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Mr. Bryan Bear <br />April 15, 2022 <br />Page 3 <br />G:\.Clients All\Hugo\Proposals\Northstar <br />Bank\LETTER_HUGO_NorthstarBank_041522_Final.docx <br />the bank area in Figure 2 is 9,772 feet. Using an average buffer width of 30 feet, the total area in <br />buffer would be 6.73 acres. 25% of this is 1.68 acres eligible for credit; making the total potential <br />credit area 51.68 acres. <br /> <br />Activities required to accomplish this would most likely be filling old drainage ditches, breaking <br />drain tile (if it exists), installing gate valves to control hydrology to meet performance standards <br />and complete management activities, the work will involve removals of any non-native and/or <br />invasive species, use of mechanical equipment such as mowers, targeted herbicide treatments, if <br />necessary, and the use of prescribed burns to bring back the natural functions and values along <br />with a more diverse vegetation population to the wetland ecosystem. <br /> <br />Wetland Banking Process <br /> <br />The wetland banking process includes multiple steps with various agencies. To increase the <br />maximum value, the bank should be Wetland Conservation Act (WCA) and US Army Corps <br />(USACOE) approved. This would result in two (2) separate yet coordinated permit processes. <br /> <br />The WCA process involves: <br /> <br />• Draft Prospectus <br />• Prospectus <br />• Mitigation (full) plan <br />• Legal boundary survey <br />• Title and easement recording <br />• Project Construction <br />• Project Certification <br />• Project Monitoring <br />• Application to deposit credits <br /> <br />This process will most likely take a full year or more to complete. <br /> <br />In addition to the WCA process, the US Army Corps, under section 404 of the Clean Water Act, <br />will assemble an Interagency Review Team (IRT) to review the application and, if applicable, <br />approve the bank under a Mitigation Banking Instrument (MBI). This process should run <br />concurrent with WCA and may take over 12 months to complete. <br /> <br />Benefits <br /> <br />Multiple benefits may be realized through the development of a wetland bank for the City of Hugo, <br />measured in terms of financial, ecological, and public perception. <br /> <br />The potential bank described above falls within the minor watershed of Clearwater Creek, major <br />watershed of Mississippi River-Twin Cities, and bank service area (BSA) 7. Using data from <br />BWSR, the average cost of a full credit for BSA 7 in 2019 was $81,558.09. If we use the number <br />of potential credits to be generated identified above (51.68), the total potenti al revenue from the <br />sale of credits at 2019 prices would be $4,214,922. These credits could be sold to outside <br />entities, sold to BWSR as part of the local road replacement program, or retained for City projects <br />where credit is needed. <br /> <br />In 2021, the City of Hugo was required to purchase 0.63 wetland credits from the City of Blaine at <br />a cost of ~$80,000. <br />