HomeMy WebLinkAboutAnn M. Bucheck EAW Comments 11-16 2301 Legion Avenue
Lake Elmo MN 55042
November 21, 2016
City of Lake Elmo
Planning and Zoning Department
Stephen Wensman, Planning Director
3800 Laverne Avenue North
Lake Elmo, Minnesota 55042
Dear Mr.Wensman,
I would like to comment, ask questions, and clarify the EAW for the proposed Royal Golf Residential
Development proposed by HC Golf Development, LLC in the city of Lake Elmo, Washington County. I will
be referring to pages in the EAW that have given me concern.
My first concern is that the commercial aspect of the development,the golf course, club house, storage
area, sport complex, and driving range were not part of the study.These commercial aspects of the
development will add to the traffic, congestion, water runoff, and have a strong environmental impact
on the area.
On page 3 it states "Traffic generated by the project will have little to no impact on the regional
transportation system. Intersections surrounding the site will continue to operate at acceptable levels
of service with the traffic generated by the proposed project."This is followed up later on page 35 by a
traffic study that was completed in July, 2016, when the golf course, driving range, club house, sport
complex, and storage building were closed and the streets to the east and west, Lake Elmo Avenue and
Manning Avenue, were under construction and school was not in session. I disagree with the Traffic
Impact Study conclusion that the proposed project will have minimal effects on adjacent public roads
and that nearby intersections will continue to operate at an overall Level of Service (LOS)A. A proper
study needs to be completed.
The study continues on page 35 to say"These residential development is expected to generate a total of
2,780 average daily trips, including 1,390 vehicles entering the site and 1,390 vehicles exiting the site. It
continues with "The complete development analyzed included an 18-hole golf course with 293 single
family home land parcels. Based on this layout, the resulting new traffic associated with the proposed
development is expected to be 1,717 vehicles entering and 1,717 vehicles exiting the development per
day (total daily trip generation of 3,434 vehicles)."There is a difference in traffic if the commercial
aspects are included in the study and they should be as they will be part of the traffic.
Also in the traffic discussion it appears they are unsure what roads the traffic will use and which traffic
to count. It would also be good to determine if the entire area will be developed at this time as this will
impact the traffic count. "There is another potential access onto Manning Trail N for the proposed
residential component.This future access will depend upon development of the adjacent property and
is not included in this traffic analysis. It should be noted that the proposed site driveways do not provide
access to the entire development as each access only services a portion of the overall site.This results in
traffic that does not mix within the site, and depending on where the driver's origin and destination,will
determine which access to use.
Page 8 states "The City's ordinance also requires that shoreland PUDs be connected to public water and
sewer systems, and that least 50%of the shoreland area be maintained as open space."This is true,
however only that land within 1000 feet of a shoreland is zoned this way and needs to be connected to
public sewer,the remainder of the land could use septic systems. In fact, depending on the placement
of the lots no home would need to use public sewer.
Page 10 states "The project is proposing to place about 14.0 acre-feet of fill in the flood fringe of Downs
Lake to elevate an area for construction of 15 residential lots and adjoining streets. Construction of a
municipal street around the east side of Lake Rose will require about 1.6 acre-feet of fill in the flood
fringe of Lake Rose." We want to make sure proper authorities are committed to supervising this activity
as streets and 15 homes could be flooded if not completed correctly.This area has been flooded in the
past. It is unfortunate the developer is not listening to the land and building outside of a floodplain.
Page 11 states "The proposed project is compatible with the proposed land use, zoning, and surrounding
land uses. The project is designed to preserve considerable forested buffers adjacent to surrounding
roadways. These vegetated buffers will enhance the compatibility of the project with nearby land uses
and help preserve the forested character of the area." It is true this may be compatible with land use,
but certainly not with density of the surrounding homes.The current surrounding lots are about one
acre and go up to almost 50 acres per household,the proposed lots start at 0.4 acre and go up to .75
acre per household. The conversion of forest to impervious surface will significantly change the
character of the area and decrease the natural habitat of the existing wildlife corridor.Also on page 32 it
states: "buckthorn may be left in the understory along exterior roadways to provide visual screening." I
don't believe an invasive species is considered a "forested buffer" and will not enhance the project.
Page 13 describes the "Grading operations for residential development construction are expected to
affect 137.5 acres and involve movement of about 750,000 to 1 million cubic yards of soil to construct
streets, residential building pads, and stormwater ponds. Grading is expected to avoid disturbance on
84.4 acres within the project area". It is unfortunate so much land has to be disturbed, however it
means there will be considerable noise. Page 34 directs our attention to "Noise generated by
construction equipment and residential building construction will be limited primarily to daylight hours
when noise levels are commonly higher than at night." If this is true,what provision is being made so
the surrounding landowners are allowed their rightful peace and quiet? I would like to suggest all noise
generating equipment may only be operated from 8 AM to 5 PM and only Monday to Friday.
Page 16 states "The project is expected to produce normal domestic wastewater. This wastewater is
expected to be typical of residential developments. The project will not include industrial wastewater
production or onsite wastewater treatment." It is unfortunate the club house and other commercial
aspects are not included as there will be wastewater from them. No estimates were given as to the
amounts.
Page 18 states "The net increase in impervious surface is estimated at 38.6 acres. The creation of
stormwater features and the preservation of wetland buffers and other open spaces is expected to
mitigate potential adverse effects from the increase in impervious surface." Again I ask for scrutiny of
any permits and close supervision and of the mitigation as they are increasing the impervious area.Also,
can we be assured there will be supervision of these projects over time to make sure they are in proper
working order? Will unlimited access be given to the proper authorities to all stormwater management
facilities?This area has had major flooding in the past and with the addition of so much impervious
surface it will need timely reviews.
Page 30 tells us "The project area includes potential Blanding's turtle's (Emydoidea blandingii), habitat
consisting of wetlands and sandy soils. The best Blanding's turtle habitat includes wetland complexes
larger than 10 acres that are surrounded by open sandy uplands."The concern continues on Page 32
with "The project may have effects on Blanding's turtles that may occur in the area.To minimize
potential adverse effects on turtles and their mobility, the project will avoid most wetlands, implement
stringent sediment and erosion controls, consider the use of surmountable curbs on roadways, and
consider erosion control materials constructed of organic fibers rather than plastic." I don't believe
these developers wish to eliminate a state-listed threatened species, and therefore should abide by the
necessary measures to assure their survival. It is one thing to "try" and another to actually do them.
They also need to avoid disturbance in type 2 and 3 wetlands, no dewatering of wetlands in the winter,
and use wildlife friendly erosion control methods. Also, roads should be kept to minimum standards on
widths and lanes (this reduces road kills by slowing traffic and reducing the distance turtles need to
cross). Who will be overseeing these measures and what agency will follow through to make sure they
are done?
On Page 32 1 was happy to see, "To the extent practicable,tree clearing will occur between October and
April, when migratory songbirds and bats are not nesting or reproducing."This is extremely important as
oak wilt is prevalent in the area and we don't wish to have trees cut at the wrong time of the year.
Please check with an arborist to make sure it is safe before cutting. However, "buckthorn may be left in
the understory along exterior roadways to provide visual screening" is not acceptable. Buckthorn is an
invasive species and difficult to remove, but to intentionally leave it when there are alternatives
available is unacceptable in Minnesota. A certified landscape architect should oversee this aspect of the
project.
Page 33 states, "Although the proposed project may affect some views from nearby homes, the project
proponent has included design elements in the project to minimize visual effects on nearby
homeowners." There are residents on all four sides of the development and all wish to have as little
sight of the development as possible. Buckthorn is not an acceptable buffer.
"The project will not involve installation of intense lights that would cause glare, nor will it include
industries that would emit vapor plumes."The developer needs to follow the lighting codes of Lake
Elmo.
Page 34 states, "The project is not expected to generate dust or odors at levels considered unusual for
suburban development construction practices."The surrounding area does not have dense
development,the area is not your"usual suburban development". "Dust, odors, and noise levels are
expected to be slightly higher during project construction than project operations". Hours of operation
are important especially if they will be going on for 5-7 years.The health and emotional wellbeing of the
surrounding homeowners should be considered and is important. I again suggest all noise generating
equipment may only be operated from 8 AM to 5 PM and only Monday to Friday.
Thank you for the opportunity to comment on the EAW.
Sincerely,
Ann M. Bucheck