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Off -Site Alternatives. An off -site alternatives analysis is not required for all permit applications. If you know that your proposal will require an individual permit (standard permit or letter of permission) from the U.S. Army Corps of Engineers, you may be required to provide an off -site alternatives analysis. The alternatives analysis is not required for a complete application but must be provided during the review process in order for the Corps to complete the evaluation of your application and reach a final decision. Applicants with questions about when an off -site alternatives analysis is required should contact their Corps Project Manager. Off -site alternatives have been reviewed by the applicant. Most of the City of Hugo has shown vast development in the past 15 years. In every direction within the City Limits there has been development. Outside the city limits there would be viable property for sale. However, for a development this size the applicant needs city sewer and water, plus the road infrastructure for commuters to the Twin Cities. The MUSA line only extends to those limits. It would not serve the project purpose to go outside the city limits because the development would need wells and septic systems, which is not feasible for a large multi -family complex. Areas outside the MUSA line are not zoned for this type of development. Therefore, the applicant has rejected all off -site alternatives and proposed to develop this which is zoned for this type of commercial development, primarily because it offers City services and infrastructure. Special Considerations (Minn R. 0515) Special considerations, when identified as being applicable to an impact site or a replacement site, must be considered by the applicant before submitting a replacement plan and by the local government unit in the review of replacement plans. Special considerations include: 1) Endangered and threatened species. The replacement plan does not involve taking species listed as endangered or threatened in Minn. R. parts 6134.0200 to 6134.0400. 2) Rare natural communities. The replacement plan does not involve the modification of a rare natural community. 3) Special fish and wildlife resources. The replacement plan does not have a significant adverse effect on a special or locally significant fish and wildlife resource. 4) Archaeological, historic, or cultural resource sites. The replacement plan does not involve the modification of known archaeological, historical, or cultural resource sites on or eligible for the National Register of Historic Places, as designated by the state historic preservation officer. 5) Groundwater sensitivity. The replacement plan would not have a significant adverse effect on groundwater quality. 6) Sensitive surface waters. The replacement plan would not have a significant adverse effect on the water quality of outstanding resource value waters listed in part Minn. R. 7050.0335 or on trout waters designated by the commissioner 7) Education or research use. The replacement plan would not cause impacts to wetlands known to be used for educational or research purposes. Minnesota Interagency Water Resource Application Form February 2014 Page 10 of 16