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Minnesota Joint Application – Attachment C: Avoidance and Minimization 13620 Fenway Boulevard North – Hugo, Minnesota Carlson McCain, Inc. Page 6 incorporating the wetland into a 2-cell system was shown to not satisfy the storage requirements in the first place, this approach does not help. Wetland impacts could be avoided if the stormwater ponds were constructed elsewhere on the Property; however, based on the area needed for the training building, parking lot to accompany the workers, the wide footprint needed to use the transmission line/substation “real-life” scenario, and the existing building/training operations, there is no room elsewhere on the property to construct the pond. The existing building (constructed in 2013) did have stormwater management requirements which were provided as part of those projects. There is no additional capacity to provide stormwater management for the proposed project in these existing basins. In addition, it is likely that the City stormwater requirements have changed since those basins were constructed, so if there was capacity it likely doesn’t meet the current City standards. If a smaller site was selected, the substation and transmission lines may need to be constructed separately (i.e. not connected) and perhaps on different sites. This negates the comprehensive training/safety aspect of this development (one of the main goals for Xcel). Any alternative site would also likely not have the convenience of adjacent classrooms, restrooms, and storm shelters that the HTC site currently offers. Relocating any of the proposed facilities development to the southwest corner of the Property would interfere with the “school of dirt” and the “gas extinguishing pit” training areas, both currently located in the southwest corner of the site. By not completing the project Xcel would fail to realize the extensive goals and benefits described in the prior section. Minimization. Both the CWA and the WCA require that all unavoidable impacts to aquatic resources be minimized to the greatest extent practicable. Discuss all features of the proposed project that have been modified to minimize the impacts to water resources (see MN Rules 8420.0520 Subp. 4): The impacts to this wetland have been minimized to the greatest extent possible by designing the development in a way that the majority of the wetland will still remain as a natural feature (vegetated stormwater retention pond). While the vegetation quality may decrease, the basin will still provide water storage/infiltration/filtration benefits as a stormwater pond. In addition, the basin will still provide habitat for invertebrates, birds, and other wildlife.