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DEPARTMENT OF NATURAL RESOURCES Central Region Headquarters 1200 Warner Road Saint Paul, MN 55106 September 2, 2022 Rachel Juba, Community Development Director City of Hugo 14669 Fitzgerald Avenue North Hugo, MN 55038 Re: DNR Comments on the Preliminary Plat and PUD for Downtown Hugo, Parcel ID 20.031.21.24.0074, Hugo Dear Rachel Juba, Thank you for notifying the Department of Natural Resources (DNR) of the upcoming September 8, 2022 public hearing on the Preliminary Plat and Planned Unit Development(PUD) application for the Downtown Hugo project. I have evaluated this application in context of the City of Hugo's shoreland ordinance and DNR's permitting requirements. Shoreland Ordinance Standards Minnesota's shoreland management standards apply to all public waters in the state that are assigned a Shoreland Classification, including Egg Lake. Under Minn. Stat. 103F.221 and Minn. Rules 6120.3900, cities with shorelands in their jurisdiction are required to adopt and administer shoreland ordinances that substantially comply with the standards in the rules.The standards are designed to accommodate development around sensitive water bodies in a sustainable way —reducing impacts on water quality, protecting fish and wildlife habitat, and preserving the natural character of the water body. The submitted application proposes a commercial development on a 4.3-acre parcel riparian to Egg Lake. Egg Lake is a shallow, approximately 150-acre Public Water Basin with a shoreland classification of Recreational Development Lake. The PUD application requests several far-reaching deviations from key protection provisions in the City of Hugo's shoreland ordinance that apply to the shoreland district for Egg Lake: • Impervious Surface Standard—Shoreland impervious surface standards are established in statewide rules and administered through local ordinances to not only limit the rate and amount of runoff and pollutants entering public waters, but also to provide space for natural functions such as vegetation and wildlife habitat. Hugo Code of Ordinances, Sec. 90-137(2) states that"no more than 25%of a lot or parcel in the shoreland district may be covered by an impervious surface." However, as indicated in the Sheet C2.0, Overall Site Plan in the Civil Plans dated March 18, 2022, this proposal would cover 46% (83,004 square feet or 1.9 acres) of the project area with buildings and impermeable pavement and another 38% (68,694 square feet or 1.6 acres) with pervious pavement, covering 84%(151,698 square feet) of the parcel with constructed hard surfaces while leaving just 16% (28,896 square feet or 0.7 acres) with a natural vegetated surface. • Structure Setback Standard—Structure setback standards from the ordinary high water level are established in statewide rules and administered through local ordinances to preserve a natural shoreline,to ensure an