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Zero Impact Alternatives: As required under MN Rule 8420 Subp.3.C.(1), two alternatives are <br />considered that avoid all wetland impacts to this site. <br />1. No -Build: In this alternative the vacant lot zone for commercial development with existing city <br />services and infrastructure to accommodate that development, would remain. The need for affordable <br />single family housing in close proximity to the metro area would remain un-met. Therefore, the no -build <br />alternative is rejected. <br />2. Alternate Locations: All wetland impacts to this site could be avoided by completing the project at an <br />alternate location. The City has water, sewer and a vast network of city/county road that connect to I- <br />35E. This makes the commute (approximately 20 miles or less) to the Twin Cities metropolitan area a <br />more favorable opportunity for potential renters than Anoka or Chisago Counties. Outside the city limits <br />there would be viable property for sale. However, for a development this size the applicant needs city <br />sewer and water, plus the road infrastructure for commuters to the Twin Cities. In addition there are <br />few outlying areas zoned for this type of development. For these reasons, the applicant has rejected all <br />off -site alternatives and proposes to develop the site selected, primarily because it offers City services, <br />infrastructure and is zoned appropriately. <br />Minimization. Both the CWA and the WCA require that all unavoidable impacts to aquatic resources be minimized to the greatest <br />extent practicable. Discuss all features of the proposed project that have been modified to minimize the impacts to water <br />resources (see MN Rules 8420.0520 Subp. 4): <br />As mentioned above, the applicant has avoided and minimized wetland impacts where practicable. The <br />attached sequencing exhibit further details where minimization has been achieved. <br />First, by decreasing the size of the project from 57 living units and 65 outdoor parking stalls to 45 <br />units and 45 parking stalls, wetland impact (fill) was decreased from 0.42 to 0.32 acres, as depicted in <br />alternatives 1 and 2. <br />Second, by shifting the building and outdoor parking area southward, wetland impact was further <br />minimized to 0.30 acres (alternative 3). <br />Finally, outdoor parking was decreased to 43 stalls and the finished floor grade elevation was <br />decreased from 919' to 918.7'. These changes decreased the amount of fill material required around <br />the facility, further minimizing wetland impact to 0.18 acres (alternative 4— preferred alternative). <br />The applicant has demonstrated that the least damaging practicable alternative would be implemented to <br />have the minimal effects on the aquatic resource. <br />The applicant requests Sequencing Flexibility (MN R. 8420.0520 Subp. 7a.) <br />The applicant requests sequencing flexibility for wetland impacts D and F. As indicated in the attached <br />MnRAM analysis report, impacted wetlands D and F, located in the Areas East and West of the Conservation <br />Easement, are degraded to the point where replacement would result in certain gain in function and public <br />value. <br />Minnesota Interagency Water Resource Application Form February 2014 <br />Page 9 of 16 <br />