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• Activity 4.1a: Explain the need for reclassifying wetlands and for conducting a function and value <br />assessment on all wetlands in consideration that the plan does not prioritize any one wetland <br />function over another. See also comments for 5.0 Management Standards, page 100 above. <br />• Goal 5.1: list the authorities the WMO has in regards to managing recreational activities. <br />• Activity 5.2a: provide more detail on the shoreline management study as to when and where <br />the study will be implemented, what the study will entail, and how the study will be funded. <br />Additionally, the second part of this activity is redundant with 5.2b. <br />• 6.3.6 Education and Public Involvement: Move and consolidate redundant education goals and <br />activities identified throughout this chapter to this section and include an activity to develop an <br />overarching education and outreach plan with clear and specific goals and strategies. <br />Additionally, we question whether the funds allocated in Chapter 7 are sufficient to successfully <br />implement the number of education and outreach activities identified throughout this chapter. <br />• Activity 6.3d: provide reference to where the 'benchmarks the GLWMO is working to achieve' <br />can be found. <br />• Activity 6.3e: becoming a Blue Thumb partner is not 'no cost' as identified in the <br />implementation plan table; it does require a donation of money or time. <br />• Activity 7.2a: explain how the WMO will ensure staff of other government units will attend <br />training. <br />• Activity 7.2e: clarify if the WMO is expecting the cities to update their ordinances to ensure the <br />activities described here will occur as well as provide a timeline for implementation of the <br />activities. <br />• 6.3.8 GLWMO Standards and Criteria: this section blends standards, which aren't all regulatory, <br />with regulation and requires consistency with WMO goals, policies, and objectives; though <br />neither policies nor objectives are identified elsewhere in the plan. Additionally, applicability <br />and design guidelines for standards should have been discussed as part of plan development <br />and clearly included in the plan. Finally, 8.1a and table 33 both reference 'rule'— does the WMO <br />intend to develop rules at some point? <br />• 6.3.9 Evaluation and Accountability: we suggest incorporating goals and activities to evaluate <br />the performance of the GLWMO. See also comments on Page 148, Evaluation and <br />Accountability below. <br />• Activity 9.2a: suggest correlating this activity with a process to set annual goals as well as <br />incorporating the results of these annual meetings into a transparent report. <br />• 6.3.10 Financing: to achieve taxing authority, the WMO would need to be recognized as a <br />special taxing district under MN Statutes §275.066 in addition to having the authority within the <br />J PA. <br />• Goal 10.3: programs and projects must be prioritized in this plan. <br />• Goal 11.1: include the criteria the WMO will use in this evaluation. <br />• Activity 11.4a and 11.4b: the second part of 11.4a appears somewhat redundant with 11.4b. <br />Include the protocols for determining cost - effectiveness in this plan. See also comments below <br />for page 148, Evaluation and Accountability. <br />• Activity 11.5a: in consideration of the training programs already available for the examples <br />provided, this activity seems in conflict with the goal to minimize duplication of effort. <br />7.0 Implementation Plan <br />Overall, the implementation plan is disappointing in its weight towards additional studies and planning, <br />few identified priorities, and lack of identification or targeting of structural practices. The chapter only <br />describes three programs; education, cost share, and monitoring; comprising less than 25% of the <br />Page 4of6 <br />