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• Mr. Jeff Smyser Page Two The avoidance alternatives discussion on pages 15 and 16 of the EAW is somewhat confusing. It is not clear whether the purpose of the discussion is to show compliance with Wetland Conservation Act requirements or with EAW process requirements. An EAW is an environmental information document to be used by the city, other units of government and interested parties to assess the potential for significant environmental effects. The "investment- backed expectations of the applicant" or "visibility [of the store] from I -35W" do not appear to be appropriate criteria for a decision on an EAW. If, however, an EIS were ordered on the proposed project, then an evaluation including economic impacts could be considered. Storm Water Runoff As noted in Item 8, this project would require the application for and issuance of a National Pollutant Discharge Elimination System General Storm Water Permit for Construction Activity. Projects that create more than one acre of new impervious surface require permanent wet sedimentation pond(s). In addition to complying with watershed and National Urban Runoff Program criteria, the pond must comply with MICA permit requirements. We strongly recommend that the developer /engineer look for every chance possible to infiltrate storm water. The major threat to the adjacent wetlands and lakes is the increased volume of storm water that will occur after this project is completed. Questions regarding the MPCA's storm water program requirements may be directed to Keith Cherryholmes at (651) 296 -6945. Thank you for the opportunity to review this project. This comment letter addresses matters of concern to MPCA staff reviewing the EAW and is submitted for consideration by the city of Lino Lakes, the responsible governmental unit, in deciding whether an EIS should be prepared on the project. It does not constitute approval by the MPCA of any or all elements of the project for the purpose of pending or future permit action(s) by the MPCA. We have attempted to identify and consult with interested program staff to identify the MPCA permits that may be required. Additional comments or requests for information may be submitted in the future to address specific issues related to the development of such permit(s). Ultimately, it is the responsibility of the project proposer to secure any required permits and to comply with any requisite permit conditions. As required by Minn. R. 4410.1700, we look forward to receiving written responses to our comments on the EAW and a record of the decision on the need for an EIS. If you have other questions conceming our review of this EAW, please contact me at (651) 296 -6703. Sincerely, -Eru.a '(-fit, Barbara Conti Planner Principal Operations and Planning Section Metro District BC:sjs cc: Thomas Palmquist, Ryan Companies Gregg Downing, Environmental Quality Board • Keith Cherryholmes, MPCA, MD /CAP Larry Zdon, MPCA, MD /CAP Innocent Eyoh, PP /CAP