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location. This option is not feasible from a safety perspective since a retaining wall in a back yard would present a hazard to small children playing there, or to residents otherwise using this outdoor living space. Zero Impact Alternatives. As required under MN Rule 8420 Subp.3.C.(1), two alternatives are considered that avoid all wetland impacts to this site. 1. No -Build: In this alternative the area presently under cultivation would remain. The wetlands areas which receive sediment and fertilizer run-off would remain in their degraded state. The need for affordable single family housing in close proximity to the metro area would remain un-met. Therefore, the no -build alternative is rejected. 2. Alternate Locations: All wetland impacts to this site could be avoided by completing the project at an alternate location. The proposed project covers approximately 120 acres with 80 contiguous acres impacting 1 acre of wetland. The remaining 40 acres is native parkland. The proposed project falls within the 2020 MUSA line so that city water and sewer can be provided. Attached, please find two figures, one is the 2020 Hugo MUSA line and the other is the same overlain on the Fish & Wildlife National Wetland Inventory Map (NWI). These maps present the same 120-acre footprint in different locations. The NWI overlay is presented to provide an estimate of the possible wetland impact the proposed project would have in alternate locations. Alternate locations 1 through 3 are inside the MUSA at undeveloped locations. These locations would cause 30 to 70 acres of wetland impact and would not be feasible from either an economic or environmental perspective. A forth location is indicated a short distance east of the MUSA. While alternate location 4 may be suitable, due to its proximity to a road, this site would not serve the project purpose because the development would need individual wells and septic systems. Also, 25 acres of wetland impact would occur at alternate location 4. Therefore, the applicant has rejected all off -site alternatives and proposed to develop the site they have owned since 2003, primarily because it offers City services. Minimization. Both the CWA and the WCA require that all unavoidable impacts to aquatic resources be minimized to the greatest extent practicable. Discuss all features of the proposed project that have been modified to minimize the impacts to water resources (see MN Rules 8420.0520 Subp. 4): As mentioned above, the applicant has avoided and minimized wetland impacts where practicable. As depicted in the exhibits and wetland sequencing, wetland impacts in B, D/E and P have been minimized. Wetlands A,C,G,H,J,O,S,U, and X have been eliminated from impact. The applicant requests Sequencing Flexibility (MN R. 8420.0520 Subp. 7a.) The applicant requests sequencing flexibility for all wetland impacts with the exception of wetland L. As indicated in the attached MnRAM analysis report, impacted wetlands B. BB,D/E and I are degraded to the point where replacement would result in certain gain in function and public value. It should also be noted that the applicant would dedicate the eastern one- third of the site, which contains wetland classified as Preserve by MnRAM, to the City for use as their natural park and trail system. Minnesota Interagency Water Resource Application Form February 2014 Page 11 of 19