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April 12, 2017 Page 3 proposed conditions. Adjacent properties will not be affected. The City will review this as part of the development plan review process. Comment 2: The response provided for Item 11, related to Surface Waters (page 22) does not describe anticipated physical effects or alterations to wetland features, detailed impacts to the host watershed, or measures to avoid and minimize wetland impacts. This section should provide detailed information or these points. Response: At the time the EAW was prepared, specific details on the wetland replacement plan were not finalized. A wetland replacement plan application that meets the requirements of the Minnesota Wetland Conservation Act and Section 404 of the Clean Water Act is currently under review by the City of Hugo, the U.S. Army Corps of Engineers, the Washington Conservation District, the Board of Water and Soil Resources, the Rice Creek Watershed District, and Department of Natural Resources. Full sequencing to address avoidance and minimization is addressed in the wetland permitting application as required. The wetland application currently identifies 1.32 acres of impact in seven separate areas, primarily to accommodate proposed road crossings. Wetland replacement is proposed through the use of existing wetland credits and from wetland bank account #1542 in Stearns County at a 2:1 ratio. The wetland impact and mitigation will be addressed through the permitting process. Comment 3: Pertaining to Item 13, Fish, wildlife, plant communities, and sensitive ecological resources, Section D, "mitigation measures" is missing this information is a required part of the EAW. As noted on page 26 of the EAW and in our NHIS review letter (Appendix C of the EAW), Blarding's turtles have been documented in the vicinity of the project and may be encountered within the project area. The DNR's NHIS review letter also noted that the project site is located within an area of statewide importance for Blarding's turtles. Our letter included several recommendations to avoid or minimize disturbance to this state -listed threatened species as well as a Fact Sheet (Appendix C) with guidance that the proposer follow both lists of recommendations to reduce the potential for incidental takings during construction activities and engineering considerations for roads, utilities, and landscaping. Examples of recommendations to reduce potential impacts include using wildlife friendly erosion control, curb design (if in use), avoiding impacts to wetlands, and vegetated buffers. The EAW did not identify how the Blandng's turtle may be affected by the project in section C and did not describe how impacts were considered in construction and planning activities and measures that would be taken to avoid or minimize disturbance (section D). Please provide this information. Response: The city and project proposer are sensitive to the fact that state -listed (Threatened) Blanding's turtles could potentially be found near the project area, and are therefore taking actions to avoid impacts to the species during and after project construction. The project proposer has largely designed the project with surmountable curb and gutter, and will use Minnesota Department of Transportation Curb and Gutter Design No. S524, or similar, where surmountable curb and gutter is specified. Approximately 98% of the wetlands on the site are being completely avoided, with impacts minimized to areas needed primarily for road crossings. Larger and higher quality wetlands that would most likely be used by Blanding's turtles have been avoided. K:\03288-040\Admin\Dots\EAW\EAW Responses to Comments 041217.docx