately 0.384 acres, or 16,735 square feet of wetland will be filled. These impacts are necessary for the construction of two of the 48 proposed residential lots within the development. Additionally, impacts will be completed to construct stormwater treatment facilities contained within an outlet within the development. According to the City of Prior Lake, a portion of the western lobe of the wetland (previously Wetland 2) within the 17744 Mission Trail parcel was previously mitigated for during the construction of the Enclave at Cleary Lake, the neighboring residential development, but was never impacted during construction. Therefore, the Applicant does not propose mitigation for 0.00683 acres of wetland impacts as it has already been mitigated. September 2018 2-2 V:\Technical\7285 Key Land Homes\0002 Meadows of Cleary Lake Impact Permitting\Meadows of Cleary Lake Replacement Plan Application_Final.docx 2.4.1 Impact Summary The total proposed wetland impact is 16,735 square feet (0.377 acres, less the previously mitigated impacts). The applicant proposes to replace for wetland impacts through the purchase of wetland bank credits. A discussion of mitigation is included in Section 3.4 below. 2.5 MNRAM ASSESSMENT A MnRAM assessment was performed for both wetlands as part of the replacement plan development. The report results show that each wetland scored an average of 0.10, or Low Quality. Categories assessed within the MnRAM report included vegetative diversity, which scored low due to the dominance of invasive species in the wetland vegetation communities. The MnRAM report is provided in Appendix B. September 2018 3-1 V:\Technical\7285 Key Land Homes\0002 Meadows of Cleary Lake Impact Permitting\Meadows of Cleary Lake Replacement Plan Application_Final.docx 3.0 Alternatives and Sequencing Flexibility 3.1 ALTERNATIVES 3.1.1 No Build One project alternative is the No Build alternative. The No Build alternative does not fulfill the project purpose, nor does it meet the housing goals of the City of Prior Lake 2030 Comprehensive Plan and future housing density needs. Due to its proximity to existing residential subdivisions, a future similar project would likely have similar impacts to wetlands as those proposed. 3.1.2 Alternative Configuration The access point which triggers proposed wetland impacts (Mission Trail) is dictated by the Enclave project that was previously constructed. The only way to avoid this proposed impact would be to eliminate two lots on the south side of the proposed Mission Trail alignment. For reasons explained in the next section, this alternative is not feasible and practicable based on the very low quality of the wetland proposed for impact. 3.2 SEQUENCING FLEXIBILITY The Applicant requests sequencing flexibility under Chapter 8420.0520 Subp. 7a, Sequencing Flexibility. Wetlands 1 and 2 (now combined, as per TEP guidance) both scored as low quality based on the MnRAM assessment and have been degraded by past development. The wetland previously delineated as Wetland 2 was previously significantly larger and was partially impacted by the Enclave at Clearly Lake development, reducing it to less than half of its original size. It appears that the wetland basin used to flow to the larger wetland complex offsite to the north (see Appendix C, Historical Aerials) before the Enclave project was constructed. The eastern lobe of the basin (former Wetland 1) appears to have been a historical drainage swale while the property was actively agricultural (see Appendix C, 1951 and 1997). Construction of the Enclave at Cleary Lake (2006) shows site disturbance initiated in the northern portion of the delineated wetland. Aerial imagery from 2000 shows most clearly the extent of Wetland 2 prior to impacts from this earlier development. Both wetlands are located immediately adjacent to Mission Trail and receive untreated stormwater from the road and the development. Both wetlands have been hydrologically cut off and altered from their historical conditions as shown in Appendix C and this would only be compounded by avoiding impacts for this project. The purchase of mitigation credits would provide a greater ecosystem function and public value than what currently exists. 3.3 COMPENSATORY MITIGATION PLAN The Applicant proposes mitigation for proposed wetland impacts at a 2:1 ratio. The unavoidable wetland impact of 0.377 acres will be replaced through the purchase of 0.754 acres of wetland credits from Wetland Bank Account #1468 in Le Sueur County. This bank is in the same Major Watershed (#33) and same Bank Service Area (#9) as the project site. Credit purchase conversations have been initiated with the Bank and a Purchase Agreement will be provided once complete. Figures 1. Site Location Map 2. 2018 Delineated Wetlands T114 R21 S6 T114 R21 S7 T114 R21 S18 T114 R21 S19 T114 R22 S1 T114 R22 S2 T114 R22 S11 T114 R22 S12 T114 R22 S13 T114 R22 S14 T114 R22 S23 T114 R22 S24 KEY LAND HOMES Site Location Map Figure 1 2,000 0 2,0001,000 Feet ±Path: L:\7285\0002\Site Location.mxd Date: 7/30/2018 Time: 2:20:35 PM User: WatME0697 AUG 2018 Scott Dakota Carver Hennepin RiceLe Sueur Project Location Legend Project Area Section Boundary 958958954958956972 958960 958972974 968 9589689 6 2 972 954962 9 6 0 970958970966968 954972 954 948 970970 956960956 964 962 956 962958956948 962 964 958958 970 958950 970 952 956960964958 954 960966968956964 962958 9629609649 5 6 960 956 972 964966 950958958962958958962962952 950 966 9709609 5 6 9689569589609 6 6 96095 8 956964954962KEY LAND HOMES Approved Delineated Boundaries Figure 2 200 0 200100 Feet ±Path: L:\7285\0002\mxd\Approved Wetland Boundaries.mxd Date: 9/11/2018 Time: 3:39:24 PM User: WatME0697 2016 Aerial Photograph (Source: MN GEO) AUG 2018 Legend Project Area 2-ft Contours (Lidar) Approved Delineated Boundaries Appendix A Site Plans WETLAND 16,735.89 SQ. SF. 0.38 AC. 958.0 955.9 957.2 960.2 958.0959.2957.8 958.0 958.9 959.2 960.8 960.5 960.3 960.5 960.7 961.0 957.7 960.3960.3 957.7 960.0 956.9 9 5 9 . 0 95 6 . 4958.5955.9958.5955.9957.6955.2FB FB FB FB *SEWO FB DW DWDW DW DW 0.5' DROP 1.5' DROP 1.5' DROP 2' DROP DW DW DW *SEWO 321321 15 14 9 4 5 6 7 8 1 OUTLOT A 96095 6 16 1' DROP 1' DRO P FB 956.3 958.2 958.0 959.6 959.2 958.2 EX956.6 EX 957.9958.3 956.8 EX 952.3 957.9950.0 956.8950.0 957.8 953.7 956.4 957.8 955.9 956.8 950.0950.8 955.1 944.9 956.9 EX 954.1 955.7 956.8 958.2 959.7 954 956958956956 9569 5 8 954 956 958 960 -0+16 954.22 0+00 954.54 1+00 956.54 2+00 957.04 3+00 956.04 4+00 955.46 5+00 956.71 6+00 958.38HP: 1+66.67 Elev: 957.21 LP: 3+84.32 Elev: 955.43 NWL = 948.0 HWL = 950.2 67 955.6 EXE.O.F. 954.2 E.O.F. 954.2 E.O.F. 957.9 E.O.F. 956.9 959.3959.6960.2960.2959.2957.8959.7959.5959.5958.4958.0957.6958.5957.5E.O.F. 956.26.5%8.3%7.1% 8.1% 7.0%5.3%6.1%7.7%6.3%5.2%5.2%6.4%7.4%7.9%5.6%1.5' DROP1.5' DROP956956 956 960 954954 954 954 954 954 956 956950950948946944942952 950 948 946 944 942 940 938938940942944946 948950952952 950 948 95 2 9 5 0 94 8 94 6 94 4 94 2 9 4 0 93 8 956 958 958 956 956 958 9 5 4 9 5 2952952 954 950950 952 954 954 954 956 958 956 9589 5 0 952 954 956 958 958 1' DROP 961.0 960.7 EBOX CBOX CBOX P-8957.4 P-7958.3 SB-2955.7 SB-3952.1 SB-4958.3SB-1951.0 SB-3955.3 EXISTING RETAINING WALL952.2 952.2 952.2 952.2 952.2 952.2 953.0953.0 953.0 953.0953.0 953.0 950.5 950.5 951.5 STREET AE.O.F.952.2958.0 EX 952.2 E.O.F. 949.5TOP BERM:951.0TOP BERM:951.0949.5 EX949.3 EX948.4 EX5+006+00 7+008+009+0010+00LP: 5+91.41 Elev: 957.46 HP: 6+69.09 Elev: 957.87LP: 8+54.89Elev: 955.71HP: 9+18.29Elev: 956.04LP: 10+04.89Elev: 955.18WETLAND IMPACT 16,735.89 SQ. FT 0.38 AC DATE____________ REG. NO._________ I HEREBY CERTIFY THAT THIS PLAN WAS PREPARED BY ME OR UNDER MY DIRECT SUPERVISION AND THAT I AM A DULY LICENSED ENGINEER UNDER THE LAWS OF THE STATE OF MINNESOTA. WETLAND IMPACTS PRIOR LAKE MINNESOTA 1 1 CO PM 8-6-18 AS SHOWN 16499.00 PRIOR LAKE, MINNESOTA 55372 17021 FISH POINT ROAD KEYLAND HOMES PRIOR LAKE CITY PROJECT #DEV18-0000025 958.0 960.0 959.0 960.3 960.5 959.5 958.0 957.6 959.1 959.5 961.0 960.6 962.1 962.5 962.6 963.0 965.0 960.7 961.0 966.0 966.5 961.5 958.0 955.1 955.9 960.2 958.0959.7957.8 958.1 958.8 959.2 960.8 960.4 959.1 962.5 964.3 960.0 960.6 964.9 965.4 960.4 961.4 966.4 966.3965.9967.4967.8966.0971.0966.0972.8966.8974.3960.3 960.6 960.6 961.0 963.0 958.7 960.5 965.5 968.0 960.5 961.6 969.8 970.8 962.6 967.5 962.5960.0 965.0962.3 957.3956.7 960.3960.3 956.7 960.0 955.7 9 5 9 . 0 95 5 . 4958.5954.9958.5954.9965.5 961.2 957.6955.2FB FB FB FB FB FB FB FB FB FB FB SEWO DW DW FB DW DW DW DW DW FB DW DW DW DW DW DW DW DW FB FB DW 1.4' DROP 1.4' DROP DW FB DW DW FBWO FBWO FBWO FBWO FBWODW *SEWO 1 2 3 1 2 3 4 5 6 7 8 1 876543213 21 15 14 13 12 11 10 9 9 10 11 12 1 2 3 4 5 4 5 6 7 8 1 OUTLOT A 96095 6 964 13 DW 16 0.7' DROP 0.7' D R O P FB 956.8 957.6 964.4 EX 963.0 EX 959.2 956.4 955.9 953.9 EX 956.4 957.9 959.4 960.9 962.2 963.1 964.0 964.1 961.8958.2957.2 EX959.7 EX963.1 EX959.1 EX955.1 EX ??? 963.9 961.7 957.6 EX 962.1 962.3 963.1 963.7 964.3 965.5 EX 971.6 969.8 966.7 964.6 964.1964.4964.2963.3962.4 964.9 968.9968.4 958.9956.9956.3 958.2 958.0 959.6 962.1 964.6 967.0 969.9 967.2 EX962.3 EX 966.7 968.3964.2 961.1 EX959.0 EX 961.7959.2 958.2 EX956.6 EX 957.9958.3 956.8 EX 952.3 957.9950.0 956.8950.0 957.8 953.7 956.4 957.8 955.9956.8 950.0950.8 955.1 944.9 956.9 EX 954.1 955.7 956.8 958.2 959.7 961.1 955.7 EX 9 6 4 954 964960 960 958 956960 962 964 956 958 95896 2 964 962960958956958956 9569 5 8 9 6 0 9 6 2 9 6 4 9 6 6 954 956 958 960 -0+16 954.22 0+00 954.54 1+00 956.54 2+00 957.04 3+00 956.04 4+00 955.46 5+00 956.71 6+00 958.38 7+00 960.05 8+00 961.68 9+00 962.72 10+00 963.72 11+00 964.38 12+00 962.96 13+00 961.20 HP: 1+66.67 Elev: 957.21 LP: 3+84.32 Elev: 955.43 HP: 10+86.25 Elev: 964.40 964.5 969.5FILTRATION BENCH@ 947.5NWL = 948.0 HWL = 950.2 1 2 3 4 5 67 955.6 EX968.5 EX 972.9 EX958.2957.4958.9960.4962.3962.8963.8965.5960.2 962.1 E.O.F. 958.9 E.O.F. 954.2 E.O.F. 954.2 E.O.F. 957.9 956.9 E.O.F. 958.6 959.3959.6960.2962.7965.1967.5969.1964.7964.2961.7960.2959.2957.8963.3972.2 970.4 967.2 965.6 969.2967.2964.7961.8959.7959.5959.5958.4958.0957.6959.0957.5E.O.F. 956.26.5%7.9%7.1%6.9%7.4%7.8%7.9%4.9%7.5%8.0%6.9%6.5%8.3%7.1% 8.1% 7.0%5.3%6.1%7.7%6.3%5.6%6.3%6.0%5.9%5.2%5.2%6.4%7.5%9.0%7.5%6.1%6.6%6.4%6.2%6.3%6.4%6.4%7.4%7.9%5.6%8.2% 7.3% 8.8% 8.5% 7.4%7.1%DW0.7' DROP 0.7' DROP 1.4' DROP1.4' DROP 958 960960958 958 956956 956 960 958 962964966 968 9 7 0 954954 954 954 954 954 956 958 960 96 2 968970956950950948946944942952 950 948 946 944942 940938938940942944946948950952952 950 948 95 2 9 5 0 94 8 94 6 94 4 94 2 94 0 93 8 956 958 958 956 956 958 9 6 0 962964966968970 9729 5 4 9 5 2952952 954 956958956 95695896096296496 4 9 6 2 9 6 0 958956954954 9569589609629 6 2 9 6 0 958958956 9 5 8 9589609629649 6 6 968970 970 972950950 952 954 954 954 956 958 956 962964966 964 9 6 4 9629629589 5 0 952 954 956 958 958 96096 2 9729709 7 2 9 7 0 9649620.7' DROP 0.7' DROP 961.0 960.6 STREET, SIDEWALK & GRADING DETAILS TO BE COORDINATED WITH THE CITY AND ADJACENT LAND OWNER EBOX CBOX CBOX EBOXCBOX CBOX P-8957.4 SB-1960.1 SB-2955.7 SB-3952.1 SB-4958.3 SB-5966.3 SB-6963.8 SB-1951.0 SB-2962.9 SB-3955.3 SB-4961.8 SB-5961.7 SB-6962.5 EXISTING RETAINING WALLEXISTING RETAINING WALL952.2 952.2 952.2 952.2 952.2 952.2 953.0 953.0 953.0 953.3 954.0 958.5 960.5 961.8960.8958.8 956.3 953.7953.0953.0 953.0 950.5 950.5 951.5 953.0 955.0 956.4 957.4956.9 953.5952.5952.0953.0954.0953.5952.0950.5950.5 950.5950.5 950.5 957.3 958.8 962.0 963.5 966.0PRAIRIE WAY180TH STREET EASTMISSION TRAIL STREET ASTREET AE.O.F.952.2958.0 EX 6" SOL ID HDPE6" PERF. HDPE6" PERF. HDPE952.2 E.O.F. 949.5TOP BERM:951.0TOP BERM:951.0949.5 EX949.3 EX948.4 EX14 -0+530+001+002+003+004+005+006+006+610+001+002+003+004+005+006+00 7+008+009+0010+0011+0012+0012+22HP: 0+24.18Elev: 971.78LP: 4+01.54Elev: 963.80HP: 4+83.33Elev: 964.27LP: 5+91.41 Elev: 957.46LP: 8+54.89Elev: 955.71HP: 9+18.29Elev: 956.04LP: 10+04.89Elev: 955.18HP: 6+69.09 Elev: 957.87 959.8 0.7' DROP 1.4' DROP958.5DW 2.1' DROP 0.7' DROP 2.1' DROP 969.1 0.7' DROP 1.4' DROP 0.7' DROP 0.7' DROP 0.7' DROP 0.7' DROP DW970.0 1.4' DROP TP-1953.1 TP-2964.5 TP-3960.6 TP-4956.1 TP-5964.3 PROPOSED RETAINING WALL WITH RAIL EXISTING UTILITY BOX TO BE RELOCATED DATE____________ REG. NO._________ I HEREBY CERTIFY THAT THIS PLAN WAS PREPARED BY ME OR UNDER MY DIRECT SUPERVISION AND THAT I AM A DULY LICENSED ENGINEER UNDER THE LAWS OF THE STATE OF MINNESOTA. GRADING PLAN PRIOR LAKE MINNESOTA 12 19 CO PM 7/26/2018 1"=50' 16499.00 PRIOR LAKE, MINNESOTA 55372 17021 FISH POINT ROAD KEYLAND HOMES BUILDING SETBACKS FRONT = 25 FEET SIDE = 10 FEET REAR = 30 FEET LOW FLOOR = 2' ABOVE HWL LOW OPENING = 2' ABOVE EOF DENOTES LIMITED BASEMENT 1-3943.0 943.0GARAGE FLOOR ELEVATION PROPOSED LOT BLOCK PROPOSED GROUND ELEVATION *SE HOUSE TYPE LOWEST ALLOWABLE FLOOR ELEVATION 4.8%DRIVEWAY SLOPE 939.5 1 6-11-18 PM REVISED STORM SEWER, POND AND FILTRATION BENCH NOT FOR CONSTRUCTION PRIOR LAKE CITY PROJECT #DEV18-0000025 RECOMMEND: 1. SUMP PUMPS 2. GUTTERS AND DOWN SPOUTS WITH LONG SPLASH BLOCKS OR EXTENSIONS DIRECTED TO THE FRONT OR REAR YARD 2 9-10-18 PM REVISED GRADES Appendix B MnRAM Summary Reports Wetland Functional Assessment SummaryWetland NameMaintenance of Hydrologic RegimeFlood/ Stormwater/ AttenuationDownstreamWaterQuality Maintenance of WetlandWaterQualityShorelineProtectionHydrogeomorphologyWetland NameGround-WaterInteractionMaintenance of Characteristic Wildlife Habitat StructureMaintenance of Characteristic Fish HabitatAesthetics/Recreation/Education/ CulturalCommercial UsesWetlandRestorationPotentialWetland Sensitivity to Stormwaterand Urban Development Additional StormwaterTreatmentNeedsMaintenance of Characteristic Amphibian HabitatAdditional InformationCowardinClassificationWetland Name LocationVegetative Diversity/IntegrityPlantCommunityWetland Community SummaryCircular39 WetlandProportionIndividualCommunityRatingHighestWetlandRatingAverageWetlandRatingWeightedAverageWetlandRatingCommunityDenotes incomplete calculation data. High Moderate Moderate Moderate Not ApplicableExisting inlet from neighboring development; no outlet0.750.660.530.380.00Wetland 1RechargeModerate Not ApplicableLowNot ApplicableNot Applicable ModerateModerateNot Applicable0.440.000.250.000.000.100.380.00Wetland 1PEM1BType 2Fresh (Wet) Meadow1000.10.100.100.10LowLowLowWetland 1LowLowLow1000.100.100.10#Name?Page 1 of 1 Wetland Functional Assessment SummaryWetland NameMaintenance of Hydrologic RegimeFlood/ Stormwater/ AttenuationDownstreamWaterQuality Maintenance of WetlandWaterQualityShorelineProtectionHydrogeomorphologyWetland NameGround-WaterInteractionMaintenance of Characteristic Wildlife Habitat StructureMaintenance of Characteristic Fish HabitatAesthetics/Recreation/Education/ CulturalCommercial UsesWetlandRestorationPotentialWetland Sensitivity to Stormwaterand Urban Development Additional StormwaterTreatmentNeedsMaintenance of Characteristic Amphibian HabitatAdditional InformationCowardinClassificationWetland Name LocationVegetative Diversity/IntegrityPlantCommunityWetland Community SummaryCircular39 WetlandProportionIndividualCommunityRatingHighestWetlandRatingAverageWetlandRatingWeightedAverageWetlandRatingCommunityDenotes incomplete calculation data. Moderate High ModerateLow Not ApplicableDepressional/Isolated (no discernable inlets or outlets)0.650.770.610.260.00Wetland 2RechargeModerate Not ApplicableLowNot ApplicableNot Applicable ModerateLowNot Applicable0.350.000.250.000.000.100.260.00Wetland 2PEM1BType 2Fresh (Wet) Meadow1000.10.100.100.10LowLowLowWetland 2LowLowLow1000.100.100.10#Name?Page 1 of 1 Appendix C Historical Aerials Former extent of Wetland 2 before construction of Enclave of Cleary Lake development in 2006 Former drainage swale KEY LAND HOMES 1951 Aerial Photo APP C 200 0 200100 Feet ±Path: L:\7285\0002\mxd\App C Historical Conditions.mxd Date: 9/11/2018 Time: 3:31:24 PM User: WatME0697 1951 Aerial Photograph (Source: MHAPO) AUG 2018 Legend Project Area Delineated Wetlands Former extent of Wetland 2 before construction of Enclave of Cleary Lake development in 2006 Former drainage swale KEY LAND HOMES 1991 Aerial Photo APP C 200 0 200100 Feet ±Path: L:\7285\0002\mxd\App C Historical Conditions.mxd Date: 9/11/2018 Time: 3:32:46 PM User: WatME0697 1991 Aerial Photograph (Source: MnGEO) AUG 2018 Legend Project Area Delineated Wetlands Former extent of Wetland 2 before construction of Enclave of Cleary Lake development in 2006 Former drainage swale KEY LAND HOMES 1997 Aerial Photo APP C 200 0 200100 Feet ±Path: L:\7285\0002\mxd\App C Historical Conditions.mxd Date: 9/11/2018 Time: 3:32:19 PM User: WatME0697 1997 Aerial Photograph (Source:FSA) AUG 2018 Legend Project Area Delineated Wetlands Former extent of Wetland 2 before construction of Enclave of Cleary Lake development in 2006 Former drainage swale KEY LAND HOMES 2000 Aerial Photo APP C 200 0 200100 Feet ±Path: L:\7285\0002\mxd\App C Historical Conditions.mxd Date: 9/11/2018 Time: 3:33:25 PM User: WatME0697 2000 Aerial Photograph (Source: MnGEO) AUG 2018 Legend Project Area Delineated Wetlands Former extent of Wetland 2 before construction of Enclave of Cleary Lake development in 2006 Former drainage swale KEY LAND HOMES 2006 Aerial Photo APP C 200 0 200100 Feet ±Path: L:\7285\0002\mxd\App C Historical Conditions.mxd Date: 9/11/2018 Time: 3:34:19 PM User: WatME0697 2006 Aerial Photograph (Source: MnGEO) AUG 2018 Legend Project Area Delineated Wetlands Former extent of Wetland 2 before construction of Enclave of Cleary Lake development in 2006 Former drainage swale KEY LAND HOMES 2010 Aerial Photo APP C 200 0 200100 Feet ±Path: L:\7285\0002\mxd\App C Historical Conditions.mxd Date: 9/11/2018 Time: 3:35:05 PM User: WatME0697 2010 Aerial Photograph (Source: MnGEO) AUG 2018 Legend Project Area Delineated Wetlands Toll Free: 800-472-2232 Email: wenckmp@wenck.com Web: wenck.com S:\Water Resources\WCA\WCA Sites\Meadows of Cleary Lake\181203 City Council Materials\Meadows of Cleary Lake WCA Attach2.docx 540 GATEWAY BLVD | BURNSVILLE, MN | 55337 | 952.737.4660 | WSBENG.COM Memorandum To: Honorable Mayor Briggs and Prior Lake City Council Members From: Alison Harwood, WSB CC: Pete Young, City of Prior Lake Date: November 27, 2018 Re: Meadows of Clearly Lake Development – Wetland Replacement Plan (No. 12921) WSB Project No. 12921-000 Key Land Homes is proposing to develop approximately 20 acres in Prior Lake into a 48-lot, residential development. The proposed project will include site grading for residential development infrastructure, including roads, utilities, and building pads. Construction is scheduled to begin in 2018 and continue until development is fully built. The project proposes to impact 0.377 acres of wetland Project wetland impacts will be replaced via purchase of credits from wetland bank 1468, located in Le Sueur County, Watershed No. 33, Bank Service Area 9. No wetland credits are currently available in Scott County. Wetlands will be replaced at a 2:1 ratio, for a total replacement of 0.754 acre. The application was noticed to the Wetland Conservation Act Technical Evaluation Panel (TEP) on November 7, 2018. The TEP met to review the application on November 15, 2018. The TEP provided comments to the applicant regarding the avoidance and minimization measures presented in the application. The applicant provided responses to the comments on November 26, 2018. The TEP reviewed the responses and was ultimately supportive of the replacement plan. On behalf of the City of Prior Lake, Local Government Unit for the Wetland Conservation Act, I recommend that the City Council approves the wetland replacement plan for the Meadows at Clearly Lake development. As a condition of the approval, the applicant will be required to submit a fully-executed Withdrawal of Wetland Credits form to the LGU and BWSR, documenting the withdrawal of 0.754 acre of wetland credit from Bank No. 1468. A Notice of Decision is attached for review. BWSR Forms 7-1-10 Page 1 of 4 Minnesota Wetland Conservation Act Notice of Decision Local Government Unit (LGU) Prior Lake Address 4646 Dakota Street SE Prior Lake, MN 55372 1. PROJECT INFORMATION Applicant Name Key Land Homes c/o Gary Horkey or Rod Just 17021 Fish Point Road Prior Lake, MN 55372 phone: 952-440-9400 email: ghorkey@msn.com rod.just@keylandhomes.com Project Name Meadows of Clearly Lake Date of Application 10/3/2018 – Incomplete 10/22/2018 - Complete Application Number 12921-000 Attach site locator map. Type of Decision: Wetland Boundary or Type No-Loss Exemption Sequencing Replacement Plan Banking Plan Technical Evaluation Panel Findings and Recommendation (if any): Approve Approve with conditions Deny Summary (or attach): A TEP was held on November 15, 2018. The TEP had comments regarding the avoidance and minimization provided in the application. Comments were provided to the applicant on November 15, 2018. Responses were provided on November 26, 2018 and were determined to be satisfactory by the TEP. 2. LOCAL GOVERNMENT UNIT DECISION Date of Decision: December 3, 2018 Approved Approved with conditions (include below) Denied LGU Findings and Conclusions (attach additional sheets as necessary): Key Land Homes is proposing to develop approximately 20 acres located in Section 12, Township 114N, Range 22W in Prior Lake into a 48-lot, residential development. The proposed project will include site grading for residential development infrastructure, including roads, utilities, and building pads. Construction is scheduled to begin in 2018 and continue until the development is fully built. The project proposes to impact 0.377 acres of wetland. The TEP reviewed the project on November 15, 2018 and provided comments to the applicant regarding the avoidance and minimization presented in the application. The applicant provided responses on November 26, 2018. Comments were determined to be satisfactory. Replacement for the 0.377 acre of wetland impact will be via purchase of credits from wetland bank 1468, located in Le Sueur County. Wetlands will be replaced at a 2:1 ratio, for a total replacement of 0.754 acre. BWSR Forms 7-1-10 Page 2 of 4 For Replacement Plans using credits from the State Wetland Bank: Replacement Plan Approval Conditions. In addition to any conditions specified by the LGU, the approval of a Wetland Replacement Plan is conditional upon the following: Financial Assurance: For project-specific replacement that is not in-advance, a financial assurance specified by the LGU must be submitted to the LGU in accordance with MN Rule 8420.0522, Subp. 9 (List amount and type in LGU Findings). Deed Recording: For project-specific replacement, evidence must be provided to the LGU that the BWSR “Declaration of Restrictions and Covenants” and “Consent to Replacement Wetland” forms have been filed with the county recorder’s office in which the replacement wetland is located. Credit Withdrawal: For replacement consisting of wetland bank credits, confirmation that BWSR has withdrawn the credits from the state wetland bank as specified in the approved replacement plan. Wetlands may not be impacted until all applicable conditions have been met! LGU Authorized Signature: Signing and mailing of this completed form to the appropriate recipients in accordance with 8420.0255, Subp. 5 provides notice that a decision was made by the LGU under the Wetland Conservation Act as specified above. If additional details on the decision exist, they have been provided to the landowner and are available from the LGU upon request. Name Pete Young, PE Title Water Resources Engineer Signature Date 12/3/2018 Phone Number and E-mail 952.447.9831 pyoung@cityofpriorlake.com THIS DECISION ONLY APPLIES TO THE MINNESOTA WETLAND CONSERVATION ACT . Additional approvals or permits from local, state, and federal agencies may be required. Check with all appropriate authorities before commencing work in or near wetlands. Applicants proceed at their own risk if work authorized by this decision is started before the time period for appeal (30 days) has expired. If this decision is reversed or revised under appeal , the applicant may be responsible for restoring or replacing all wetland impacts. This decision is valid for three years from the date of decision unless a longer period is advised by the TEP and specified in this notice of decision. 3. APPEAL OF THIS DECISION Pursuant to MN Rule 8420.0905, any appeal of this decision can only be commenced by mailing a petition for appeal, including applicable fee, within thirty (30) calendar days of the date of the mailing of this Notice to the following as indicated: Check one: Appeal of an LGU staff decision. Send petition and $ fee (if applicable) to: City of Prior Lake 4646 Dakota Street SE Prior Lake, MN 55372 Appeal of LGU governing body decision. Send petition and $500 filing fee to: Executive Director Minnesota Board of Water and Soil Resources 520 Lafayette Road North St. Paul, MN 55155 Bank Account # 1468 Bank Service Area 9 County Le Sueur Credits Approved for Withdrawal (sq. ft. or nearest .01 acre) 0.754 acre BWSR Forms 7-1-10 Page 3 of 4 4. LIST OF ADDRESSEES SWCD TEP member: Troy Kuphal BWSR TEP member: Ben Carlson LGU TEP member (if different than LGU Contact): Alison Harwood, WSB & Associates, Inc. DNR TEP member: Becky Horton, Jennie Skancke DNR Regional Office (if different than DNR TEP member) WD or WMO (if applicable): Paul Nelson, Scott WMO Applicant and Landowner (if different) Gary Horkey & Rod Just, Keyland Homes Members of the public who requested notice: Meaghan Watson, Wenck Associates; Chris Ockwig, Probe Engineering Corps of Engineers Project Manager: BWSR Wetland Bank Coordinator (wetland bank plan decisions only) 5. MAILING INFORMATION ➢ For a list of BWSR TEP representatives: www.bwsr.state.mn.us/aboutbwsr/workareas/WCA_areas.pdf ➢ For a list of DNR TEP representatives: www.bwsr.state.mn.us/wetlands/wca/DNR_TEP_contacts.pdf ➢ Department of Natural Resources Regional Offices: NW Region: Reg. Env. Assess. Ecol. Div. Ecol. Resources 2115 Birchmont Beach Rd. NE Bemidji, MN 56601 NE Region: Reg. Env. Assess. Ecol. Div. Ecol. Resources 1201 E. Hwy. 2 Grand Rapids, MN 55744 Central Region: Reg. Env. Assess. Ecol. Div. Ecol. Resources 1200 Warner Road St. Paul, MN 55106 Southern Region: Reg. Env. Assess. Ecol. Div. Ecol. Resources 261 Hwy. 15 South New Ulm, MN 56073 For a map of DNR Administrative Regions, see: http://files.dnr.state.mn.us/aboutdnr/dnr_regions.pdf ➢ For a list of Corps of Project Managers: www.mvp.usace.army.mil/regulatory/default.asp?pageid=687 or send to: US Army Corps of Engineers St. Paul District, ATTN: OP-R 180 Fifth St. East, Suite 700 St. Paul, MN 55101-1678 ➢ For Wetland Bank Plan applications, also send a copy of the application to: Minnesota Board of Water and Soil Resources Wetland Bank Coordinator 520 Lafayette Road North St. Paul, MN 55155 6. ATTACHMENTS In addition to the site locator map, list any other attachments: Approved Impact Figure Technical Memo Wenck | Colorado | Georgia | Minnesota | North Dakota | Wyoming Toll Free 800-472-2232 Web wenck.com To: Alison Harwood and Pete Young, City of Prior Lake From: Meaghan Watson, Wenck Associates, Inc. Copy: Chris Ockwig, Probe Engineering; Gary Horkey, Key Land Homes Date: November 26, 2018 Subject: Meadows of Cleary Lake Response to TEP Comments from 11/15/2018 The following information is a response to comments received from the Meadows of Cleary Lake TEP which occurred November 15, 2018. The comments were as follows: 1. The TEP does not agree that the wetlands have been degraded to the point that they qualify for Sequencing Flexibility. As such, the alternative configuration design needs to be more fully described. 2. Provide a No Impact alternative – this is different from the No Build in that it should be an alternative that would allow development without impact to the wetland area. It appears that this could be accomplished by removing the 2 lots south of Mission Trail and reconfigure the stormwater pond to fit within the lobe of the wetland and then provide an overflow to maintain hydrology. If this is not feasible, document why. 3. The Alternative Configuration notes that the proposed wetland impacts are dictated by the existing access point and construction of Mission Trai l. Based on the review of the plans, it appears that the impacts are not from the roadway/access, but rather from fill for two housing pads and construction of the stormwater pond. As noted in comment #2, please provide additional justification as to why removal of these lots and reconfiguration of the ponding is not feasible. Item 1 – Design Considerations 1. The Ponding/filtration area shown on the plan is a required feature of the site to meet City, Scott WMO and MNPCA storm water requirements. The design layout of the development is largely dictated by the access points and stub streets that limit the interior road design. The connections to Mission Trail on the north, Prairie Way in the southwest and Mission Trail connection to 180th Street on the south are all required by the City as a condition of approval. Additionally, the 2 stub streets to the east are required by the City as a condition of approval. Internal street configuration limits flexibility for alternative configuration of design. Moving interior streets would not provide for an efficient lot layout given the constraints of the stub streets, and therefore the design layout and lot locations are largely dependent on this restriction. 2. The City and Scott WMO have a 25 ft “No Impact” Buffer requirement around the wetland as it scored low quality on the MnRAM. “No Impact” buffer requirement extends the no impact zone out to 25 ft beyond the wetland perimeter. This would further limit the area of developable upland in which to place the pond, which would create further challenges in lot layout for the project to be viable. City of Prior Lake Meadows of Cleary Lake Response to TEP Comments 2 V:\Technical\7285 Key Land Homes\0002 Meadows of Cleary Lake Impact Permitting\Response to TEP Comments 11-26-2018\Meadows of Cleary Lake Response to TEP Comments 11- 26-2018 FINAL.docx 3. The wetland has 2 lobes protruding to the south, both of which creep upslope of the main basin area. These two lobes make an avoidance design challenging to impossible without the loss of lots. As the MnRAM score for this wetland basin is low quality, there is no reasonable, economically achievable avoidance design that is a logical option given the low quality of the wetland basin. This is further discussed in Item 2. 4. Lowest allowable floor elevations of proposed houses are a minimum of 2 ft above the Pond HWL. Lowest allowable openings of proposed houses are 2 ft above emergency overflows. Item 2 - No Impact Analysis In a No Impact scenario, the pond/filtration area would be moved south of the wetland and extend south to Street A. To keep the hydrology to the wetland, the pond outlet would be built near the southerly tip of the easterly lobe. The pond outlet would have to be set at about 952’ in order to discharge into the wetland at this point and maintain wetland hydrology. This is 4 ft higher than the currently proposed pond outlet elevation of 948’. This higher pond outlet elevation requires higher storm sewer elevations, which in turn require higher street and rear yard grades which in turn require higher house elevations. This alternative results in cascading impacts throughout the site and a majority portion of the site would need to be raised requiring import of fill material. This wetland basin is dominated by invasive vegetation and scored out as low-quality in the MnRAM analysis. The practicality of avoiding this wetland, given its low quality, is not logical given the significant economic impact of avoidance. With a No-Build scenario, if the overall site components were not raised 4 ft to allow for the pond to drain into the existing basin, grading and development around it would severely constrain the wetland’s surface hydrology, further degrading it and possibly rendering it non-wetland, therefore resulting in an indirect impact. A swale would be graded in order to direct surface water to the westerly lobe of the wetland to maintain hydrology. The existing grade in this location of the no impact zone is about 956’ elevation. This would result in the rear yards of Lots 7 through 13 of Block 6 having to be raised about 8-10 feet (depending on the final design of swales and storm sewer). This in turn will require a berm along the west plat line adjacent to the existing houses of about the same height in order keep the project’s drainage contained and directed toward the westerly lobe of the wetland. The berm would use up the majority of back yard space, making the lots much less marketable and likely drawing significant opposition from existing adjacent homeowners. This alternative also raises serious economic concerns in light of wetland quality as previously discussed. The result of a no-impact scenario are as follows: 1. The loss of 7 lots, Lot 1 Block 7, and Lots 1 through 6 of Block 6. This would constitute a loss of 14.5% of the total lots being proposed which would no longer fulfill the project purpose or the residential development goals for this area. 2. The significant additional expenditure for importing soil to raise a significant portion of the site would also render the project purpose untenable. City of Prior Lake Meadows of Cleary Lake Response to TEP Comments 3 V:\Technical\7285 Key Land Homes\0002 Meadows of Cleary Lake Impact Permitting\Response to TEP Comments 11-26-2018\Meadows of Cleary Lake Response to TEP Comments 11- 26-2018 FINAL.docx 3. There would be minor offsets in that we would not have to construct sanitary sewer and water services for 6 of the 7 lots. However, these savings pale in comparison to the expenditures that would be required to perform the work described in Items 1 and 2. Item 3 - Configuration Justification (Minimization) To keep the hydrology to the wetland, the pond would have to outlet to the southernmost part of the eastern wetland lobe. The pond outlet would have to be set at about 952’ in order to discharge into the wetland at this point. This is 4 ft higher than the currently proposed pond outlet elevation of 948’. An alternative configuration that would remove Lots 1 and 2 would minimize direct wetland impacts but would result in similar issues as with the No-Impact scenario. The pond would have to be raised in order to maintain hydrology to the wetland, which would result in cascading impacts throughout the site, including raising street and yard grades. Otherwise, the eastern lobe of the wetland would be hydrologically constricted, as it outlets at its northern point across Trailhead Lane SE. Reconfiguring the site design by removing Lots 1 and 2 would still result in an indirect impact to the eastern lobe of the wetland, as it would remove surface hydrology. Overall, it is simply not feasible and prudent to avoid a relatively small impact to a degraded wetland. Such a plan does not fulfill the development needs of the area and it renders the project untenable. As stated in the initial submittal, it is anticipated that Scott County will require 60,000 to 70,000 acres of platted developable land to accommodate the anticipated population growth in the coming years. If this project is not completed at this site, whi ch is zoned for the proposed use, another project will eventually be proposed which is likely to have similar wetland impacts.