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BWSR NOD Form – November 12, 2019 2 Expansion of the existing Xcel Energy HTC is required to improve training for gas, electrical, and nuclear operators and improve in-processing for planned nuclear plant maintenance outages. The proposed design meets specific requirements to increase training effectiveness, including an outdoor transmission line and substation training are and indoor 2-story building to support in-processing for nuclear plant maintenance outages. Sequencing Multiple considerations were made by the applicant to address sequencing requirements. As discussed, the purpose of the project is to improve training for gas, electrical, and nuclear operators and improve in-processing for planned nuclear plant maintenance outages. Therefore, the no-build option was rejected even though this option would have resulted in no wetland impacts. Various alternatives were reviewed to avoid wetland impacts. The first was to adding on to the existing building. This would avoid all wetland impacts, but the existing building’s systems were not designed to handle and expansion and made this alternative cost-prohibitive and was therefore rejected. The second alternative that would avoid wetland impacts was to design a 2-cell system for stormwater management, of which the first cell would incorporate pre-treatment and the second cell (wetland) would be for volume control/storage. However, given the elevation of the wetland and the required finished floor elevation of the building, there would be little to no water flow into the wetland, preventing it’s use for stormwater management. This would not meet City runoff requirements. Also, this alternative would also reduce or eliminate the wetland’s hydrology. Because of those reasons, this option was rejected. Moving the stormwater pond that will ultimately impact the wetland to another location on the property was also evaluated but based on the area needed for the training building, parking lot, and transmission/sub- station training area there is no other room on the property available. Utilizing a different or smaller property for the facilities would also avoid wetland impacts, but negates the comprehensive training/safety aspect of the development and was therefore rejected. The preferred alternative locates the new building and associated parking lot in the northeast corner of the parcel. The transmission line and substation training facilities are located throughout the central and northwest portions of the site. A stormwater management pond is proposed immediately west of the new building and parking area to provide stormwater management for the new impervious. Replacement The chosen alternative results in 0.39 acres of impact to Type 2 wetland (Wetland 1). A replacement ratio of 2:1 is required. To meet this, the applicant is proposing to replace these impacts using 0.78 acres of credit from Bank #1722. Bank #1722 is located within the same major watershed (Mississippi River-Twin Cities) as the impacted wetland. No banking credits are available in the same minor watershed as the impacted wetland. Special Considerations The applicant has provided a thorough review of all of the special considerations identified in MN Rule 8420.0515. These include: • Endangered and threatened species • Rare natural communities • Special fish and wildlife resources • Archeological, historic, and cultural resources • Groundwater sensitivity • Sensitive surface waters