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33 <br /> <br />Tami Norgard- Managing Partner, Vogel Law Firm’ <br />I appreciate the opportunity to engage in this important and historic process. While another month <br />would bring us closer to a permittable levee alignment, the Task Force succeeded in identifying new <br />key features that significantly reduce impacts of the project for upstream entities and Minnesota while <br />retaining federal authorization. <br />The MNDNR's involvement provides a permitting advantage moving forward. While the original <br />project was not permitted for a variety of reasons, MNDNR now studied the options and identified <br />features, which should increase its understanding of the social and economic impacts of proposed <br />project modifications that were merely conceptual when suggested as the original permit was denied. <br />MNDNR now has a stronger basis on which to permit a new project, given the lack of or impact of <br />alternatives. <br />The Technical Team brought forth solutions that optimized numerous important factors; not just <br />minimizing the amount of floodplain removed, but also considering financial and social costs, <br />additional home buyouts and added risk to the communities. MNDNR should find an iteration similar <br />to 7A or 7C to be permittable. The permitability does not rise or fall on whether there is another <br />alternative that removes less floodplain acreage. The entire metro area is within a floodplain, so feature <br />selection is a precarious balancing act, identifying where to draw the lines of protection. The crucial <br />inquiry is how many homes and citizens should be protected, at what cost and at what burden to <br />upstream landowners. Either 7A or 7C represents a significant victory for Richland and Wilkin <br />Counties, and an enormous compromise of the Diversion Authority. <br />MNDNR should be reasonable in encouraging an affordable embankment alignment. Since 1900, <br />only 5 flood events would have impounded any water upstream with alignment 7C and 37 feet of <br />water through town. Most of that inundation would happen during spring flooding, resulting in little <br />or no impact on planting. This is not constant or regular flooding. <br />The Tech Team's optimizing of critical factors should be viewed favorably by MNDNR in permitting. <br />Implementing 7C and 37 feet through town, for example, distributes newly impacted upstream acreage <br />more equitably, with the ND/MN impacts split 45/55. In addition, the channel impacts over 8000 <br />acres, 95% of which is in ND. 7C reduces newly impacted acreage in Richland and Wilkin Counties <br />from 1124 and 1391 acres down to 337 and 239, respectively, mostly impacting low areas like creek <br />bottoms. 7C reduces the need to mitigate homes in Richland County from 3 to 2, and in Wilkin <br />County from 5 to 2. <br />The 7C and 37 feet through town option would be a significant compromise. 8000 less acres will be <br />protected in the metro in order to save 2700 acres upstream from having flood easements. 102 more <br />homes would be removed and metro families displaced in order to save 6 homes in Richland, Wilkin <br />and Clay counties. There will be more risk to thousands of city residents by sending 37' of water <br />through town, causing more pressure on levees and less freeboard in many areas. Further, this is only <br />100 year protection, which is a huge compromise since the 100 year protection levels have been