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WCA/CWA Wetland Application <br />Gervais Hills <br />GES Project No. 2004.040 <br />June 16, 2004 <br />Page 3 <br />Total Wetland Avoidance Alternatives <br />Given the size of the parcel and the position of the wetland, a viable development <br />cannot occur on the site without impact to the wetland. Although it is possible to <br />avoid the wetland impact, it is not practicable or feasible for several reasons. <br />First, the quality of the wetland must be taken into account when considering the <br />practicality and feasibility of avoidance. The use of this wetland as a stormwater <br />conduit has apparently been the main factor in the wetland plant community <br />being dominated by reed canary grass and other invasives such as box elder. <br />The only native species which could be considered to be "dominant" is river <br />bulrush which is tolerant of changes to water quality and sedimentation. Native <br />species in the wetland appear to be on the decline while the more invasive <br />species are probably increasing their coverage. <br />When considering the practicality and feasibility of avoidance, it is also necessary <br />to consider the avoidance alternative's economic impact on the project. To avoid <br />the wetland, which has been demonstrably degraded, would result in the loss of <br />five of the proposed 12 residential units. Although it is understood that economic <br />arguments alone cannot be used to dismiss an avoidance alternative, decreasing <br />the buildable lots by 42 percent would render the project infeasible and is not <br />practicable when considering the wetland quality. <br />Much of the wetland impact is due to the creation of on -site wetland mitigation <br />basins which will also serve to manage and treat stormwater flowing to Gervais <br />Lake. Most of the water entering this site is not the result of the project but is <br />existing runoff from off -site. The mitigation plan will help to attenuate stormwater <br />flows and will provide water quality benefits for Gervais Lake. The <br />implementation of the plan will reduce the existing peak stormwater runoff rate <br />and thereby reduce flooding potential. <br />Impact Minimization <br />The proposed impact cannot be further minimized. Slopes from the proposed fill <br />area for the street and residential pads cannot be steepened without creating the <br />potential for erosion and the compromising of the stability of the street and <br />residential pads. <br />Rectification of Impact <br />No temporary wetland impacts are proposed which could be rectified after project <br />completion. <br />Reduction or Elimination of Impacts Over Time <br />A Storm Water Pollution Prevention Plan and a Grading, Drainage and Erosion <br />Control Plan have been developed by the project engineer which will reduce the <br />impacts to downstream waters through erosion control and water quality <br />treatment measures. <br />