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Sequencing Flexibility for wetland L is not requested. Wetland L, is classified as Preserve in the MnRAM Management Classification Report, and Moderate to High in the Wetland Functional Assessment Summary. As stated in the Avoidance section, impact avoidance to wetland L, in the back yard of Lot 12, Block 11, along the east side of Street 3, could be achieved by installing a retaining wall at that 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. Therefore, the applicant has demonstrated avoidance and minimization for wetland L, but it would not be eligible for sequencing flexibility since L is a high quality wetland. Special Considerations (MN R.8420.0515) This section of the rules lists nine special considerations which must be considered in the review of replacement plans. Since the project will be constructed on an area that has historically been under cultivation which resulted in degraded adjoining wetlands, several of these considerations are not applicable. Since the applicant would dedicate the eastern one- third of the site, which contains high quality wetland, woods and meadow, special fish and wildlife resources (MN R. 8420.05156 Subp.4.) would remain intact. Engineering has been completed to maintain stormwater run- off at pre -development conditions, and provide pre-treatment, so that wetlands can maintain current hydrology budget. The groundwater study completed for this site found an impermeable clay layer 20 to 40 feet thick, which provides water quality protection to the underlying aquifer. The Army Corps of Engineers review of this application did not identify the need to examine for archaeological, historic, or cultural resource sites (MN R. 8420.05156 Subp.5). Consistency with other plans(MN R. 8420.05156 Subp.10.)was demonstrated in the April 23rd, 2018, TEP meeting where the City Planner was also present, and the engineer pointed out future street connections from the proposed project that would avoid wetland impact as Hugo continues to develop. The Oneka Place NHIS Data Review (MN R. 8420.05156 Subp.3.) completed by Westwood (Attached) found there are no records of rare features within the project boundary. Minnesota Interagency Water Resource Application Form February 2014 Page 12 of 19