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7. Page 16, Stormwater. The DNR recommends that stormwater be used for landscape irrigation. <br />The re -use of stormwater for irrigation will reduce the volume of stormwater and stormwater <br />pollution flowing downstream of the site. In addition, the use of stormwater for irrigating <br />landscaping will conserve valuable groundwater. <br />8. Page 16, Stormwater. The increase in impervious surfaces will also increase the amount of road <br />salt used in the project area. Chloride released into groundwater as well as local lakes and <br />streams does not break down, and instead accumulates in the environment, potentially <br />reaching levels that are toxic to aquatic wildlife and plants. Consider promoting local business <br />and city participation in the Smart Salting Training offered through the Minnesota Pollution <br />Control Agency. There are a variety of classes available for road applicators, sidewalk <br />applicators, and property managers. More information and resources can be found at this <br />website. Many winter maintenance staff who have attended the Smart Salting training — both <br />from cities and counties and from private companies — have used their knowledge to reduce <br />salt use and save money for their organizations. <br />We also encourage cities and counties to consider how they may participate in the Statewide <br />Chloride Management Plan and provide public outreach to reduce the overuse of chloride. Here <br />are some educational resources for residents as well as a sample ordinance regarding chloride <br />use. <br />9. Page 16, Stormwater. Large stormwater ponds are proposed to be located directed adjacent to <br />Wilkinson Lake, which is a high -quality natural resource. Stormwater directed towards this <br />natural area could alter the natural hydrology, contribute to sediment and erosion, or introduce <br />nutrients and other contaminants that could degrade this natural area. We encourage the <br />development to give sufficient buffer to the Outstanding MBS Site, and to ensure robust <br />Stormwater treatment to protect Wilkinson Lake. The project area is also in a High Potential <br />Zone for the federally -endangered, rusty patched bumble bee. Therefore, we encourage the <br />development to use weed -free, native seed mixes in landscaping and stormwater features to <br />the greatest extent possible in order to provide pollinator and wildlife habitat. <br />10. Page 18, Wetlands. Please note that the MBS Site of Outstanding Biodiversity Significance and <br />the associated two Native Plant Communities (NPC) mapped adjacent to the project area more <br />than likely extend across the hard line that makes up the northern border of the NPCs. The <br />straight line of the northern border is an arbitrary stopping point of a survey site based on the <br />change from Ramsey to Anoka County and does not represent a change in plant community. <br />Aerial imagery, historic imagery, and LiDAR support the extension of the NPCs into the project <br />area (see image below), and a consultation with MBS staff confirmed that a continuation of the <br />NPCs (MRn83 — Northern Mixed Cattail Marsh and WMn82a — Willow — Dogwood Shrub <br />Swamp) into the project area would be considered appropriate based on DNR mapping <br />standards. <br />NPCs with a Conservation Status Rank of S1 through S3, or wetlands within High or Outstanding <br />MBS Sites of Biodiversity Significance may qualify as Rare Natural Communities (RNC) under the <br />Wetland Conservation Act (WCA). Minnesota Rules, part 8420.0515, subpart 3, state that a <br />wetland replacement plan for activities that modify a RNC must be denied if the local <br />government unit determines proposed activities will permanently adversely affect the RNC. The <br />