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May 16, 2014 Dawn Bittner Pequot Lakes Zoning Administrator 4638 County Road 11 Pequot Lakes, MN 56472 Dear Ms. Bittner: Would you please share this information with the Planning Commission members, the City Planner, and the two City Council members present at last night's public hearing on the third amended CIC preliminary plat of Wilderness Resort Villas? It doesn't change the position of the Cullen Lakes Association as I expressed it last night. However, it will make me feel better regarding one of the comments made by Mr. Jeff Miller in response to one of the items I brought up and also regarding the lack of near shore aquatic vegetation shown on the plat. First, Mr. Miller stated the definition of a bluff has changed through the years, implying that the definition is different now than it was when the first plat map was prepared by Widseth Smith Nolting back in 2005. This is not true. The DNR's definition of a bluff has not changed since the current Shoreland Standards were adopted in 1989. The definition is and remains (language copied directly from the Shoreland Standards, bold print added by me): 6120.2500 DEFINITIONS. Subpart 1. Scope of terms, mandatory, distances. For the purpose of parts 6120.2500 to 6120.3900, certain terms or words used shall be interpreted as follows: the word "shall" is mandatory, not permissive. All distances, unless otherwise specified, shall be measured horizontally. Subp. I a. Accessory structure or facility.. "Accessory structure" or "facility" means any building or improvement subordinate to a principal use which, because of the nature of its use, can reasonably be located at or greater than normal structure setbacks. Subp. 1b. Bluff. "Bluff" means a topographic feature such as a hill,cliff,or embankment having all of the following characteristics: A. part or all of the feature is located in a shoreland area; B. the slope rises at least 25 feet above the ordinary high water level of the waterbody; C. the grade of the slope from the toe of the bluff to a point 25 feet or more above the ordinary high water level averages 30 percent or greater; and the slope must drain toward the waterbody. An area with an average slope of less than 18 percent over a distance for 50 feet or more shall not be considered part of the bluff. The area being referred to at last night's meeting may well not be a bluff. I have no way of knowing. My point is simply that what Mr. Miller stated is not true. He misled the Planning Commission.