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consultation with MBS staff confirmed that a continuation of the NPCs (MRn83 - Northern Mixed <br />Cattail Marsh and WMn82a - Willow - Dogwood Shrub Swamp) into the project area would be <br />considered appropriate based on DNR mapping standards. <br />NPCs with a Conservation Status Rank of S1 through S3, or wetlands within High or Outstanding MBS <br />Sites of Biodiversity Significance may qualify as Rare Natural Communities (RNC) under the Wetland <br />Conservation Act (WCA). Minnesota Rules, part 8420.0515, subpart 3, state that a wetland <br />replacement plan for activities that modify a RNC must be denied if the local government unit <br />determines proposed activities will permanently adversely affect the RNC. The project is proposing to <br />impact wetlands, which requires the preparation of a wetland replacement plan. Please refer to WCA <br />Technical Guidance on RNCs as the project moves forward, and contact DNR Regional Plant Ecologist, <br />Amanda Weise (651-259-5793; Amanda. Weise@state.mn.us) for further coordination on RNC <br />evaluation during the WCA process. <br />Response: No impacts to any NPCs are anticipated. Wilkinson Lake and its wetland fringes were avoided in the <br />design of the project. Any potential wetland impacts will be subject to review under the WCA permitting <br />process. Currently stormwater from the agricultural field drains into these wetlands with no treatment. The <br />proposed development will include stormwater treatment at a higher level to preserve the NPC's adjacent to <br />the site. <br />11. Page 21, Rare Features. Please refer to the previous comment. Current and historical (1991- present) <br />aerial imagery show no apparent differences in land use or vegetation between the Outstanding MBS <br />site closer to Wilkinson and the contiguous wetlands within the project area. They are all part of the <br />wetlands surrounding Wilkinson Lake and it is likely that the conditions and NPCs in the MBS Site <br />continue into these wetlands within the project area. "Outstanding" sites contain the best occurrences <br />of the rarest species, the most outstanding examples of the rarest native plant communities, and/or <br />the largest, most ecologically intact or functional landscapes. The condition of the wetlands on the <br />western side of the project is not known. <br />Response: No impacts to any NPCs are anticipated. Wilkinson Lake and its wetland fringes were avoided in the <br />design of the project. Any potential wetland impacts will be subject to review under the WCA permitting <br />process. Currently stormwater from the agricultural field drains into these wetlands with no treatment. The <br />proposed development will include stormwater treatment at a higher level to preserve the NPC's adjacent to <br />the site. <br />12. Page 21, Rare Features. This section does not represent the abundance of state threatened, <br />Blanding's turtles, in the area. There are two mapped element occurrences of the Blanding's Turtle <br />that overlap with the Project site and several other documented occurrences within a mile. Blanding's <br />Turtles may move up to or over a mile during the active season. They use wetlands, creeks, ponds, <br />and lakes to overwinter and use uplands during the active season for travel, feeding, and nesting. <br />Response: A Blanding's Turtle Avoidance Plan will be prepared prior to the any construction activities taking <br />place. <br />11 <br />