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April 12, 2017 <br />Page 5 <br />The City of Hugo is committed to reducing its aquifer demand, and has implemented several <br />water conservation efforts since the adoption of the 2030 Comprehensive Plan Of note, the City <br />has implemented stormwater irrigation projects that directly reduce maximum day demands, <br />thereby delaying the need for additional municipal wells. <br />3. Minnesota Pollution Control Agency (MPCA) <br />Comment 1: <br />Permits and Approvals (Item S) <br />This section indicates that a Clean Water Act (CWA) Section 404 Permit from the U.S. Army Corps of <br />Engineers (USACE) for project related wetland impacts may be necessary. Please be aware that if a <br />USACE Section 404 Individual Permit is required for any project activity, then an MPCA CWA Section 401 <br />Water Quality Certification or waiver must also be obtained as part of the permitting process. The <br />Section 401 Water Quality Certification ensures that the activity will comply with the state water quality <br />standards. Any conditions required within the MPCA 401 Certificate are then incorporated into the <br />USACE 404 Permit. You can find additional information about the MPCA's 401 Certification process at <br />www.pca.state.mn.us/waterl401.html. For further information about the 401 Water Quality <br />Certification process, please contact Jim Brist at 651-757-2245 or Bill Wilde at 651-757-2825. <br />Response: <br />Noted for the record. All required permits regarding wetlands and water quality protection will <br />be acquired prior to project construction. <br />4. Minnesota State Historic Preservation Office (SHPO) <br />Comment 1: <br />Due to tnC- nature and location of the proposed projeo, we rem mmend that a Phase I archaeological survey <br />be completed The survey +nim meet the requirements of the Secietary of the Interior's Standards for <br />ldenti ication and Evaluation, .and Should include an evaluatlan of National Register eligibility for any <br />propc-rties that are identified. For a list of consuftanls who have expressed an interest in undeftaking such <br />5i.arwe , please visit the wabslte preservatiorKfirectory.rnnhsorg. and select °Archaeolcgjist In the '"Seaircch <br />by Spetialties" box. <br />We will reconsider the need for survey if the project .area can be dkKumented as previously survey Dr <br />disturbed. Any previous survey work must meet contemporary standards. Note' plowed areas and right -ref= <br />way are not automatically considered disturbed. Archaeological sites can remain intact b8neath the plow zone <br />and in undisturbed portions of the right -of -Tway. <br />Please note that this comment letter does not address the requirements of Section 106 of the National <br />Historic Pmservation Act of 1966 and �6CFRSW, pr(Kedurw of the Advisco Councli on H Istorie Preserwatiion <br />far the protettlon of histok properties, If this project is considered for federal assistance, or requires a <br />federal license or permit, it should be wbmitted to our afke by the responsible federal agency - <br />Response: <br />The project proposer has coordinated with the US Corps of Engineers regarding the need for <br />additional cultural or archaeological survey as the lead federal agency. The US Corps has <br />indicated that no additional work is needed. The City will take the SHPO comment under <br />advisement. <br />K:\03288-040\Admin\Dots\EAW\EAW Responses to Comments 041217.docx <br />