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HomeMy WebLinkAboutMatter Public InputHAND DELIVERED 6649 Inskip Avenue South Cottage Grove, MN 55016 February 21, 2024 City of Cottage Grove Mayor and Council Members Tamara Anderson, City Clerk 12800 Ravine Parkway South Cottage Grove, MN 55016 Dear Mayor and Council Members: Subject: City of Cottage Grove City Council Meeting, February 21, 2024 - Regular Agenda Item 11C. Preliminary Plat and Planned Unit Development - Mississippi Landing I oppose the proposed Mississippi Landing 377 unit residential development. Please refer to my Open Forum comments. In addition, I have the following concerns regarding the most recent proposal: • This developer and the builders should be held to a higher standard because of the proximity of the development to the Mississippi River and the Grey Cloud SNA. "Meets requirements" is not enough. • The overall plan for this new Rachel Development using 4 different home builders appears to have changed substantially from when this whole development started in November 2021. There is less acreage allocated for this most current plan of 377 homes and the density was increased by changing lot sizes. • On the Mississippi Landing Amended Plan, the proposed homes on the southeast side appear to have moved closer to the river. How many feet are they setback from the Mississippi River? • Where is the stormwater runoff ponding for the homes with front row locations from east to west to the Mississippi River. • Where is the plan document detailing how the developer will hide those homes from the river so that the Public River Corridor Views (PRCVs) are provided; specifically from Hazen P. Mooers Park and Grey Cloud Dunes SNA. • I am concerned when reading that the City "misunderstood" PRCVs. In the future, I will want to go to Hazen P. Mooers Park and the Grey Cloud SNA and be surrounded by the natural world. I do not want to look at a residential development while sitting at the Mooers Park picnic table. I would like to understand the developer's implementation plan. How will the views be protected? • Does the City have dollars available to fix the City Conservation (Mississippi Dunes) Park issues outlined by the developer? Estimated cost? • When the City or the Developer refers to the "DNR", please be specific as to what department of the DNR organization. A contact name would also be helpful. • Please stop with the PUDs. The City residents have given this developer enough by losing this natural space. Note: The thoroughness of the information provided and the delivery of this plan on the City's website was excellent. My comment says nothing about the accuracy of the information but the accessibility to the individual files on the website was the best it's ever been. Please add this file to the public record for this project. Thank you. Respectfully,` A Bonnie Matter, Resident Ref: Public River Corridor Views (PRCVs): • Mr. Matthew Blythe, Superintendent, letters to Emily Schmitz, City of Cottage Grove, dated January 6, 2022 and February 14, 2024, U.S. Department of the Interior, National Park Service, Mississippi National River and Recreation Area (NRRA) Ref: Mississippi Dunes Golf Course EWA Requirements: • Ms. Karen Kromar, Project Manager, Environmental Review Uni, Resource Management and Assistance Division, Minnesota Pollution Control Agency letter to Emily Schmitz, City of Cottage Grove, dated December 22, 2021 Ref: Grey Cloud Scientific and Natural Area Protection: • Ms. Melissa Collins, Regional Environmental Assessment Ecologist, Minnesota Department of Natural Resources, Division of Ecological and Water Resources Region and Headquarters, letters to Emily Schmitz, City of Cottage Grove, dated December 22, 2021, and September 6, 2023 • Ms. Melissa Collins, Regional Environmental Assessment Ecologist, Minnesota Department of Natural Resources, Division of Ecological and Water Resources Region and Headquarters, letter to Mike Mrosla, City of Cottage Grove, dated May 13, 2022 3 Bonnie Matter Cottage Grove City Council Meeting Regular Agenda Item 11C. Preliminary Plat and Planned Unit Development - Mississippi Landing Open Forum I oppose the 377 unit residential development of the Mississippi Dunes. I oppose it because of its proximity to both the Mississippi River and the Grey Cloud Dunes Scientific and Natural Area. I oppose it because it is in the Mississippi National River and Recreation Area, This is a different space. It needed different planning and community engagement before changing the zoning from transitional to residential. I oppose it because that area is Cottage Grove's unique natural space on the Mississippi River. I oppose it because of the harm it will cause to the Mississippi River, the Grey Cloud Scientific and Natural Area (SNA), and all the wildlife, migrating birds, local birds, four -legged animals, bees, flowers, vegetation - all the inhabitants that call it home today. It was a mistake that the property was zoned residential from transitional without getting community input first. The perception was that the City was trying to push this through quickly because the City knew how unique the area was and wanted to profit from it. There were other options. The outpouring from the Community has been heartbreaking to watch. And the response by the City Council and the Planning Commission has been perceived as callous and disrespectful to their concerns. We know that a landowner has the right to dispose of their property as they see fit as long as it meets the zoning requirements. In this particular case, there were many things that seemed a bit off. The property was purchased by the current landowner in a foreclosure sale. There was a pandemic when most people were learning how to conduct their jobs from their homes on Zoom. It appeared that there was a rush on the part of the City to move the plan through. In 2021, there was a mysterious fire on the property that burned down the clubhouse. The Community outcry was for keeping the location a natural space. Community members had hoped to turn the property into a nature park. Various nature organizations indicated a willingness to help purchase the property but required the City's support. But the City never recognized that. Instead, there was a development plan accepted by the City before the zoning had gone through the required regulatory approval process. The Environmental Assessment Worksheet raised more questions and comments both from the regulatory agencies as well as the public. Whatever happens moving forward, It is imperative that the Grey Cloud Scientific and Natural Area (SNA) be protected by the City of Cottage Grove, the developer, the builders and their employees, and the future residents of that development. The Community and the Friends will be watching, United States Department of the Interior IN REPLY REFER TO: 1.A.1 January 6, 2022 Emily Schmitz Senior Planner City of Cottage Grove 12800 Ravine Parkway South Cottage Grove, MN 55016 NATIONAL PARK SERVICE Mississippi National River and Recreation Area I I I E. Kellogg Blvd., Ste 105 St. Paul, Minnesota 55101-1256 RE: Former Mississippi Dunes golf course EAW Dear Emily Schmitz: The Mississippi National River and Recreation Area (MNRRA) is pleased to provide continents on the Former Mississippi Dunes golf course Environmental Assessment Worksheet (EAW). The proposed project would lie completely within the boundary of the Mississippi National River and Recreation Area (NRRA). Congress established the Mississippi NRRA in 1988 to preserve, protect, and enhance the significant values of the Mississippi River Corridor in the Twin Cities metropolitan area. The Former Mississippi Dunes golf course (Mississippi Dunes) is in a unique site that would benefit from the inclusion of more natural areas than what is being proposed. While much of the development has been disturbed for agriculture and as a golf course, it has not been maintained for several years. The 164 acres of open space should be developed with precautions as not to disturb any species of concern at Mississippi Duties since it has been vacant. Cover Types While we have concerns over the proposed Mississippi Dunes development, there are a few aspects of the design in the EAW we do appreciate. The space allotted as park is more than what is required by ordinance and designating over a 300-foot setback from the Mississippi River is quite generous. While we are pleased that these portions of the development have been set aside as park space, we do not want to see a housing development that will remove 6.9 acres of woodlands/Forests, and 3.8 acres of brush/grasslands. This would remove 100% of these cover types. Table 5 states there will be an increase of 27.8 acres of open/natural space, not including a single acre before the development. This is misleading as the majority of the 164 acres has become more natural since it has been vacant. Incorporating established natural cover types into the development's design would be better than demolishing this established habitat. This is especially true on the western side of the development where dry tall grasses and forests tie into ag vegetation and the addition of vegetation within the housing development may reduce ,ts from the SNA's PRCV. the proposed development in the EAW is in line l with the al environments of MRCCA, . The Mississippi is still more that can be done to preserve and enhance NRRA is willing to assist by providing input during the continued design o£ this project. If you any questions regarding these comments, please contact my staff, Adam Muilenburg at adam mullenburg c�nps.gov or by calling 6512 Sincerely, Digitally signed by MATTHEW MATTHEW BLYTHE BLnHE Date: 2022.01.0615:01:10-06'00' Matthew T. Blythe Superintendent CC Paul Heuer �gNT op ) Per,. �>yFi United States Department of the Interior NATIONAL PARK SERVICE H 3'0a Mississippi National River and Recreation Area 11 1 E. Kellogg Blvd„ Ste 105 IN REPLI' RCf('R TO: St, Paul, Minnesota 55101-1256 1.A.1 February 14, 2024 City of Cottage Grove Emily Schmitz, Community Development Director 12800 Ravine Parkway South, Cottage Grove, MN 55016 RE: Mississippi Landings 11 Preliminary Plat Dear Community Development Director Schmitz, The Mississippi National River and Recreation Area (NRRA) is pleased to provide comments on the Mississippi Landings 11 preliminary plat. The proposed project would lie completely within the boundary of the NRRA. Congress established the Mississippi NRRA in 1988 to preserve, protect, and enhance the significant values of the Mississippi River Corridor in the Twin Cities metropolitan area, The NRRA reviews and comments on local actions like this within the NRRA boundaries as authorized in Section 4 of Subehapter CX1 of US Code 16 to ensure river resources are protected, The Former Mississippi Dunes golf course is in a unique site that would benefit from the inclusion of more natural areas. The 164 acres of open space should be developed with precautions as not to disturb any species of concern and prevent non-native plants from establishing in the nearby Scientific and Natural Area, As in our response (January 6, 2022) to the site's EAW, we arc still concerned with the impact that the development will have on two Public River Corridor Views (PRCV) within the immediate area of the plated properties. These protected views ensure that disruptions on the landscape viewed from PRVCs do not impact the scenic resources. A way of looking at a PRCV is it creates an overlay on the lands that form the PRVC's viewshed, parts of this project site fall within PRVC viewsheds. We believe the city misunderstood PRVCs in their response to our EAW letter stating that PRVCs are not present. While there are not any PRVC points on the project site, the project site does fall within the viewshed of two PRVCs. One is located at Hazen P. Mooers park, the other Grey Cloud Dunes SNA. There is a potential for these protected views to be permanently impacted without proper vegetative screening. To comply with state and federal policies the city should ensue that development properly screens structures with native vegetation from these two protected viewpoints. Maintaining existing native vegetation will be important to achieve protection of views from the river and PRVC. Current plans appear lacking in protecting these PRC'Vs. As this development continues, we look forward to working with the City of Cottage Grove to ensure protection of river resources. If you have any questions regarding these comments, please contact niy staff, Forest Eidbo at Sincerely, MATHEW BLYTHE Datea2024.02,150 56 6H06'00'YTHE Matthew T. Blythe Superintendent 520 Lafayette Road North I St. Paul, Minnesota 55155-4194 1 651-296.6300 800-657-3864 1 Use your preferred relay service I info,pca@state,mn.us I Equal Opportunity Employer December 22, 2021 Emily Schmitz Senior Planner City of Cottage Grove 12800 Ravine Parkway South Cottage Grove, MN 55016 Re: Former Mississippi Dunes Golf Course Environmental Assessment Worksheet Dear Emily Schmitz: Thank you for the opportunity to review and comment on the Environmental Assessment Worksheet (EAW) for the Former Mississippi Dunes Golf Course project (Project) in the city of Cottage Grove, Washington County, Minnesota. The Project consists of a new residential development on a former golf course. Regarding matters for which the Minnesota Pollution Control Agency (MPCA) has regulatory responsibility or other interests, the MPCA staff has the following comments for your consideration. Cover types (Item 7) The cover types listed in the table under Item 7 do not seem to portray the existing site conditions accurately. For example, under open space, zero acres are listed. It would seem that a golf course would have a significant amount of open space. Permits and Approvals (Item 8) It may be necessary to obtain a Sanitary Sewer Extension Permit from the MPCA prior to construction. The application form and additional information on this process can be found at http•//www Dca state.mn.us/water/permits/!ndex.htmI#sanitarysewer. Questions on the sanitary sewer extension permit process should be directed to Dave Sahli at 651-757-2687 or David.Sahli@state.mn.us. Water Resources (Item 111 Wastewater • This section mentions the additional work and utilities that must be extended to serve the Project, but there are no details about that work in the EAW, There was a mandatory EAW completed for the Cottage Grove South District Trunk Sewer earlier this year. If that sewer needs to be extended again for this Project, a separate mandatory EAW may be required. This related work, and whether a mandatory EAW is needed for the extension of the sewer to this site, needs to be discussed in more detail. Stormwater • The Project proposes disturbance of 110 acres of the 164-acre site and will discharge stormwater to the Mississippi River, which has construction -related impairments. Because the Project will disturb 50 or more acres, the Stormwater Pollution Prevention Plan (SWPPP) will need to be submitted for review and approval by MPCA prior to obtaining National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) Construction Stormwater Permit (CSW Permit) coverage. Emily Schmitz Page 3 December 22, 2021 We appreciate the opportunity to review this Project. Please provide your specific responses to our comments and notice of decision on the need for an Environmental Impact Statement. Please be aware that this letter does not constitute approval by the MPCA of any or all elements of the Project for the Purpose of pending or future permit action(s) by the MPCA. Ultimately, it is the responsibility of the Project proposer to secure any required permits and to comply with any requisite permit conditions. If you have any questions concerning our review of this EAW, please contact me by email at i<aren.kromar�state mn us or by telephone at 651-757-2508. Sincerely, y�y /<20"Vax& This document has been electronically signed, Karen Kromar Project Manager Environmental Review Unit Resource Management and Assistance Division KK/RG/DS/CVH:rs cc: Dan Card, MPCA, St. Paul Roberta Getman, MPCA, Rochester Dave Sahli, MPCA, St, Paul Cathy Villas -Horns, MDA, St. Paul Division of Ecological and Water Resources Transmitted by Email Region 3 Headquarters 1200 Warner Road Saint Paul, MN 55106 December 22, 2021 Emily Schmitz, Senior Planner City of Cottage Grove 12800 Ravine Parkway Cottage Grove, MN 55016 Dear Emily Schmitz, Thank you for the opportunity to review the Former Mississippi Dunes Golf Course EAW. The DNR greatly appreciates the early coordination and consideration of the Grey Cloud Dunes Scientific and Natural Area (SNA) throughout the development of this project. As a prominent neighbor to this development, the DNR has an interest in any project that could affect the use of the SNA by both wildlife and the community as well as our management of this natural resource. We recognize the willingness on the part of the City of Cottage Grove to facilitate the expansion of the SNA and to ensure that natural resource concerns are addressed through the environmental review process. Less than 1% of Minnesota's native prairie remains and the remaining prairie mostly consists of widely scattered small fragments surrounded by agriculture and development. Many of the species that rely on these prairies have been extirpated from our state or are on the brink of being lost, and so protecting remaining prairie remnants is critically important. It was not feasible for DNR and partner organizations to purchase the entire project area, therefore we prioritized the highest quality habitat for the 12 acres expansion of the SNA. We recognize the challenge that many cities are facing in balancing heightened development pressures with natural resource management and protection. With that in mind, we respectfully submit the following comments for your consideration: 1. Page 8, Construction Timing of Site Development Activities. The project proposes to start grading activities in the Spring/Summer of 2022. The Natural Heritage Review (NHIS) letter, dated November 19, 2021, identifies several threatened and endangered plant and animal species within the direct vicinity of the project. Minnesota's Endangered Species Statute (Minnesota Statutes, section 84.0895) and associated Rules (Minnesota Rules, part 6212.1800 to 6212.2300 and 6134) prohibit the take of threatened or endangered species without a permit. Avoidance and survey requirements will need to be met before any grading of the site or tree removal can proceed. Species -specific work exclusion dates and survey timeframes will affect the timing of construction. Please consult with the Endangered Species Environmental Review Coordinator, Lisa Joyal (lisa.joyal@state.mn.us), regarding this process. 10. Page 22, Post Construction Conditions. We recommend using BWSR-approved, native seed mixes for seeding stormwater features, project landscaping, and soil stabilization. Due to the proximity to the SNA, please make sure that all seed mixes are free of noxious weeds and invasive species. 11. Pages 26-29, Rare Features. This section mentions the previous agricultural and golf course uses of parts of the project area, but fails to identify that the area planned for development is mapped as a Minnesota Bioloicai Survey (MBS) Site of High Biodiversity Significance as well as a DNR Native Plant Community (NPC). Despite the previous uses and disturbance, sections of the project area within the golf course were left intact and may yet contain rare plants and valuable wildlife habitat. Though the previous use as a golf course disturbed these plant communities, the conversion of an additional 43 acres to impervious surfaces is a more significant impact and should not be minimized. The MBS Site was mentioned by DNR in the November 19, 2021 NHIS letter and in early coordination documents. Sites of Biodiversity Significance have varying levels of native biodiversity and are ranked based on the relative significance of this biodiversity at a statewide level. Sites ranked as "High" contain very good quality occurrences of the rarest species, high -quality examples of rare native plant communities, and/or important functional landscapes. Dry Sand — Gravel Prairies (Southern) are listed as imperiled and every effort should be made to preserve what remnants are left. This particular MBS Site will be completely eliminated by the housing development under the current proposal. This site has been disturbed by previous land use and may no longer qualify as a prairie remnant. However, the golf course left areas of prairie intact and it is likely that native plant communities and seed banks persist and could be fully restored. 12. Page 29, Rare Features. The project proposes to avoid impacts to the Rusty -patched bumble bee, Leonard's skipper, Regal fritillary and the Monarch butterfly by completing the vegetation disturbance early in the 2022 season. Due to the potential need for plant surveys during the growing season, these mitigation measures are unrealistic. Permanently converting even degraded grassland to impervious surfaces will remove habitat within the project area and should be considered a long-term impact. Because the Rusty -patched bumble bee is a federally - listed as endangered, please coordinate with the U.S. Fish and Wildlife Service regarding mitigation for long-term impacts to this species. 13. Page 30, Rare Features. The summary of DNR's requirements should mention that tree/shrub removal is prohibited from April through August 15t" to avoid impacting endangered bird species that have been documented in the direct vicinity of the project. Please coordinate with DNR if this is not feasible as bird surveys may be necessary prior to disturbance. 14. Page 32, Dust and Odors. If water is taken from the Mississippi River for controlling dust, then the use of more than 10,000 gallons of water in a day must be approved under a DNR Water Appropriation Permit. 15. Page 32, Dust and Odors. Please do not use products that contain chloride for dust control. 16. The DNR supports the development of a park that will allow the community to access and engage with the Mississippi River and the unique ecosystem of the area. Please include the SNA in trail planning in order to ensure that trail locations meet the management needs of all parties and that encroachment onto the SNA is prevented. We look forward to continuing Division of Ecological and Water Resources Region 3 Headquarters 1200 Warner Road Saint Paul, MN 55106 September 6, 2023 Emily Schmitz, Senior Planner City of Cottage Grove 12800 Ravine Parkway Cottage Grove, MN 55016 Dear Emily Schmitz, Transmitted by Email The DNR has been contacted by concerned citizens regarding the Mississippi Landing Development that is on the agenda for the Special City Council Meeting to be held by the City of Cottage Grove on September 6, 2023. As a prominent neighbor to this development, the DNR has an interest in any project that could affect the use of the Grey Cloud Dunes Scientific and Natural Area (SNA) by both wildlife and the community as well as our management of this natural resource. We recognize the willingness on the part of the City of Cottage Grove to facilitate the expansion of the SNA, and we look forward to coordinating further on natural resource management as the City establishes a new city park in the area. As the City considers the proposed development, we respectfully submit the following comments for your consideration: 1. Please be aware that the previous development proposer, Pulte, obtained a Natural Heritage Review (NHIS) letter (dated November 19, 2021) that identified several threatened and endangered plant and animal species within the direct vicinity of the project. Minnesota's Endangered Species Statute (Minnesota Statutes, section 84.0895) and associated Rules (Minnesota Rules, part 6212.1800 to 6212.2300 and 6134) prohibit the take of threatened or endangered species without a permit. Avoidance and survey requirements will need to be met before any grading of the site or tree removal can proceed. Species -specific work exclusion dates and survey timeframes will affect the timing of construction. Many of the state -protected rare features within the SNA can occur beyond the SNA boundary, therefore it is important that all development, utilities, and construction projects within the vicinity allow sufficient time for coordination with DNR. The Natural Heritage database is continually being updated, which is why NHIS letters are considered current for 12 months. The previous Natural Heritage Review was conducted in 2021, and by a different proposer. It is important that Rachel Development also coordinates with DNR to avoid impacting state -protected species, and may do so by submitting the project to �Vlialne, -'(A a 0)1-1 eivf ,�Licm Please consider incorporating this step into further Minnesota Department of Natural Resources 1200 Warner Road St. Paul, MN 55106 Phone: 651-259-5755 Email: melissa.coliins@state.mn.us CC: Jennifer Levitt, City Administrator Paul Robinson, Rachel Development Kit Elstad-Haveles, DNR Region 3 SNA Supervisor Liz Harper, DNR Assistant Regional Manager Equal Opportunity Employer Division of Ecological and Water Resources Transmitted by Email Region 3 Headquarters 1200 Warner Road Saint Paul, MN 55106 May 13, 2022 Mike Mrosla, Senior Planner City of Cottage Grove 12800 Ravine Parkway Cottage Grove, MN 55016 RE: Preserve at Prairie Dunes Development Adjacent to Grey Cloud Dunes SNA Dear Mike Mrosla, The Department of Natural Resources (DNR) has reviewed the information provided in the City of Cottage Grove Planning Commission packet regarding the Preserve at Prairie Dunes Development, and would like to provide comments to be shared with City staff and council members prior to the consideration of this project at the May 18, 2022, City Council Meeting. A query of the Natural ir�t� Inforrr��tit�r� system (NHIS) should be requested to assess the potential impacts to rare species, as was stated would be required in the Cottage Grove Business Park AUAR 2022 Update. It is likely that surveys and/or timing restrictions for tree removal and construction may apply to this development, and an NHIS review would support taking these factors into account. Potential impacts to rare species and subsequently the SNA should be factored into decision -making when the City considers this project. Many of the state -protected rare features within the SNA can occur beyond the SNA boundary, therefore it is important that all development, utilities, and construction projects within the vicinity query the NHIS in the early planning stages of a project as to allow sufficient time for coordination with DNR. Also, please be aware that the project area is within a high potential zone for Rusty -patched bumble bee (RPBB). Because RPBB is federally listed as endangered, the proposer will need to coordinate with the U.S. Fish and Wildlife Service regarding potential impacts to this species. The DNR appreciates that a trail will act as a barrier between residences and the SNA since management of the SNA involves semi -regular use of prescribed fire to maintain open habitat conditions that are favorable to rare plant and wildlife species that exist on the property. Prescribed burning is generally considered a safe land management tool, but smoke from this activity can reach other adjacent properties on occasion. The trail width will not always be sufficient to prevent smoke from reaching neighboring properties and potential homeowners should be made aware of this potential when purchasing adjacent property. tea.DEPARTMENT OF Lands and Minerals Division Region 3 1200 Warner Road St. Paul, Minnesota 55106 To: Mike Mrosla, planner, City of Cottage Grove From: Martha Vickery, regional coordinator Lands and Minerals Division Date: February 14, 2022 RE: DNR comments - Cottage Grove 2040 Comprehensive Plan Amendment DNR is submitting comments on the proposed amendment to the Cottage Grove 2040 Comprehensive Plan. r The mission of the Minnesota Department of Natural Resources is to work with citizens to conserve and manage the state's natural resources, to provide outdoor recreation opportunities and to provide for commercial uses of natural resources in a way that creates a sustainable quality of life. With these things in mind, we appreciate the opportunity to provide on the proposed plan amendment. We support the City's commitment to protect and enhance the natural environment. The following comments outline ways to further these goals: Wastewater. The DNR requests that the City of Cottage Grove continue to coordinate with the Grey Cloud Dunes Scientific and Natural Area (SNA) to ensure that future development does not negatively impact (either directly or indirectly) the quality of the natural resource within the SNA, or access to the SNA. Any future sewer collection lines and utilities should avoid the Grey Cloud Dune SNA boundary. No utility lines may cross the SNA; if there is a need to do so, the city must apply for a utility ` crossing license. Many of the state -protected rare features within the SNA can occur beyond the SNA boundary, therefore we recommend that any planning for development, utilities, and construction projects in the SNA vicinity include a query of the Nm-ural Herit� Information aystetb to avoid impacts to state -listed rare species. Mississippi River Corridor Critical Area. The revised plan mid maps reference the Liississip River Corridor Critical Area MOCK:A but do not show the t��3RCCA PI-imary conservadou Areas or the t Exi Ling V gg Lath r '21, catds within the proposed plan amendment area. MDEPARTMENT OF NATURAL RESOURCES sources Division of Ecological & Water Re 500 LafaVette Road, Box 25 St. Paul, MN 55155-4025 Novernber19, 2021 .a...ce # ERDB 20220&,4. Jessica Points Swanson Haskamp Consulting, LLC 246 South Albert Street, Suite 2A St. Paul, MN 55105 RE: Natural Heritage Reviewof the proposed Dune Development- Pulte Homes, T27N R21W Sections 30 and 31; Washington County Dear Jessica Points, As requested, the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one -mile radius of the proposed project. Based on this query, rare features have been documented within the search area (fordetails, please visitthe formore information on the biology, habitat use, and conservation measures of these rare species). Please note that the following rare features may be adversely affected by the proposed project: Ecologically Significant Areas The Minnesota Biological Survey (MBS) has identified several Sites of Biodiversity Significance within the project boundary. Sites of Biodiversity Significance have varying levels of native biodiversity and are ranked based on the relative significance of this Biodiversity at a statewide level. Factors taken into account during the ranking process include the number of rare species documented within the site, the quality of the native plant communities in the site, the size of the site, and the context of the site within the landscape. These Sites were documented to contain multiple native plant communities. However, these areas were delineated priorto the golf course development in the area. As such, a majority of these ecologically significant areas are destroyed completely or extremely deteriorated. According to aerial photography, there are small portions of Dry Barrens Prairie (Southern) native plant communities that may still be Intact. Multiple state -protected species (see below) have isn't feasible, as the DNR may request that a survey for active nests be conducted prior to construction. Louisiana broomrape (Orobanche ludoviciona var. ludoviciano) and seaside three -awn (Arlstida tuberculoso), both state -listed threatened plant species, and purple sandgrass (Triplasis purpureovar. purpurea) and Hill's thistle (CirsiLIM PUMIJUM var. hilli), both state -listed plant species of special concern, have been documented in the vicinity ofthe proposed project. These species are found primarily in prairie habitatswith sandy sails and dunes. Minnesota's Endangered Species Statute (Minnesota Statutes, section 84,0895) and associated Rules (Minnesota Rules, part 6212,1800 to 6212,2300 and 6134) prohibitthe take of threatened or endangered species without a permit, As Louisiana broomrape and seaside three -awn were documented in the vicinity of the proposed project, a qualified surveyor needs to conduct a habitat assessment in any undisturbed areas that will be impacted by the proposed project. If potential habitat for these species is documented and those areas cannot be avoided, a botanical survey will be needed. Surveys must follow the standards contained in the attached Rare Species Survey Process and Rare Plant Guidance, Project planning should take Into account that any botanical survey needs to be conducted during the appropriate time of the year, which may be limited. Please consultwith the Endangered Species Environmental Review Coordinator, Lisa Joyal (lisa,joyal @state. mn.us), regardingthis process. Is North American racer (Coluber constrictor), a state -listed species of special concern, has been documented in the vicinity of the proposed project and may be encountered on site. These snakes prefergrassy areas with sandy and gravel soils. Given the presence of these rare snakes, the DNR recommends that the use of erosion control mesh, if any, be limited to wildh V1 a, The Leonard's skipper (Hesperia leonardus) and regal fritillary (Speyerla Walla), both state -listed butterfly species of special concern, have been documented within the vicinity of the project These species populations have declined historically due to the widespread conversion of native prairie for agriculture and otheruses. Less than 1% of Minnesota's native prairie remains and the remaining prairie mostly consists of widely scattered small fragments surrounded by agriculture and development. To protect these prairie obligate butterfly species, avoiding disturbance to native prairie is strongly recommended. Federally Protected Species To ensure compliance with federal law, conduct a federal regulatory review using the U.S. Fish and Wildlife Service's (USFWS) online h0('01Thdh10n F""i on 0 Environmental Review and Permitting Page 3 of 5 Unko: Rare Species Guide http://www.dnr.stote.mn.uu/oK/|ndex.htnd DNRReg! ooa|EnvironmaNe|Assnsamen LGun\ogistContac1|n[o http://www.dnr.otate.mn.uo/eco/enwiew/erp_regionoontacts.htm| U5FVVS}PoCTon| https://ecPac/ VVi{dl ifeFr|endlv[rosionControl http://f i|es.dm.date.mn.us/eco/no ngame/wi|dlif e-f rlendly-ems|on -co nt rol.pdf MBSS\tesnf8iod|vero\tYS\Qnificanoe htip://wxxvv.dnr.state.mn.us/eco/mcbs/b(od|memity_Quide|ines.htm| DNRNative P|ant Communities http://www.dnr.state.mn.Lis/tipc/index,html K4NGeospaUa|Commons httpy://nixdata.mn.gov/ BVV5RNative Vegetation/seed Mixes http://wovw.bwstutate.mn.us/naUva_ye8etadon/ Cc: Melissa Collins and Leslie Parris Page 5 of 5 friencls 4 Minnesota Scientific & Natural Areas www.snafriends.org City of Cottage Grove Attn: Emily Schmitz 12800 Ravine Parkway South Cottage Grove MN, 55016 Re: Comments on environmental assessment of the proposed Mississippi Dunes development project. Dear Emily, Friends of Minnesota Scientific and Natural Areas (FMSNA) is a Minnesota non-profit, tax- exempt ["501(c)(3)"] corporation, established to advocate and support the establishment, management, perpetuation of Minnesota's Scientific and Natural Areas (SNAs), statewide, in an undisturbed natural state. Thank you for the opportunity to comment on the environmental assessment of the proposed Mississippi Dunes development project. In reviewing the EAW on the Mississippi Dunes project we notice an inconsistency between the text and Figure #5 Concept Sketch Plan. The text includes a plan to sell -12 acres of land adjacent to theGrey the Concept Cloud Sketch oDunes f Pulte Hoto the Dmes(Figurein ord with the #5) shows he lots forter de detached an homesfigure #4). However, p homes placed right up to the current boundary of the SNA. This inconsistency should be remedied so there is no question that the Proposer intends to sell the 12 acres to the DNR to protect the natural resources and wildlife in the Grey Cloud Dunes SNA. Below are the two quotes from the EAW which are inconsistent with Figure #5 which is attached: Page 9 c. Explain the project purpose; if the project will be carried out by a governmental unit, explain the need for the project and identify its beneficiaries. The Project will provide a diverse mix of housing types within the City and will help meet current and future demand for housing as established within the City's 2040 Comprehensive Plan. It includes 239 60-foot lots intended for market rate detached single-family homes, 130 50-foot lots planned for detached townhomes marketed to active seniors 55+, and a 130-unit senior [a living building. During the Mississippi Dunes Master Plan process the City identified the land abutting the Mississippi River as an important public amenity that should be protected and accessible. This Project will protect the river frontage for a combination of active and passive park uses, river buffer and extension of the MnDNR Scientific Natural Area (SNA). As shown on the Concept Sketch Plan, approximately 25.3 acres of land will be protected as river buffer/ park, 6.8 acres as City Park, and approximately 12-acres are planned for purchase by the MnDNR. Page 29 d. Identify measures that will be taken to avoid, minimize, or mitigate adverse effects to fish, wildlife, plant communities, and sensitive ecological resources. The adjacent Grey Cloud SNA is an area with known high -quality wildlife, plant communities and rare features. Given the adjacency of the Project site to the Grey Cloud SNA, the Project Proposer is working with the City and the MnDNR to properly site the open space corridor to protect the natural resource area and have Identified the potential to sell approximately 12- acres of land to the MnDNR. The area identified as important to protecting the natural resources and wildlife in the Grey Cloud SNA would be sold from the Project Proposer to the MnDNR and Incorporated as part of the SNA into perpetuity. ENVIRONMENTAL ASSESSMENT WORKSHEET Figure 5. Cancepl Sketch Plan DRAFT rnrMl Mississippi Dunes Ectl Cwsse Thank you for your attention to this matter, Sincerely Yours, Tim Johnson Friends of Minnesota Scientific and Natural Areas (763) 486-8139 auNEs Working to protect the Mississippi River and its watershed in the Twin Cities area. Suite 2000 M"JI11r.or S,Iint Peal, MN 55-101 info@trnt org January 5, 2021 Emily Schmitz, Senior Planner City of Cottage Grove 12800 Ravine Parkway S. Cottage Grove, M N 55106 Dear Emily: Friends of the Mississippi River (FMR) appreciates the opportunity to comment on the Environmental Assessment Worksheet (EAW) for Pulte Homes' redevelopment proposal for the former Mississippi Dunes golf course. Mississippi Dunes is a rare and ecologically valuable area. Sand dunes like these are an exceptionally rare landscape in the Twin Cities and across the state. The site also includes 1,900 feet of Mississippi River shoreline, provides habitat for several threatened and endangered species, and adjoins the Grey Cloud Dunes Scientific and Natural Area (SNA). All of these assets make Mississippi Dunes more fragile than most other redevelopment sites in Cottage Grove. Any redevelopment here must be done with the greatest of care. Given the unique nature of this property and the area's rare ecological resources, this Proposed project has the potential for significant environmental effects. Therefore Cottage Grove should require an Environmental Impact Statement for this proposed project. We also request revisions to the following EAW sections: 10. Geology, soils, and topography/land forms 11. Water resources The topography and soil types in the project area present special considerations. Because sandy soils are so absorbent, subsurface water movement through the site will be significant. The site's slope towards the river suggests that without mitigation, subsurface water runoff will move towards the river. Slope stability, water volume through the site, and impacts to neighboring sites from this water movement need to be carefully studied. 13 11 off -trail human traffic in the SNA could be particularly harmful because of the site's fragile geology and rare plant species. Mitigation could include design elements (such as the platting home lots, adding trail connections, and using fencing or other barriers) to block egress to the SNA outside of existing trails. This section should also state that the project's vegetation management practices must be fully compliant with the city's Mississippi River Corridor Critical Area (MRCCA) ordinance. 14. Historic properties The project area has an extensive history of human use, including Indigenous settlement. Grey Cloud Island contains rare pre -contact archaeological resources, including Washington County's largest known concentration of burial mounds, and was the site of the only documented Indigenous village in the county. It is reasonable to believe that the Mississippi Dunes project area may also contain archaeological resources given its proximity to these documented sites. As noted in the draft EAW's correspondence with the State Historic Preservation Office, the majority of archaeological sites in the state have not been recorded. A lack of documented resources on the project site should not be taken as an assurance that such resources do not exist. Given the project's proximity to sites of immense historic significance, further study should be conducted before concluding that the proposed project will not adversely affect archaeological or cultural resources. The Prairie Island Indian Community, as well as any other interested tribes or Indigenous -led organizations, should be invited to consult on this study. 15. Visual We disagree that "there are no scenic views or vistas identified in the city's MRCCA plan" (31). The Public River Corridor View from Hazen P. Mooers Park will be affected by this project. Mississippi Dunes is clearly visible in the photo of this view included in the city's MRCCA plan. The Public River Corridor View from the Grey Cloud Dunes SNA may also be affected. A visual analysis of the project's impacts to these views should be conducted as part of this EAW and appropriate mitigation strategies employed. The goal of mitigation should be to preserve a view as similar to the existing view as possible, prioritizing vegetative screening and minimizing the visibility of new structures. Per the DNR, strategies to mitigate visual impacts can include: • Using building materials that blend in with natural surroundings, such as green or brown materials