Riley Purgatory Bluff Creek Watershed District Comment Letter
protect. manage. restore.
18681 Lake Drive East
Chanhassen, MN 55317
952-607-6512
www.rpbcwd.org
MEMORANDUM
TO: Bob Generous, Senior Planner
FROM: Terry Jeffery, Watershed Planning Manager
DATE: December 23, 2020
RE: Wetland Alteration Permit 2021-003
RPBCWD Comments
Thank you for the opportunity to comment on this proposed wetland alteration. We
received an application on December 18, 2020 and have not yet performed our review.
We will have comments specific to our rules later.
Chanhassen has a long history of wetland protection. Even prior to the Wetland
Conservation Act, the City of Chanhassen codified the protection of wetlands from
degradation with Article VI of Chapter 20 of Chanhassen City Code.
The stated goal and purpose of Article VI is to prevent “alteration and destruction of
wetlands... unless there is no feasible alternative.” [§20-401(b)] Clearly this constitutes
wetland alteration and there is a feasible alternative; leave the wetland as is.
Section 20-402 (3) states the purpose of the article is to “Require(ing) sound
management practices that will protect, conserve, maintain, enhance and improve the
functions and values of wetlands within the community.” Section 20-410 states that
when a wetland alteration is to be allowed the alteration must not have a “net adverse
effect on the ecological and hydrologic characteristics of the remaining wetland” and
“shall be located as to minimize the impact on vegetation.”
The proposed alteration will result in the loss of interspersion of plant communities and
the subsequent habitat provision. The excavation will result in the overall watershed
losing diversity and structure and instead will leave primarily type 5, open water wetlands.
Moreover, there is no restoration plan in place to address the plant community within the
excavated area. Nor is there any attempt to provide any habitat variability via undulation
of the excavated area. The proposal does little more than mimic a stormwater pond
rather than seek to improve the functions and values of a wetland.
Even were the City to allow it on private land, it is unclear how this meets the intent of
protecting this area in an outlot during the development of Fox Path to protect the
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wetland from alteration. Further, the plat of Fox Path utilized better site design to
minimize tree loss where feasible. This proposal will result in removal of up to 1.5 acre of
woodland.
To allow this to move forward is not in keeping with the stated goals of the Surface Water
Management Plan either. Whether the wetland is classified by the City of Chanhassen as
a Manage 1 or a Manage 2 wetland, this proposal is not in keeping with the stated
management strategy in Table 42 of Chapter V of the Surface Water Management Plan.
It is the District’s hope that you will consider the net impact that this will have on habitat
provision and deny this application as it alters and degrades the overall quality of the
wetland.