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Sequencing MN Rule 8420.0520 lists specific sequencing requirements. As part of the applicant's sequencing process ten (10) alternatives were considered as part of project planning. Five (5) of these alternatives resulted in no wetland impacts to the site. The first was the no -build option. This alternative was rejected since its does not meet the project purpose and does not meet the physical, economic, or demographic requirements of the project. Alternatives 2-5 involved an alternative location search. Four (4) alternate locations were considered for development to meet the project purpose. The search criteria included inclusion in the Metropolitan Urban Service Area (MUSA), existing access road connections, a large (-80-acre footprint), minimal wetlands, and be located within Hugo. Alternative sites 1-4 were rejected since they did not meet the search criteria or resulted in increased wetland impacts. Minimization efforts involved five (5) alternative site designs. Alterations of the site included moving roadways, removing and reconfiguring lots, and adding retaining walls. Impacts were reduced from 2.86 acres to 0.91 with the current design. Wetland Replacement The applicant's proposed alternative to develop the site will result in 0.91 acres of permanent impact to eight (8) type 2 wetlands. These basins include wetlands B, BB, D, E, F, I, L, and P. MN Rule 8420.0522 requires that wetland impacts be replaced at a 2.5:1 ratio. The applicant has requested the ratio be reduced by 0.5:1 since replacement for the impacted wetlands will be withdrawn from an approved wetland bank site within the same major watershed (#20-Mississippi River -Twin Cities). The resulting replacement ratio is 2:1. The applicant is proposing to purchase 1.82 acres of type 3 and 4 wetland credit from wetland bank #1649. BWSR siting requirements for wetland replacement require applicants follow the priority order of using credits within in the same minor watershed, the same major watershed, the same bank service area (BSA), and in another BSA. There are no approved wetland credits within the Hardwood Creek minor watershed, therefore the applicant is proposing to use credits from wetland bank 1649 which is in the same major watershed (#20-Mississippi River -Twin Cities). The application includes a purchase agreement for 1.82 acres of wetland credits from wetland bank 1649. Special Considerations The applicant has addressed MN Rule 8420.0515 subps. 1-10. The development and resulting wetland impacts will not have an adverse impact on rare natural communities, endangered or threatened species, archeological sites, groundwater, sensitive surface waters, nor does the site support educational or research uses, or contain a waste disposal site and is consistent with other plans. BwsR Forms 11-25-09 Page 3 of 6