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deviation. Additionally, this project does not achieve the spirit or the policy criteria in either the city’s PUD standards or <br />the City of Hugo Downtown Plan & Design Guidelines, an element of the city’s comprehensive plan. <br />The DNR has offered to work with the city over the years, going back to February 2017, to amend its shoreland <br />ordinance with implementation flexibility through the procedures in Minn. R. 6120.2800. That process requires <br />discussions to identify specific flexibility needs in return for higher or more protective standards elsewhere. <br />Unfortunately, the city did not pursue these offers and the Planning Commission has decided to approve a project with <br />significant impacts to Egg Lake- directly rejecting its own environmental goals and policies. Even if the city had pursued <br />these offers, no flexibility provided through the shoreland rules would ever allow for development as currently proposed <br />for the downtown. For these reasons, the DNR respectfully recommends denial of this preliminary plat/PUD <br />development and request the Mayor and Council leadership also recommend denial. <br />Sincerely, <br /> <br />Dan Lais <br />Central Region Manager <br /> <br />cc: Rachel Juba, Community Development Director <br />Dan Scollan, DNR East Metro Area Hydrologist <br /> John (Jack) Gleason, DNR South District Hydrologist Supervisor <br /> Jenny Shillcox, DNR Land Use Unit Supervisor <br />