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<br />Water Appropriation Permitting Requirements <br />Sheet L1.0, Overall Landscape Plan in the Civil Plans shows an irrigation pump inlet pipe in Egg Lake for landscape <br />irrigation. A DNR Water Appropriation Permit is required to take water from a lake, wetland, stream, or well to irrigate <br />landscaping if the amount of water exceeds 10,000 gallons per day, or one million gallons per year. <br />DNR Recommendations <br />Unless substantial changes are made to the submitted Preliminary Plat and PUD application to align with the city’s <br />shoreland ordinance standards, DNR strongly recommends denial of this application. <br />While DNR finds this particular development application highly problematic, we understand the city’s interest in <br />downtown development near Egg Lake. We have on multiple occasions encouraged city staff to develop a revised <br />shoreland ordinance for DNR approval that includes alternate standards for the downtown central business district. We <br />previously communicated to city staff as far back as February 2017 that DNR can accommodate alternate standards in <br />shoreland through the implementation flexibility process in Minn. R. 6120.2800, subp. 3. The implementation flexibility <br />process is the appropriate process under state law for communities to negotiate deviations to statewide minimum <br />shoreland development standards. <br />Sincerely, <br /> <br />Dan Scollan <br />East Metro Area Hydrologist <br /> <br />cc: Dan Petrik, DNR Lake & River Shoreland Program Manager <br /> John (Jack) Gleason, DNR South District Hydrologist Supervisor