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6. Response to July 21 TEP meeting minutes FINAL 4830-5370-4017 v.2 26105 Wild Rose Lane, Shorewood, Minnesota 55331, Phone: 952 -401-8757, Fax: 952-401-8798 Memorandum Date: October 9, 2017 To: Andi Moffatt (for City of Chanhassen, LGU) Todd Gerhardt & Kate Aanenson, City of Chanhassen Cc: Ben Meyer, BWSR Aaron Finke, Carver County SWCD Ryan Malterud, US Army Corps of Engineers From: Melissa Barrett, Kjolhaug Environmental Services Company Mark Nordland, Level 7 Development Darren Lazan & Steve Sabraski, Landform Professional Services Peder Larson, Larkin Hoffman Jim McComb, McComb Group Re: Response to July 21, 2017 – Revised August 1, 2017 TEP Meeting Minute Notes for Avienda Meeting July 11, 2017 This memo provides responses to outstanding WCA status items from the July 21, 2017 TEP Meeting Minute Notes for Avienda Meeting July 11, 2017 (Attachment A). Item 2. Avoidance and Minimization. Status: The applicant needs to supply a clear, concise avoidance and m inim ization argum ent in conform ance with W CA 8420.0520 Subp 3-Subp 6 and based on the Revised Table 2, discussion at the TEP m eeting, and the changes in the proposed wetland im pacts. Avienda Response: A summary of the project sequencing argument following the organization of MN WCA Rule 8420.0520 Sequencing Subp 3-Subp 6 is included as Attachment B. Table 2-REV. Comparison of Avienda with Other Regional Lifestyle Centers along with a discussion is in that attachment. The summary supports the determination that sequencing requirements have been satisfied. Changes in the proposed wetland impacts are illustrated on Figure A and itemized in Table 1 on the following page. As now proposed, Wetlands 3, 4, and 10 will be completely avoided. 2 Impact to Wetland 6 has been significantly (nearly 50%) reduced by removing the previously proposed stormwater pond (Figure B1) and incorporating its treatment function within other stormwater BMPs in the updated Draft Stormwater management Plan dated 10-6-2017. Impact reduction for Wetland 6 was feasible because it is located along the periphery of the project limits and within a natural low spot that was originally proposed to be used entirely for stormwater treatment purposes (Figure B2). This situation does not apply for the remaining wetlands proposed for impact (Wetlands 1, 1/2, 2, 5, 7, 8, and 9). The reduced impact to Wetland 6 has resulted in significant modification to the previously submitted Draft Stormwater Management Plan. A revised Draft Stormwater Management Plan dated 10-6-2017 has been submitted to the LGU. Table 1. Revised Wetland Impact Summary -Avienda, Chanhassen Wetland Original Proposed Impact (ac) Impact Type Revised Proposed Impact (ac) Impact Type USACE Regulated Wetlands 1 1.1001 Fill 1.1001 Fill No Wetland 1/2 0.1860 Fill 0.1860 Fill No Wetland 2 2.2569 Fill 2.2569 Fill No Wetland 4 0.1253 -- -- -- Yes Wetland 5 0.3483 Fill 0.3483 Fill No Wetland 6 0.5302 Fill 0.4986 Fill Yes Wetland 6 0.2514 Excavate -- -- -- Wetland 7 0.0150 Fill 0.0150 Fill No Wetland 8 0.0844 Fill 0.0844 Fill No Wetland 9 0.0985 Excavate 0.0985 Excavate No Total 4.9961 4.5878 Item 3. Secondary Impacts. Status: The applicant will need to submit the new stormwater analysis and modeling to the City for review as part of the WCA process, including analysis of secondary impacts to Wetlands 3 and 4 and downstream mitigation areas. Avienda Response: A revised Draft Stormwater Management Plan dated 10-6-2017 has been submitted to the City/LGU. Revisions were necessary because the stormwater pond previously proposed in the northwest corner of the site has been removed from the plan and its treatment functions have been incorporated into the revised stormwater plan. The analysis of secondary impacts (i.e., the potential for a decrease in wetland hydrology and hence wetland size post-development) to avoided and downstream wetlands can be evaluated by comparing pre and post-development discharge volumes (i.e., volume of runoff discharging into wetlands) and wetland high water levels. When large reductions in input volumes or high water levels occur, wetland type and specific characteristics that 3 dictate actual wetland hydrology/wetland boundaries should be taken into account as well when evaluating the potential for secondary wetland impacts. Reproduced below is Appendix G from the updated Draft Stormwater management Plan. Discharge Volumes The table provided by the engineer demonstrates that the discharge volume for 1, 10, and 100-year storm events post-development either increases or does not significantly decrease for Wetland 3, Wetland 6, MNDOT Mitigation Wetland M9, or MNDOT Mitigation Wetland M10. Although calculations indicate a significant decrease in discharge volume to Wetland 4 for all storm events, when considering the actual specific characteristics of Wetland 4, it can be confidently determined that this reduction will not affect the wetland boundary. Wetland 4 is a small (0.1253-acre), Type 1 flow-through wetland that is hydrologically 4 supported by intermittent drainageway discharge/flow (Figure C). Wetland 4 is located at the convergence of two drainage pathways and one agricultural tile outlet, and would most accurately be described as a vegetated sediment plume. The wetland is slightly sloping and has two incised drainageways within it. The existing outlet for Wetland 4 is below the wetland boundary and removes any short or long-term water storage. As long as the drainage/runoff from the ~20-acre woodland to the northwest keeps flowing through it, Wetland 4 hydrology will be maintained. The plans show that this existing woodland drainage pathway will be maintained. Although the post-development discharge volumes to Wetland 6 increases more than 120% of pre-existing conditions for each storm event, Wetland 6 is also a sloping, flow- through wetland with an outlet located below the wetland boundary. Increased discharge to this wetland will simply continue to pass through it, as is now the case. High Water Levels Changes in wetland high water levels for 1, 10, and 100-year storm events (although calculable) is immeasurable in the real world for MNDOT Mitigation Wetland M9 or MNDOT Mitigation Wetland M10. For those storm events that technically show a decrease (noting that some actually show an increase) in the post-development high water level, the resulting high water level is still above the wetland outlet elevation which is generally considered the elevation that controls the extent of the wetland boundary. Because the high water level for all storm events will be higher than the outlet elevation, is can be confidently determined that secondary wetland impacts will not occur. Although a significant drop in high water level is indicated for Wetland 4, this wetland is actually incapable of a high water level as it is a sloping wetland with an outlet located below the wetland boundary. High water levels are not provided for Wetland 6 for the same reasons. The calculated decrease in the high water level for Wetland 3 for all storm events is a function of the new engineered outlet elevation that is 1.1-feet lower than the current outlet. The pre-development outlet elevation used for stormwater modeling represents the current lowest landscape position along the wetland boundary (Figure D). A review of historical aerial photos (Appendix E of the Wetland Permit Application) and field observations showed that Wetland 3 has never ponded water, and that prior to development to the west the excess hydrology appeared to flow west if it flowed at all. It is extremely unlikely that water ever discharges from Wetland 3. Therefore, the engineered outlet at a “lower” elevation in conjunction with increases in discharge volume to Wetland 3 for the 1-year storm event, and insignificant changes in discharge volume for 10 and 100-year storm events is unlikely to result in secondary impact to the wetland (i.e., unlikely to result in a smaller/lower wetland boundary). The engineer has indicated that a weir structure could be added to the outlet culvert if deemed necessary by the TEP. Item 5. Housekeeping Items. Status: The applicant needs to provide written documentation and current site plan showing the accurate wetland impacts. 5 Avienda Response: Revised proposed wetland impacts are summarized in Table 1 above and are illustrated in Figure A. Revised impacts/avoided wetlands include:  Wetland 4 will now be completely avoided because the request for a variance for development impacts to the BCOD was not approved by the planning commission. The request for the variance was subsequently withdrawn.  The west half of Wetland 6 will now be avoided by removing the stormpond in that part of the site. The Draft Stormwater Management Plan has been remodeled, and other/additional stormwater management methods have been used so that the updated plan meets local, state, and federal water quality requirements. 4830-5370-4017, v. 2 K:\01694-860\Admin\Docs\2017_07_21 TEP Meeting Notes.docx 701 Xenia Avenue South | Suite 300 | Minneapolis, MN 55416 | (763) 541-4800 Memorandum To: TEP Members and Other Interested Parties (list below) From: Andi Moffatt, WSB Date: July 21, 2017 – Revised August 1, 2017 Re: TEP Meeting Minute Notes for Avienda Meeting July 11, 2017 WSB Project No. 1694-860 On behalf of the City of Chanhassen as the LGU for W CA, outlined below please the m eeting notes from the TEP m eeting that was held Jul y 11, 2017 to discuss the Avienda application. These notes have been reviewed b y City Staff and the TEP. If you have additions or corrections for these notes, please let m e k now by July 28, 2017. At tendees TEP Mem bers: Andi Moffatt, W SB (on behalf of City of Chanhassen) Paul Oehm e, Cit y of Chanhassen Ben Me yer, BW SR Aaron Fink e, Carver SW CD Others in Attendance: Melissa Barret, Kjolhaug Mark Kjolhaug, Kjolhaug Karen W old, Barr Jim McCom b, McCom b Group Peder Larson, Lark in Hoffman Mark Norland, Launch Properties Clare Bleser, RPBCW D Steve Sabraski, Landform Darren Lazan, Landform Kate Aanenson, Cit y of Chanhassen Others Copied on Mem o: Beck y Horton, DNR Terry Jeffery, RPBCW D Kendra Lindahl, Landform Todd Gerhardt, Cit y of Chanhassen Overview of Project Level 7 Developm ent, LLC, has applied for a W etland Conservation Act (W CA) perm it with the Cit y of Chanhassen as the Local Governm ent Unit (LGU) for the W CA. The developer provided an overview of the 115-acre developm ent project (about 80 acres are developable) for a Regional Lifestyle Center . The developer is proposing to im pact 4.897 acres of W CA regulated wetland, either by fill or excavation for storm ponds. There is also 1,429 square feet of waterway im pact, but this is not regulated b y W CA as it is not a W CA wetland. W SB has been reviewing the perm it application on behalf of the City since February 2017. Building a legacy – your legacy. Equal Opportunity Employer | wsbeng.com Attachment A K:\01694-860\Admin\Docs\2017_07_21 TEP Meeting Notes.docx Aug 1, 2017 Page 2 1. Applicant subm itted application February 15, 2017 with prelim inary storm water m odeling inform ation on Februar y 21, 2017. 2. Cit y determ ined application was incom plete on March 10, 2017. This determ ination was reviewed with the applicant on March 9, 2017. 3. Applicant subm itted revisions on March 14, 2017. 4. Cit y determ ined the application was com plete on March 17, 2017. A W etland Conservation Act Notice of Application was sent out the Technical Evaluation Panel on March 17, 2017. 5. T he first 60-day tim eline ended May 13, 2017. The LGU extended that tim eline in writing for 60 additional days until July 12, 2017. The LGU indicated that if the applicant wanted to extend the tim eline again, the Cit y needed this extension in writing. The applicant has supplied this extension so the third 60-day tim eline ends Septem ber 10, 2017. 6. T he project proposes to im pact the following wetlands: Table 1. Summary of Proposed Wetland Impacts W etland Num ber W etland T ype W etland Acreage Im pact Acreage (fill and excavate) Fill or Excavate Wetland Management Class W etland 1 1, 3 1.001 1.001 F Manage 2 W etland 1/2 1, 2 0.1860 0.1860 F Manage 2 W etland 2 1, 2, 5 2.2569 2.2569 F Manage 2 W etland 3 1 0.6696 0 NA Manage 2 W etland 4 1 0.1253 0.1253 F Manage 2 W etland 5 1 0.3483 0.3483 F Manage 3 W etland 6 1 0.5302 0.5302 Fill Manage 2 W etland 6 1 0.2514 0.2514 E (for pond) Manage 2 W etland 7 1 0.0150 0.0150 F Manage 3 W etland 8 1 0.0844 0.0844 F Manage 3 W etland 9 1 0.0985 0.0985 E (for pond) Manage 3 W etland 10 1 0.0740 0 NA Preserve TOT AL 5.6406 4.897 The applicant and City staff noted that Cit y Council had given conditional approval for the developm ent at the July 10, 2017 City Council m eeting. This approval is conditional pending approval of the W CA perm it. Items Discussed by the T EP 1. Wetland Boundary, Type and Classification: The LGU reviewed the wetland delineation, typing, and MnRAM classifications. This inform ation is summ arized below. Per the Replacem ent Plan Check list included with the March 17, 2017 Notice of Application, sequencing flexibility is not being sought with this project. The LGU and TEP concurred with the wetland delineation, wetland typing, and MnRAM classifications as noted below and in the application. Attachment A K:\01694-860\Admin\Docs\2017_07_21 TEP Meeting Notes.docx Aug 1, 2017 Page 3 Table 3. Wetland T ype and M anagement Classification Summary 2016 Application Ci ty's Plan 2014 Report Cowardi n Ci rcul ar 39 Management Cl ass Manage me nt Class Cowardin Circular 39 We tland 1 PEMAd T1 M2 M2 PEMB T2 PEMCd T3 We tland 2 PUBG T5 M2 M2 PEMB T2 PEMBd T2 PUBFx T4 PEMAd T1 We tland 3 PEMA T1 M2 M3 PEMB T2 We tland 4 PEMAd T1 M2 PEMB T2 We tland 5 PEMAd T1 M3 PEMA T1 We tland 6 PEMAd T1 M2 M2 PFO1A T1 We tland 7/8 PEMAd T1 M3 We tland 9 PEMAd T1 M3 We tland 10 PFO1A T1 P Status: No additional information from the applicant is needed. 2. Avoidance and M inimization: The March 2017 application did not provide sufficient supporting docum entation that avoidance and m inim ization had been m et per the W CA. The applicant provided a m ark et study dated March 2017 (subm itted in April 2017). This stud y summarized existing retail trends and shopping centers in the greater Twin Cities area. The appendices in the June 5, 2017 subm ittal provided additional inform ation about regional lifestyle centers and the need for different land use t ypes to provide a viable developm ent. The LGU developed a table (in the June 30, 2017 TEP m eeting agenda m em o) based on this inform ation for discussion purposes. At the TEP m eeting, the applicant clarified table categories and provided a revised table based on appropriate comparative data, to clarify the LGU’s compilation and interpretation of various information gathered from the Applicant’s June 5 submittal. This revised table is shown below. The applicant discussed what m akes a Regional Lifestyle Center and stated that it is the synergy of the proposed developm ent that m akes it a viable developm ent and function together. A Regional Lifest yle Center is intended to create an experiential use to overcom e e -comm erce pressures. T he applicant discussed that the Senior Housing that was proposed in a part of the Bluff Overlay District was being rem oved; the Cit y s taff indicated the proposed road through the Bluff Overlay was also being rem oved. W etland 4 is no longer being im pacted as noted in the application. T he applicant indicated the stubbed roads surrounding the project set up the location for the internal ring road and that there was 75 feet of relief across the site, which also sets up site constraints for development. The applicant stated that if they avoided the center wetland, the ring road connection and carefully designed retail hub, both integral components of the project, would be lost and there would not be enough m ass of uses or project synergy for the developm ent to serve as a regional lifestyle center. Attachment A K:\01694-860\Admin\Docs\2017_07_21 TEP Meeting Notes.docx Aug 1, 2017 Page 4 Status: T he applicant needs to supply a clear, concise avoidance and m inim ization argum ent in conform ance with W CA 8420.0520 Subp 3-Subp 6 and based on the Revised Table 2, discussion at the T EP m eeting, and the changes in the proposed wetland im pacts . 3. Secondary Impacts: The inform ation supplied does not provide sufficient evidence that secondar y h ydrolog y im pacts would not occur to onsite W etland 3 and to the downstream wetland mitigation areas (W SB m em o dated May 1, 2017). New Note: As part of the TEP reviewing these m eeting notes, since W etland 4 is now proposed to not be im pacted, analysis of secondar y im pacts also needs to be provided for W etland 4. At the m eeting, the applicant provided a quick overview of the additional storm water anal ysis and design that they will be submitting to the Cit y. This inclu ded pervious pavem ent, rock beds, and rainwater capture s ystem s. Status: T he applicant will need to subm it the new storm water anal ysis and m odeling to the Cit y for review as part of the W CA process, including analysis of secondary im pacts to W etlands 3 and 4 and downstream m itigation areas . 4. M itigation: T he applicant is currently proposing wetland m itigation through the purchase of wetland credits within banks located in Blue Earth, Stevens, and Rice Counties. The TEP asked if there were other bank s located within the Carver or Hennepin County or closer to the project. Melissa indicated there were not when she was looking for credit. The City discussed that if sequencing and secondar y im pacts can be evaluated, that wetland m itigation could be accom plished through the purchase of the wetland credits at a 2:1 ratio as proposed, as well com pletion of a wetland im provem ent project within the city. This in-cit y project could com e in the form of an actual project or b y securing funds from the applicant for a future project to be com pleted by the cit y when a suitable location is determ ined. The TEP discussed this m itigation strategy and concluded that (pending justification of avoidance and m inim ization) purchase of credits at a 2:1 would meet the W CA. The TEP was silent on the need for further replacem ent of lost functions and values within the watershed and indicated this would be for the LGU to determ ine. The LGU determ ined that while the purchase of credits m eets the 2:1 requirem ent of replacem ent, it does not replace the lost functions and values within the imm ediate watershed. The project is within the headwaters of Bluff Creek and Lake Susan, which are im paired waters. Recognizing there is not currently a good location to complete a project in the watershed to replace lost functions and values, the LGU has determ ined that securing funds from the applicant for an in-city project to be c onducted at a future date would m eet the need to replace lost functions and values in the watershed. The group discussed that this future project would not need to m eet W CA wetland design or perform ance standards, but rather work to provide general habitat and water treatm ent functions. Status: No additional inform ation from the applicant is needed. 5. Housekeeping Items: A f ew housekeeping item s with the application were discussed. Status: T he applicant needs to provide written docum entation and current site plan showing the accurate wetland im pacts. These m eeting notes reflect the LGU’s recollection of the m eeting and have been reviewed b y the TEP and City staff. If you have questions or changes, please contact m e within one week of the date of this m em o to discuss additions or corrections at 763-287-7196 or am offatt@wsbeng.com . Attachment A Avienda, Chanhassen Attachment B 1 Response to the TEP’s request for information “responding to the requirements of Minnesota Rules 8420.0520 Subp 3-Subp 6, including reference to the Revised Table 2, discussion at the TEP meeting, and the changes in the proposed wetland impacts.” Avienda provided information on avoidance and sequencing in its March 2017 application, its June 2017 submittal subsequent communications. We provide this supplemental information in response to the TEP request. 8420.0520 SEQUENCING Subp. 3. Impact avoidance. Subp. 3.A. Avoidance is required when indicated by part 8420.0515. RESPONSE: This subpart of Minnesota rules first requires a determination of whether avoidance is required based on consideration of “Special Considerations” as described in Minnesota Rules 8420.0515. None of those Special Conditions arise from the project so avoidance is not required. Subp. 3.B. Wetland dependence determination: RESPONSE: This subpart of Minnesota rules first requires a determination of whether the Avienda project is wetland dependent. The Avienda project is not wetland dependent. Subp. 3.C. Alternatives analysis: The alternatives analysis is used as the basis of the local government unit’s determination of “whether any proposed feasible and prudent alternatives are available that would avoid impacts to wetland.” If such an alternative is not available in light of the Basic Project Purpose, the LGU must evaluate the replacement plan’s compliance with the impact minimization requirements in Subpart 4. This one sentence description of the Basic Project Purpose was included in Section 2.1 of the application that was deemed complete on March 14, 2017: To provide a viable mixed use Regional/Lifestyle Center within the City of Chanhassen that will meet local and regional demand and need for the provided uses and implement the City’s vision and intent for property based on the current land use guidance plan. Subsequent sections defined “Mixed Use Lifestyle Centers” (Section 2.2), described the City of Chanhassen Mixed Use Regional/Lifestyle Need (Section 2.3) and the Geographic Area of review (Section 2.4). A more detailed Basic Project Purpose is included in Section 5.1 of the application: Creating a viable project that will meet Project Purpose and Need requires that the project design be driven by project scope and City vision considerations while meeting other applicable environmental regulations. The Avienda project plan must meet all of Avienda, Chanhassen Attachment B 2 the following goals and requirements to be considered feasible and prudent, and well as reasonable and practicable. 1. Provide a mixed use development within the City of Chanhassen of community and regional scale integrated with retail and business uses to serve local residents and a regional market; 2. Provide housing alternatives for all stages of life; 3. Create a pattern of land uses that are compatible and supportive by providing a mix of cultural, employment, entertainment, housing, shopping, and social components; 4. Provide a development design that serves pedestrian/walking use, mass transit use, and automobile traffic with vehicle and pedestrian access that is coordinated and logically linked to provide a comprehensive circulation system including a pedestrian promenade; 5. Create a layout design that is planned as a group of organized uses and structures to accommodate a sensitive transition between uses of commercial and residential and to share parking; 6. Connect all structures and spaces with compatible pedestrian walkways, sidewalks, and trails and provide connections to existing pedestrian walkways and corridors; 7. Provide effective drainage for the overall site while capturing and treating stormwater runoff in a manner consistent with local, state, and federal standards (see Stormwater Requirements description on the following page); 8. Be consistent with the updated AUAR. The City is currently updating the AUAR, which will reflect the proposed development plan. The AUAR update is expected to be completed in early 2017. 9. Be sensitive to environmental features (topography, vegetation, wetlands, scenic views); 10. Avoid and minimize alteration to the Bluff Creek Overlay District bluff area, high quality woodland, and cultural resources; 11. Avoid and minimize direct and indirect impacts on wetlands and water resources to the extent practicable; 12. Maintain the ecological and hydrological characteristics of remaining wetlands (see City Code Requirements on the following page); 13. Replace unavoidable wetland impacts with compensatory wetland mitigation that has wetland functions equal to or exceeding those of the impacted wetlands; and 14. Designate/establish buffers adjacent to avoided wetlands, and establish easements over the remaining wetlands, wetland buffers, and avoided/preserved areas of the Bluff Creek Overlay District to ensure their long-term viability and protection. Avienda, Chanhassen Attachment B 3 In addition, the Avienda Basic Project Purpose is detailed in the Memorandum to the U.S. Army Corps of Engineers dated June 5, 2017 that is was previously submitted to the City. (“USACE Memorandum”). That document contains important information describing why creating a viable mixed use Regional/Lifestyle Center is the Basic Project Purpose and why the individual project components must be correctly arranged to create a viable mixed use Regional/Lifestyle Center. Page 4 of that document states that “This project provides this opportunity for this diverse mix of uses in a high- quality lifestyle center. Lifestyle centers create a lifestyle experience, rather than a simple shopping experience, for customers though creation of a main street in the center of the project with places to dine, converge and socialize.” An understanding of what constitutes a (1) mixed use, (2) regional, (3) lifestyle center is essential to evaluating whether the alternative meets the project purpose.  Mixed use is described throughout the McComb Alternatives Evaluation Memorandum included in the June 5 supplemental information packet. (Paraphrasing) along with the anchor stores, smaller retail stores, and food services provided by the traditional shopping center/regional mall, the MIXED USE regional lifestyle centers incorporate medical, office, hotels, and residential uses in a coordinated development, integrated on one site, located in close proximity to facilitate continent pedestrian circulation (i.e., walkable environment). The primary draw/focus of the mixed use regional LIFESTYLE CENTER continues to be the centrally located retail hub which is an integrated shopping center with a “main street” or central village.  The scale of the project must be large enough to serve a REGIONAL market. The McComb Alternatives Evaluation Memorandum discussed the components within two examples of existing comparable mixed use regional lifestyle centers; West End and Arbor Lakes. Table 2-REV (provided on the following page) from the July 21, 2017 TEP meeting, provides a comparison of the size (i.e., developed area) of the proposed project to the size of other mixed use regional lifestyle centers. The proposed project is smaller than any other comparable project. Due to the smaller overall size, the internal layout of Avienda, specifically the internal layout of the retail hub (central focus of the project), is critical for project success. The retail hub is the “main street in the center of the project” critical to the Avienda Basic Project Purpose. The Avienda project as a whole and the Retail Hub area are significantly Avienda, Chanhassen Attachment B 4 smaller than other Regional Lifestyle Centers as shown in the revised Table 2 below that was discussed in the last TEP meeting: Table 2-REV. Comparison of Avienda with Other Regional Lifestyle Centers Development Develope d Area (sf) * Retail Hub (sf) Total Retail (sf)* Avienda Preferred 1,115,200 167,000 405,000 Avienda Minimized 675,000 0 194,000 Avienda Avoid 468,000 0 128,000 Galleria 6,000,000 417,000 3,000,000 Shoppes at Arbor Lakes 3,500,000 391,151 2,000,000 Woodbury Lakes 2,000,000 318,853 1,500,000 West End 3,000,000 348,541 950,000 Central Park Commons 2,000,000 434,000 1,200,000 City Place Unknown 170,000 Unknown * Indicates estimated values The Memorandum to the U.S. Army Corps of Engineers dated June 5, 2017 includes in Exhibit G a memorandum from the McComb Group evaluating alternatives in light of the Basic Project Purpose. Subp. 3.C(1) In addition to documentation for the proposed project, the applicant must provide the local government unit with documentation describing at least two alternatives that avoid wetland impacts, one of which may be the no-build alternative. RESPONSE – Complete Avoidance Alternatives – No Build Alternative – The applicant fulfilled the requirement of providing alternatives in its submittals. The alternate project configurations provided in the Wetland Permit Application by the applicant were good faith efforts that included illustrations of the type/scope of project that would completely avoid wetland impacts (Section 5.3, Figure 7). Avienda provided the no build alternative as well as other alternatives that “include consideration of alternate sites or alternative project configurations on the proposed site” as provided for in the rule. The No Build Alternative was provided in Section 5.2 of the Wetland Permit Application. Additional information regarding the No Build alternative was provided in the response to USACE Comment 5(d) of the June 5 supplemental information packet. Additional information regarding the No Build alternative was provided in the response to USACE Comment 5(d) in the USACE Memorandum, noting that the No Build Alternative: would not meet the project purpose and need which is a mixed use Regional/Lifestyle Center within the City of Chanhassen. This has been an identified need since 2008, and there have been multiple attempts to develop a viable site plan. The current project team has been working with the City for Avienda, Chanhassen Attachment B 5 over 2.5 years, and has developed a plan that meets both the City’s need/vision/rules, and is also a viable plan for the developer. The no build alternative is not a feasible and prudent alternative because it is inconsistent with the City of Chanhassen vision contained in the Comprehensive Plan and is therefore fails the test of whether “it is consistent with reasonable requirements of the public health, safety, and welfare.” The No Build Alternative does not result in a mixed use Regional/Lifestyle Center within the City of Chanhassen . RESPONSE – Complete Avoidance Alternatives – Complete Avoidance On-Site Alternative. The complete avoidance alternative was provided in Section 5.3 of the Wetland Permit Application (including Figure 7 and Appendix G in the Application). That Application information shows that the alternative fails the test of “whether reasonable modification of the size, scope, configuration, or density of the project would avoid impacts to wetlands.” That analysis concludes the required modifications are not reasonable because: 1. The layout lacks a contiguous, flowing traffic system in which to circulate traffic as required by the City. 2. Office uses are physically separated and visually distanced from retail uses by the avoidance of Wetlands 1 and 2. Anchor retail/entertainment/hospitality is visually distanced from specialty retail by avoidance of Wetland 5. Avoidance of Wetland 9 Avienda Mixed Use Regional/Lifestyle Center Wetland Permit Application physically separates retail uses. Disconnected and isolated uses eliminate project synergy. 3. Disconnected and isolated uses do not provide an inviting and comfortable “walking” environment as required by the City and necessary for project viability. 4. The avoidance design lacks sufficient component area as detailed in Table 7 below. Specifically, the site does not provide sufficient components of retail hub, anchor retail/hospitality, or residential services/uses as required to meet Project Purpose and Need. 5. This alternative does not meet the use diversity/make-up requirements of the proposed PUD. The McComb Alternatives Evaluation includes an assessment of the Complete Avoidance Alternative beginning on page 10 of that document. The analysis concludes that the alternative “is not feasible,” “does not represent a regional lifestyle center in scope, design, or size” and “is not consistent with the City of Chanhassen vision contained in the Comprehensive Plan.” The complete avoidance alternative is not a feasible and prudent alternative because it is inconsistent with the City of Chanhassen vision contained in the Comprehensive Plan Avienda, Chanhassen Attachment B 6 and therefore fails the test of whether “it is consistent with reasonable requirements of the public health, safety, and welfare.” In addition, the alternative is not a feasible and prudent alternative available to avoid impacts to wetlands because it fails the test of “whether reasonable modification of the size, scope, configuration, or density of the project would avoid impacts to wetlands.” The modifications of the “size, scope and configuration or density” required to create the complete avoidance alternative are not reasonable because the resulting project would not achieve the Basic Project Purpose and would result in a project that, according to the McCombs alternative memorandum, is “not feasible” and inconsistent with the City’s vision. RESPONSE – Complete Avoidance Alternatives – Alternative Sites. Section 2.4 of the Wetland Permit application describes the geographic area of review for alternative sites: The City of Chanhassen 2030 Comprehensive Plan identifies the need for a mixed-use regional lifestyle center within the City limits to service the existing and rapidly increasing population within this overall rapid growth, yet underserved, area of the southwest Twin Cities Metro. Undeveloped sites outside the City of Chanhassen were not explored for project feasibility or practicability as they failed to meet the stated Project Purpose and Need. Cities to the north and east are already highly developed with little to no large-tracts of appropriate, undeveloped land remaining. Cities to the west and south have yet to demonstrate the need or market support for the proposed project. The defined geographic area of the City of Chanhassen for a mixed-use regional lifestyle center is therefore appropriate and consistent with local planning and need. An analysis of alternative sites was provided in Section 3 of the Wetland Permit Application. Each of those sites contain significant wetlands and, as the analysis shows, each fails the test of whether an alternative site “is an environmentally preferable alternative based on a review of social, economic, and environmental impacts.” Subp. 3.C(1) For projects that repair or rehabilitate existing infrastructure, only one alternative is required. The alternatives may include consideration of alternate sites or alternative project configurations on the proposed site. RESPONSE - The project does not “repair or rehabilitate existing infrastructure. Subp. 3.C(1) (continued) The alternatives must be judged by the local government unit as good faith efforts, or the local government unit may require the applicant to redraft them for reconsideration. RESPONSE - The alternate project configurations provided in the Wetland Permit Application by the applicant are good faith efforts that illustrated the type/tenant mix/layout/ scope/scale of projects that would completely avoid (Avoidance Alternative #2; Section 5.3, Figure 7). As noted in the minimization discussion below, the applicant also provided good faith alternatives to minimize (Section 5.4, Figure 8) wetland impacts. Knowing that the impacts under primary focus/scrutiny were those to Wetland Avienda, Chanhassen Attachment B 7 1, Wetland 2, and Wetland 1/2 (henceforth referred to as Wetland 1/2) (due to overall wetland size), the avoidance and minimization alternate project configurations both showed avoidance to Wetland 1/2. Subp. 3.C (2) The local government unit must determine whether any proposed feasible and prudent alternatives are available that would avoid impacts to wetlands. An alternative is considered feasible and prudent if it meets all of the following requirements: (a) it is capable of being done from an engineering point of view; (b) it is in accordance with accepted engineering standards and practices; (c) it is consistent with reasonable requirements of the public health, safety, and welfare; (d) it is an environmentally preferable alternative based on a review of social, economic, and environmental impacts; and (e) it would create no truly unusual problems. Response: No feasible and prudent alternatives are available that would avoid impacts to wetlands. The applicant submitted several alternatives, each of which was submitted because it might be “capable of being done from an engineering point of view . . .in accordance with accepted engineering standards and practices.” Those alternatives were then evaluated to determine if any alternative is an environmentally preferable alternative based on a review of social, economic, and environmental impacts.” o Six other alternative sites within the City of Chanhassen were explored for project feasibly in Section 3 of the Wetland Permit Application. Two of the six sites were found to be potentially practicable alternative sites. While it is understood that the “LEDPA” determination is specific to the Army Corps of Engineers Section 404 process, the underlying analysis is applicable to the City’s action. It was concluded that: “locating the project on the Proposed Site (Applicant’s Preferred) … is the Least Environmentally Damaging Practicable Alternative (LEDPA) that will meet the Applicant’s stated Project Purpose and Need. There are no alternative sites where a viable project could be located that do not affect special aquatic sites, and locating the project on other potentially practicable alternative sites would have more adverse impact on aquatic ecosystems and other environmental factors.” o The proposed alternative is the environmentally preferred alternative because, although it results in wetland impacts, it avoids impact to other onsite locally identified high priority resources (based on City rules and policy) of BCOD woodland, bluff slopes, and cultural resources, o Furthermore, the alternative sites analysis (Section 3 of the Wetland Permit Application) concluded that there are no other single sites or conglomeration of adjacent sites within the city of Chanhassen that provide 90+ acres of contiguous developable land AND result in less impact to wetlands and other natural resources. This is supportive of the proposed site as the most environmentally appropriate site within the geographic area of review for this single and complete project. Subp. 3.C(3) The local government unit must consider the following in evaluating avoidance alternatives as applicable: Avienda, Chanhassen Attachment B 8 (a) whether the basic project purpose can be reasonably accomplished using one or more other sites in the same general area that would avoid wetland impacts. An alternate site must not be excluded from consideration only because it includes or requires an area not owned by the applicant that could reasonably be obtained, used, expanded, or managed to fulfill the basic purpose of the proposed project; (b) the general suitability of the project site and alternate sites considered by the applicant to achieve the purpose of the project; (c) whether reasonable modification of the size, scope, configuration, or density of the project would avoid impacts to wetlands; (d) efforts by the applicant to accommodate or remove constraints on alternatives imposed by zoning standards or infrastructure, including requests for conditional use permits, variances, or planned unit developments; (e) the physical, economic, and demographic requirements of the project. Economic considerations alone do not make an alternative not feasible and prudent; and (f) the amount, distribution, condition, and public value of wetlands and associated resources to be affected by the project and the potential for direct and indirect effects over time. RESPONSE –As described above, no feasible and prudent alternatives are available that would avoid impacts to wetlands. The information provided by the applicant shows: o The basic project purpose cannot be reasonably accomplished “using one or more other sites in the same general area that would avoid wetland impacts”. The proposed project is a single and complete project. Using more than one site in the same general area would not meet the definition of a mixed use regional lifestyle center – which is a centrally located group of organized and compatible uses and structures (i.e., the retail hub/lifestyle center), surrounded by mixed supporting uses (i.e., housing, office, retail, grocery, hotel, entertainment) that are regional (i.e., large) in scale. Mixed use lifestyle centers and City if Chanhassen mixed use regional/lifestyle center requirements were described in Sections 2.2 and 3.1 of the Wetland Permit Application. Using more sites is not a feasible or prudent wetland avoidance alternative for the proposed project. In addition, as noted above the alternative sites would not “avoid” wetland impacts. o The materials supplied by Avienda are more than sufficient to allow the LGU assess “the general suitability of the project site and alternate sites considered by the applicant to achieve the purpose of the project.” The project site is specifically guided for the “purpose of the project”, which is described above. The applicant provided information describing potential alternative sites and detailed information and analysis showing that no alternative site is preferable and that the project site is suitable for project. o The modifications of the “size, scope, configuration, or density of the project” necessary to avoid impacts to wetlands are not reasonable because, as described in detail in this Avienda, Chanhassen Attachment B 9 document and the applicant’s submittals, they would result in project configurations that do not meet the Basic Project Purpose. Based on the needs of the City and surrounding cities, the proposed project is regional in scale. A reduction in project scale would not meet the project purpose of a mixed use regional lifestyle center, or satisfy the need for the project. o The city is very aware that Avienda has made significant efforts to “accommodate or remove constraints on alternatives imposed by zoning standards or infrastructure, including requests for conditional use permits, variances, or planned unit developments”. There is no other site/parcel/conglomeration of parcels within the City or straddling City limits (under private ownership and without considerable shoreland) that could accommodate the proposed project as demonstrated in the alternative sites analysis; therefore, this is the only parcel within the City of Chanhassen that is undeveloped, large enough, and can be re-zoned to Regional/Commercial to accommodate the proposed project. The project plan was developed under a PUD which allows for the project to meet overall density and land use goals without being bound by standard zoning requirements. Any parcel within the City of Chanhassen could be developed under a PUD, no matter the zoning. However, as stated in City Code Sec. 20-502 – Allowed Uses (1) Each PUD shall only be used for the use or uses for which the site is designated in the comprehensive plan. For this site, the PUD use must follow City Code Sec. 20-509 – Standards and guidelines for regional/lifestyle center commercial planned unit developments. Site constraints are illustrated in Figure 1. A variance to impact a portion of the BCOD for the high-density housing component was rejected by the City. The City will not allow impacts to the BCOD. A use transition that includes high and medium density housing is required by the City in the west portion of the site, adjacent to single-family housing. A comprehensive, circulating traffic system (Bluff Creek Boulevard extension and connection to Powers Boulevard) is required by the City. These site constraints cannot be removed. The site will be developed under a PUD which will allow for the project to meet overall density and land use goals without being bound by standard zoning requirements. The proposed plan which represents a mixed use regional lifestyle center meets these standards and guidelines. The avoidance (and minimization) alternatives do not represent a mixed use regional lifestyle center and therefore they do not meet these standards and guidelines. o The applicant has provided extremely thorough data and analysis that together describe the “the physical, economic, and demographic requirements” to build a viable mixed- use Regional/Lifestyle Center within the City of Chanhassen. Integral to site design is the centrally located retail hub and its internal layout. Any wetland avoidance alternative would require elimination of the retail hub (i.e., the lifestyle center) which is the central focus of the project (i.e., the most important project component) and would make the project unviable/infeasible. Avienda, Chanhassen Attachment B 10 The physical requirements of the project were presented in Section 3.2 of the Wetland Permit Application. Of primary importance was a project location wholly or partially within the City of Chanhassen. Second to location was a tract of contiguous land 90+ acres in size, which was based on the information present in Section 3.1 of the Wetland Permit Application. The table Development Area Computation – Regional Lifestyle Center included in the submittal to the Corps and also reproduced below itemizes mixed use regional lifestyle center components and their standard areas and supports the Wetland Permit Application determination that the project must occur on a tract of contiguous land 90+ acres in size. Information on the contiguous nature of the project has been provided in detail. Furthermore, the alternative sites analysis concluded that there are no other single sites or conglomeration of adjacent sites within the city of Chanhassen that provide 90+ acres of contiguous developable land AND would result in less impact to wetlands and other natural resources with development of the proposed project. Due to site constraints of: (1) City mandated Bluff Creek Overly District (BCOD) avoidance, (2) City mandated transitional housing buffer, and (3) City mandated Bluff Creek Boulevard extension and connection to Powers Boulevard, the retail hub cannot be repositioned within the site to avoid impact to Wetland 1/2 (Figure 1 on the following page).The size/location/internal layout of the retail hub cannot be reduced to avoid impacts to Wetland 1/2. Based on the needs of the City and surrounding cities, the proposed project is regional in scale. A reduction in project scale would not meet the project purpose of a mixed use regional lifestyle center, or satisfy the need for the project. Market/retail studies (submitted previously) confirm that the proposed project will be supported by the economic and demographic characteristics of the local and regional population. o The materials supplied by Avienda are more than sufficient to allow the LGU “to consider the amount, distribution, condition, and public value of wetlands and associated resources to be affected by the project and the potential for direct and indirect effects over time.” The amount, distribution, condition, and public value of Figure 1 - Updated Project Layout Illustrating Existing Wetland Boundaries and Associated Buffer with Avoidance Avienda Village (KES 2015-130)Chanhassen, Minnesota Note: Boundaries indicated on this figureare approximate and do not constitute an official survey product. ¯0 500 Feet Site Boun dary Wetlan ds Wetlan d Bu ffer (40-ft) WL6 WL2 WL1/2 WL1 WL8 WL7 WL5 WL9 WL3 WL4 WL10 Avienda, Chanhassen Attachment B 11 wetlands on this site is low, especially when compared to potentially available alternative sites. The majority of the site (and associated wetlands) has been degraded by farming. The largest wetland on the site has been altered by excavation and degraded by untreated agricultural runoff and sediments. Ecologically significant area on the site is restricted to within the BCOD woodland – which will be completely avoided. Development of the site will result in permanent protection of the BCOD, and a reduction in indirect effects to remaining wetlands by the elimination of agricultural runoff/sediment and the implementation of a stormwater management plan. The stormwater management plan - which will meet City anti-degradation rules - will also benefit downstream water resources, specifically Lake Susan (impaired water). With site development, all impervious runoff leaving the site will meet City local, state and federal water quality standards. (Discussion on future potential direct or indirect effects to the wetland hydrology of Wetland 3, Wetland 4, Wetland 6, and adjacent MnDOT wetlands with project development is provided in the accompanying memo.) Subp. 3.C (4) If the local government unit determines that a feasible and prudent alternative exists that would avoid impacts to wetlands, it must deny the replacement plan. If no feasible and prudent alternative is available that would avoid impacts to wetlands, the local government unit must evaluate the replacement plan for compliance with subparts 4 to 8. CONCLUSION - Per the analysis presented previously and in the other materials submitted to the LGU, there are no feasible and prudent alternatives available that would avoid impacts to wetlands. Subp. 4. Impact minimization. The applicant shall demonstrate to the local government unit's satisfaction that the activity will minimize impacts to wetlands. In reviewing the sufficiency of the applicant's proposal to minimize wetland impacts, the local government unit must consider all of the following: A. the spatial requirements of the project; RESPONSE – The applicant supplied sufficient information to the City to allow the TEP to fully consider this factor. The regional scale of the project was discussed in the response above to the avoidance requirements of Subp.3.C(3)(c). The regional project footprint requirement of 90+ contiguous acres of developable land was discussed in the response above to the avoidance requirements of Subp.3.C(3)(e). B. the location of existing structural or natural features that may dictate the placement or configuration of the project; Avienda, Chanhassen Attachment B 12 RESPONSE - The applicant supplied sufficient information to the City to allow the TEP to fully consider this factor. The requirements for the project to avoid existing BCOD, extend Bluff Creek Boulevard through the site, and provide a housing transition zone - all of which affect the spatial location of available developable area - was discussed in the response above to the avoidance requirements of Subp.3.C(3)(d). C. the purpose of the project and how the purpose relates to placement, configuration, or density; RESPONSE - The applicant supplied sufficient information to the City to allow the TEP to fully consider this factor. The purpose of the project as well as the density/scale/regionality of the project was discussed in was discussed in the response above to the avoidance requirements of Subp.3.C.(3)(a). Constraints on the placement and configuration of the project layout within the site was discussed in the response above to the avoidance requirements of Subp.3.C.(2). The primary focus of the site design is the centrally located retail hub which creates the draw for the project. The retail hub attracts the small store/specialty comparison shopping base critical for a regional draw. These shop owners know that they could not exist on their own, and the shops constituting the desired tenant mix will only locate in an environment where they will all agree to locate, and therefore survive. The retail hub is a very carefully designed project component. The number, size, and mix of tenants are all very carefully thought through, and even building and individual parking space orientations are considered in the efficacy of the design. The lifestyle center/retail hub footprint is 25 acres which includes buildings with appropriate spacing, internal roadways, parking space, and open/landscaping space. Due to City mandated site constraints, this footprint is smaller than other comparable retail hub footprints. Key retail hub design components are: (1) the internal roadway connection from Bluff Creek Boulevard to Avienda Parkway, (2) the “main street village” with anchor retail at one end. This is a very common successful layout design for lifestyle centers. The current location, length/area/spacing, and orientation of the main street village is considered by retail experts to represent a successful main street village within a lifestyle center. Any wetland minimization alternative that minimizes impact to Wetland 1/2 by avoiding large portions of Wetland 1/2, would result in the elimination or substantial reduction in size of the main street village, negatively affecting its layout and function to such an extent that the desired tenant mix would no longer be interested in locating at this site, and the project would not move forward due to a lack of interested businesses. D. the sensitivity of the site design to the natural features of the site, including topography, hydrology, and existing vegetation; RESPONSE - The applicant supplied sufficient information to the City to allow the TEP to fully consider this factor. The majority of the site is comprised of annually tilled agricultural land and topography will be altered with runoff incorporated into the stormwater management plan. The site design prioritizes avoidance of the BCOD woodland, bluff slopes, and cultural resources. Avienda, Chanhassen Attachment B 13 Section 3.5 of the Wetland Permit Application compares multiple environmental factors on the proposed site with those on potentially practicable alternative sites, with the finding that development of the proposed site will result in the least impact to aquatic resources and other environmental factors such as: waterways, wetlands, wetland functions, BCOD, cultural resources, water quality, viewshed impacts, and disturbance to perennial vegetation cover. E. the value, function, and spatial distribution of the wetlands on the site; RESPONSE - The applicant supplied sufficient information to the City to allow the TEP to fully consider this factor. Wetland characteristics and spatial distribution were described and illustrated in Section 4.2 of the Wetland Permit Application. Generally, wetlands are located at different elevations and are scattered throughout the site (Figure 3 of the Wetland Permit Application). Wetland functions and values were evaluated in Section 4.3 of the Wetland Permit Application. The only wetland of above “Medium” quality was Wetland 10 (rated as Preserve/Exceptional) located in the southwest part of the BCOD. The primary focus of project impacts, Wetland 1/2 due to its large size, was rated as a Manage 2/Medium quality wetland for its highest rated function of Low for amphibian habitat. The most beneficial function of Wetland 1/2 may be its storage and filtering of untreated agricultural chemical runoff and storage. With site development, this function will replaced/met by the stormwater management plan (and the site will no longer discharge untreated agricultural runoff). F. individual and cumulative impacts; and RESPONSE - The applicant supplied sufficient information to the City to allow the TEP to fully consider this factor. Discussion on future potential direct or indirect effects to the wetland hydrology of Wetland 3, Wetland 4, Wetland 6, and adjacent MnDOT wetlands with project development is provided in the Draft Stormwater management Plan dated 10-6-2017 submitted to the City.. G. an applicant's efforts to: (1) modify the size, scope, configuration, or density of the project; (2) remove or accommodate site constraints including zoning, infrastructure, access, or natural features; (3) confine impacts to the fringe or periphery of the wetland; and (4) otherwise minimize impacts. RESPONSE - The applicant supplied sufficient information to the City to allow the TEP to fully consider this factor. Item 1 was previously discussed in the responses above to the avoidance requirements of Subp.3.C.(3)(a) and Subp.4.D. Item 2 was previously discussed in the response above to the avoidance requirements of Subp.3.C.(3)(d). Items 3 and 4 – Because the entire areas of Wetland 1/2, 5, 7, 8, and 9 are proposed for impact, confining impacts to the fringe or periphery of the wetland is not feasible. This was discussed in Section 5.7 of the Wetland Permit Application. It should be noted that since the Wetland Permit Application was submitted, the plan has been modified to eliminate impacts to Wetland 4. Also, impacts to Wetland 6 have been reduced to the outer (periphery) swale portions (See Figure A of accompanying memo). Subp. 5. Impact rectification. Temporary impacts must be rectified by repairing, rehabilitating, or restoring the affected wetland according to the no-loss provisions of part 8420.0415, item H. Avienda, Chanhassen Attachment B 14 RESPONSE - No temporary impacts to wetlands are proposed. Impact rectification does not apply (Section 5.8 of the Wetland Permit Application). Subp. 6. Reduction or elimination of impacts over time. After an activity is completed, further impacts must be reduced or eliminated by maintaining, operating, and managing the project in a manner that preserves and maintains remaining wetland functions. The local government unit must require applicants to implement best management practices to protect wetland functions. RESPONSE - The applicant supplied sufficient information to the City to allow the TEP to fully consider this factor. See Section 5.9 of the Wetland Permit Application. Also see discussion regarding potential impacts to avoided and offsite wetland provided in the accompanying memo. 4820-6606-9329, v. 1 Figures (See following pages) Figure A - Updated Project Layout with Wetland Impacts Avienda Village (KES 2015-130)Chanhassen, Minnesota Note: Boundaries indicated on this figureare approximate and do not constitute an official survey product. ¯0 1,000 Feet Wetland Fill Wetland Excavation WL6 WL2 WL1/2 WL1 WL8 WL7 WL5 WL9 WL3 WL4 WL10 Avienda Mixed Use Regional/Lifestyle Center (KES 2015-130)Chanhassen, Minnesota Note: Boundaries indicatedon this figure are approximate and do not constitute an official survey product. ¯ Source: MnGeo, ESRI Imagery Basemap Post-dev~915-ft mslPost-dev~915-ft msl Existing and post-dev~886-890-ft msl Existing~890-896-ft mslExisting~890-892-ft msl Figure B1 - Wetland 6 Minimized Impact 92 2 924 9 2 6 920928918916914 912 910 908 906 930932934 936904 902 900 898 896 894892 890 888 886 938 940 942 944 8 8 4 946932 936 88 4 930 940 926920 912 930938940 936 938922928934934 936 896 916 940 914 932 9369 3 4 934 924918 938 9 4 2 Figure B2 - Wetland 6 Existing Conditions Avienda Mixed Use Regional/Lifestyle Center (KES 2015-130)Chanhassen, Minnesota Note: Boundaries indicatedon this figure are approximate and do not constitute an official survey product. ¯0 150 Feet Legend Proposed Site Carver County Lidar Wetlands Intermittent Drainageway Source: MnGeo, ESRI Imagery Basemap Wetland 640.7816 Acres 910 912 908904 906 896902900 898914916918920922 924926 894928 892890888 886884882930 880932 878934 876 936 874872938 87 0 940942868 944 946 866932 930928 920926 874926 9 0 0934 8729 2 4 93 2 934918932924872 930 934 9 0 2 938 936 910870938910 92 8 914930 88 4 914 9169289308749 2 2 924926 936Figure C - Wetland 4 Post Development Conditions Avienda Mixed Use Regional/Lifestyle Center (KES 2015-130)Chanhassen, Minnesota Note: Boundaries indicatedon this figure are approximate and do not constitute an official survey product. ¯0 150 Feet Legend Proposed Site Intermittent Drainageway Carver County Lidar - Existing Wetlands Source: MnGeo, ESRI Imagery Basemap Wetland 40.13 Acres 922924926914 916918920928930932 91291 0 9 0 8 906904 9 3 4 902 900 936 898 896894938940942 892 944 890946 888922 93 2 918934 926 908 920 910928928922922 92 4 9 3 2 9129389 3 4 924922 934 9369 1 2 930 934930932 926 936922 930 926 93691 6 932 9049289249 2 4 934 930930 934 91 4914928 924 930934916918932 92 0 928 91092 4 90 6 9 0 2 Figure D - Wetland 3 Existing Conditions Avienda Mixed Use Regional/Lifestyle Center (KES 2015-130)Chanhassen, Minnesota Note: Boundaries indicatedon this figure are approximate and do not constitute an official survey product. ¯0 150 Feet Legend Proposed Site Carver County Lidar Wetland Estimate Wetlands Intermittent Drainageway Source: MnGeo, ESRI Imagery Basemap Wetland 31.30 Acres