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Mr. Bryan Bear April 15, 2022 Page 6 G:\.Clients All\Hugo\Proposals\Northstar Bank\LETTER_HUGO_NorthstarBank_041522_Final.docx • Vegetation performance - is the vegetative community within the bank diverse, high quality, and composed of a majority of native species? This can be mitigated through proper planning and installation, as well as completing any prescribed corrective measures from the TEP during the monitoring period. • Water Levels- Impacts on floodplain and low floors Hugo City Ordinance Revision on Priority Siting The issue of priority siting for wetland replacement within the City has been discussed previously outside of the context of the Northstar Bank, but consideration of revising the Hugo City ordinance to include priority wetland replacement siting that is required to begin within the city will increase the rate at which credits may be purchased from the bank and ensure that wetland benefits and functions are retained within the city. Currently, under MN Rule 8420.0522 Subpart 7, applicants are required to consider wetland credits for purchase in the minor, then major, then same BSA, then statewide. A revision to the rule, which has not yet gone into effect, but is predicted to within the near future based on statutory changes would allow applicants to select credit within the same BSA; avoiding the need to consider the same minor watershed and major watershed. This could result in wetland benefits and functions described above being lost to the City of Hugo as BSA 7 stretches westward to Pope, Douglas, and Kandiyohi, and north to Aitkin County, far from any benefit to the City of Hugo. One potential positive is Rice Creek Watershed District’s rules are more restrictive than the state’s and require projects with the District to mitigate within the District making Hugo’s wetland bank more attractive to projects in RCWD. If the NorthStar bank is developed, under the existing rule, an applicant could purchase wetland credits from these far away locations rather than the Northstar Bank which provides direct ecological and financial benefit to the City. If the Northstar Bank is developed, it is highly recommended the City revise its wetl and ordinance to require applicants for wetland replacement plans using bank credits to follow the siting priority below: • Within the City of Hugo, • Within minor watershed • Within major Watershed, • within Washington or Chisago County • Within the BSA (7), • statewide Next steps Hydrology Monitoring (2022) The generation of credits for this bank site is predicated on restoring partially drained wetland s. To support this contention, we will need some data on site hydrology. To accomplish this, we propose to install a series of seven (7) monitoring wells utilizing water level data loggers to