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<br />G:\.Clients All\Hugo\Proposals\North Star Wetland Bank\Prospectus\PROPOSAL_North Star Wetland Bank Prospectus - <br />052323.docx 701 XENIA AVENUE S | SUITE 300 | MINNEAPOLIS, MN | 55416 | 763.541.4800 | WSBENG.COM May 23, 2023 <br /> <br /> <br />Shayla Denaway <br />City of Hugo <br />14669 Fitzgerald Ave N <br />Hugo, MN 55038 <br /> <br />Re: Proposal to Develop North Star Wetland Bank Prospectus <br /> <br />Dear Shayla Denaway: <br /> <br />WSB is providing this proposal to develop a prospectus (concept plan) for the North Star <br />Wetland Bank based on the previously submitted draft prospectus completed in May <br />2023 and reviewed by the Technical Evaluation Panel (TEP) and Interagency Review <br />Team (IRT). <br /> <br />The IRT provided the following essential comments on the draft prospectus. Below each <br />comment is the site investigation necessary to address these: <br /> <br />1. Comment: It is possible that broader regional issues, beyond the sponsor’s <br />control, are affecting water levels on this site. Looking at well data in Attachment <br />D the sponsor needs to consider how blocking the relatively shallow ditches on <br />this site is expected to restore the historical and natural hydrology regime. Many <br />wells are far beyond the expected drainage effect of the relatively shallow <br />ditches, yet they show a water table much lower than would be expected. The <br />historical hydrology regime would likely have a water table within 12 inches of the <br />surface well into the growing season if not throughout the growing season. If <br />regional factors beyond the sponsor’s control are affecting site hydrology and <br />hydrology performance standards cannot be achieved then wetland bank credits <br />cannot be released, regardless of projections in the Mitigation Plan. The sponsor <br />is assuming that regional issues beyond their control are not a prevailing factor <br />and this site’s shallow ditches are having a significant drainage effect several <br />hundred feet away. <br /> <br />Action: Discussion during the TEP meeting on April 28, 2023 with the city water <br />resources engineers indicated that the sub-watershed provides adequate <br />amounts of water to the site. It was noted that the 2022 growing season was dry <br />and well data may not be representative of the site under normal conditions as <br />well. During a site visit on May 25, 2023, we saw surface water around 6-12 <br />inches in all of the ditches on site. Monitoring wells have been installed for the <br />2023 growing season and we will continue monitoring to get additional data on <br />the subsurface water level. <br /> <br />