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RRRINERA W & W TEL :218-828-6043 Feb 17 '05 9 : 18 No .001 P .01 <br /> Minnesota Department of Natural Resources <br /> r w�4 M gDNR WATERS, 1601 MINNESOTA DRIVE,BRAINERD.MN 56401 <br /> 218/829-2605 <br /> February 16,2005 Po*W Fax Note 7671 F <br /> Tie <br /> CoJDOPL Co. <br /> Tom Woog,Chairman, Planning Commission P114e414 Phone# 7 <br /> Pequot Lakes City Hall Fax# <br /> 4638 County Road 1 I FM <br /> Pcquot Lakes, MN 56472 <br /> Dear Chairman Woog: <br /> PROPOSED WILDERNESS POINT RESORT PUD,MIDDLE CULLEN LAKE(18377), CROW WING <br /> COUNTY <br /> I have reviewed the proposed plans and offer the following comments for your consideration. The purpose of <br /> my review is to evaluate the project for consistency With die State Shoreland Management Standards. <br /> The proposed development, which includes 55 individual unfits, is being presented as a`resort". Resorts are a <br /> form of "Commercial Planned Unit Development". The State Shoreland Standards, which the City has <br /> adopted,differentiates between commercial and residential PUDs based on tho following definitions: <br /> Subpart 3a, Commercial planned unit developmenos. <br /> "Commercial planned unit developments" are typically uses that provide transient, short-tern lodging <br /> spaces, room, or parcels and their operaticns are essentially service-oriented- For example, botcUmotel <br /> accommodations, resorts, recreational vehicle and camping parks, and other primarily service-oriented <br /> activitiLz are commercial planned unit developments." <br /> Subpart 13a. Residential planned unit devolopment. <br /> "Residential planned unit development"mcans a use where the nature of residency is noutransient and_ <br /> the major or primary focus of tix development is not service-oriented. For example, residential <br /> apartments, manufactured home parks,time-sliare condominiums,townhouses,cooperatives,and full fee. <br /> ownership residences would be considered as residential planned unit developments." <br /> Note that "resorts" are included in the definition of Commercial Planned Unit Development, yet there is no <br /> separate definition for`resort". Thus,in order to determine if a proposed project which is labeled as a`resort', <br /> qualifies as a Commercial Planned Unit Development, it must meet the two general requirements of this <br /> definition,which are(1)that it provides transient,short-term lodging spaces, rooms,or parcels,and(2)that the <br /> operation is essentially service oriented <br /> Further guidance as to what constitutes a commercial planner(unit development is found in the"Statement of <br /> Need and Reasonableness for the Proposed Revisions to Minnesota Rules, Part 61.20.2500- 6120.3900.'2 This <br /> was the supporting document which provides justification for the current shoreland Hiles. The following <br /> excerpt it found on Page 69 of this document: <br /> DNR Information:651-296-6157 • 1-888-646-6367 • T -651-296-5484 • 1-800-657-3929 <br /> An Nual Opportunity Employer Printed on Recycled Paper Containing a <br /> Who Values Diversity Minimum of 20%Post-Consumer Write <br />