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535 N. W.2d 384, 387 (Minn. App. 1995). In the Wolfson case, St. Paul tried to turn public parking lot into a right-hand turn lane. The Court ruled it lacked authority to do so, and as a result of its attempts, the ownership of the parking lot reverted back to the old owners. Roseville is attempting the same thing St. Paul was not allowed to do: take a public right-of- way specifically meant for one purpose and turn it into something else entirely. Roseville has no authority to do so. 2. People have long relied on the street to access their property. For my clients, this street is their only vehicle access to the back of their property. They have used this street for unloading groceries, unpacking after trips, vehicle storage, accessing lawn clipping and leaf bags, hauling gardening supplies, etc. One client has used this street since before Roseville was incorporated as a City. Some have health and mobility issues, and this street gives them their only realistic chance to access the back yard. Furthermore, a closer look at the maps above and you will see that there are three properties completely isolated with the only access via Wagner Street. Two of those properties are owned by Roseville, and have the designated address of 0 Wagner Street. One property is owned by two of my clients, and is also designated as 0 Wagner Street. If this Street were to be turned into a Pathway, my clients will completely lose the ability to access their property by vehicle. B. The negatives outweigh any potential benefit. The neighborhood is very much opposed to the project. I represent the owners of eight homes that will overlook this pathway. All of them vehemently opposed to the project. This Commission has so far heard from one other citizen on this project who was also vehemently opposed. The potential environmental degradation is a massive risk. I highlighted the environmental degradation such pathway would cause, running directly through a designated wetland. This wetland was one of only two in the entire Capital Region Watershed District to score in the "moderate" zone for plant life and macroinvertebrate in a recent CRWD study. (See attachments). The pathway proposed by Roseville runs the risk of knocking the wetland into the "poor" category by replacing plant life, natural vegetation, native soil, and healthy wetland with Class 5 and asphalt, displacing habitat for wildlife such as migratory birds. Yet, there remains little reason for adding this pathway. There already is access to this park, and this exact route is already open for the public to use. There is no benefit to disrupting the status quo. Dated: July 23, 2021 Anderson Law Group PLLC /s/ Matthew Anderson By: Matthew E. Anderson (ID#: 0397364) 1010 Dale St. N. St. Paul, MN 55117 Email: