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A MN Joint application requesting a no -loss for an area located within parcel number 163-2903121340001 was received on September 26, 2016 and considered complete on October 26, 2016. A subsequent Notice of Application was issued on November 7, 2016. The application (submitted by Westwood Professional Services) dated September 26, 2016 requested a no - loss for an area on the above described parcel that was delineated as a wetland in a wetland delineation report submitted by Kjolhaug Environmental Services dated June 25, 2015. This area is identified as wetland 4 in the 2015 Kjolhaug report and referred to as such for the remainder of this document. Multiple sources were reviewed to make the determination provided in this document. These include Hugo LGU correspondence from 2012 that includes figures from two 2005 wetland delineations, the 2015 Kjolhaug wetland delineation report, and historical imagery review, antecedent precipitation data, and wetland determination field data forms submitted by Westwood Professional Services as part of the September 26, 2016 no -loss application. The first of two wetland boundary maps created by Westwood Professional Services, dated August 4, 2005 and titled exhibit 5 does not include wetland 4, but does show boundaries for other wetlands on site similar to the boundaries identified in the 2015 Kjolhaug report. The second wetland boundary map created by Bonestroo, Rosene, Anderlik, and Associates, dated 1 /2006 and titled Figure 1 does include wetland 4. Based on Hugo LGU correspondence included with the first map, it appears as though this was the approved wetland boundary; although a copy of the decision was not located. The 2015 Kjolhaug wetland delineation report did not include wetland 4 initially but was added after a May 14, 2015 field review. The report describes the soils in the area of wetland 4 as hydric and the boundary for wetland 4 was identified by a slight change in topography and the absence of primary hydrology indicators (water marks). Antecedent precipitation data shows that April was a normal precipitation month, while May was wetter than normal with 2.14 inches of rain at the site between May 1, 2015 and May 14, 2015. No field sampling (hydrology, vegetation, or soils) data forms were completed for wetland 4 as part of the Kjolhaug report. As part of the no -loss application, Westwood Professional Services included a historical imagery review. The review included images from years between 1991 and 2016 with some years represented by more than one photograph. Of the 20 images reviewed, nine occurred within normal precipitation years. Of these nine, four or 44% of the images showed a wetland signature (soil wetness or crop stress). Overall 35% of the images contained wetland signatures. Since this area was not identified on the NWI or other wetland map, but did have hydric soils and between 30 and 50% of the images contained a wetland signature, field verification was required. Field sampling in wetland 4 confirmed primary hydric soils indicators (depleted matrix and depleted below dark surface) but showed the area lacked primary hydrology indicators and had only one secondary indicator (geomorphic position). Vegetation was significantly disturbed since wetland 4 occurs in a formerly plowed agricultural field. Furthermore, no water was found within 24 inches of the surface. BWSR guidance suggests that in situations where the area in question is not identified on an NWI or other wetland map, but has hydric soils and a wetland signature is present in 30-50% of the images used for review, the site must have other hydrology indicators present to be considered wetland. Field sampling by Westwood showed no primary and only one secondary hydrology indicator present during wetter than normal conditions. Based on a review of the supporting documents described above, the application for no -loss submitted by Westwood Professional Services on September 26, 2016, is approved. For Replacement Plans using credits from the State Wetland Bank: Bank Account # Bank Service Area County Credits Approved for Withdrawal (sq. ft. or nearest .01 acre) 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: BWSR Forms 11-25-09 Page 2 of