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MDEPARTMENT OF NATURAL RESOURCES Minnesota Department of Natural Resources Ecological and Water Resource 1200 Warner Road St. Paul, MN 55106 March 29, 2017 Brian Bear Administrator 14669 Fitzgerald Ave. N Hugo, MN 55038 Re: Adelaide Landing Residential Development EAW Dear Mr. Bear, Transmitted Electronically The Minnesota Department of Natural Resources (DNR) has reviewed the Environmental Assessment Worksheet (EAW) for the Adelaide Landing Residential Development. We offer the following comments for your consideration. A significant portion of this project area is within the mapped 100-year floodplain and development will need to meet local and state floodplain regulations. The EAW should provide a more detailed description of how elevations in the existing floodplain will be modified, what compensatory storage will be constructed and where it will be located, and how the project will alter flood flow (determined through hydraulic modeling). 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 on these points. 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), Blanding'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 Blanding'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 Blanding'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. The EAW references an incorrect ERDB number for the NHIS review letter that is included in Appendix C. For future reference, the correct number is 20160443. Appendix C includes an "Eagle Nest Assessment Summary" dated July 2016. This summary indicated that bald eagles were observed in the project vicinity, however no eagle nests were observed within the project boundary at the time of the survey. It is unclear if all tree clearing activities related to this project will occur at one time, or during multiple phases of the project (extending out to 2021). As such, the DNR recommends that trees be surveyed for eagle nests each year, prior to any tree cutting activities. Minnesota Department of Natural Resources • Ecological and Water Resources 1200 Warner Road, St. Paul, MN 55106