HomeMy WebLinkAbout#17 Royal Golf Club EAWMAYOR AND COUNCIL COMMUNICATION
DATE: 12/06/2016
Regular Item
ITEM #: 17
AGENDA ITEM: Royal Golf Environmental Assessment Worksheet (EAW) Comments
SUBMITTED BY: Stephen Wensman, Planning Director
THROUGH: Kristina Handt, City Administrator
REVIEWED BY: N/A
BACKGROUND:
According to State Statutes, the Royal Golf Residential Development is required to prepare a
mandatory EAW. A draft of the EAW was prepared by the developer and accepted by the City
for advertisement with the Environmental Quality Board on October 24, 2016. The
advertisement triggered a 30 day comment period. To keep the City Council informed, Staff has
provided the Council with this memorandum the comments received by the public and
government agencies during the 30 day comment period which ended on November 23, 2016.
The City has 30 days in which to respond to the comments received and to determine whether a
more involved Environmental Impact Statement is required. It is anticipated that the response to
the comments will be drafted and reviewed by City Staff for the City Council at its December 20,
2016 meeting. If there are any delays in the ability to respond, the City may postpone its
decision to gather critical missing information for up to 30 days or a longer period if agreed to by
the developer; the decision must be documented in written record of decision.
The EAW has no impact on the comprehensive plan amendment, but does need to be approved
by the City Council prior to approving the preliminary plat for the development.
RECOMMENDATION:
There is no recommendation. This item is for informational purposes only.
ATTACHMENTS:
• EAW comments - Public and agency
PROTECTING, MAINTAINING AND IMPROVING THE HEALTH OF ALL MINNESOTANS
An equal opportunity employer
November 23rd, 2016
Stephen Wensman
Planning Director
City of Lake Elmo
3800 Laverne Avenue North
Lake Elmo, MN 55042
Dear Mr. Wensman,
Thank you for providing the Minnesota Department of Health (MDH) with the opportunity to
comment on the Environmental Assessment Worksheet (EAW) for the Royal Golf Club
Residential Development project. The mission of MDH is to protect, maintain, and improve the
health of all Minnesotans. The careful planning and development of projects such as this one
supports this mission and is an important step in ensuring health in all policies.
MDH does have several comments regarding groundwater, water quality, and soil contamination
at and near the site:
Section 10 – “Geology”
Although no sinkholes have been identified on the project property, the Minnesota Geological
Survey (MGS) karst inventory does map one sinkhole less than one mile northeast of the project
property, just north of the intersection of Manning Avenue and 27th St. N. (UTM coordinates
510846/4981836). Depth to carbonate bedrock is an important factor in the potential for karst
development, with that potential increasing significantly where depths are less than 50 feet
(Alexander, et al. , 2003, “Sinkholes, Sinkhole Probability, and Springs and Seeps”, Goodhue
County Atlas, County Atlas Series, Atlas C-12, Part B, Plate 10). Well logs near the east property
boundary of the project area indicate depth to bedrock is approximately 47-59 ft. (unique well
numbers: 442166, 447252, 431201, and 503306). Two infiltration areas and two stormwater ponds
are planned near the northeast corner of the project property (as shown on Figure 7). Consideration
should be given to potential karst development beneath these infiltration areas and whether any
mitigation measures are needed, particularly given the proximity of these areas to planned home
construction.
Section 11 – “Water Resources”
The groundwater discussion should include more information regarding the perfluorochemical
(PFC) contamination in the groundwater in this area. Groundwater has been impacted by PFCs
from the former Washington County Landfill and 3M-Oakdale Disposal Site. Due to groundwater
flow, surface water-groundwater interactions, and stormwater management activities, the
groundwater east of Lake Elmo has been impacted by PFCs emerging from these disposal areas.
Recent MDH sampling has detected PFCs at concentrations above the new Environmental
Stephen Wensman
The Royal Golf Club Residential Development
Page 2
November 23rd, 2016
Protection Agency (EPA) Lifetime Health Advisory levels of 70 parts per trillion for PFOS and
PFOA in the surface water in Lake Elmo, the unnamed creek that discharges from Lake Elmo onto
the project property, Horseshoe Lake, and the series of ditches and stormwater ponds further
downstream. Surface water ponds on the property that are part of the Project 1007 drainage system
are almost certain to be similarly impacted. The full extent and distribution of PFCs in this portion
of Lake Elmo are still being determined. Use of surface water or groundwater at the project site
should be carefully managed to avoid human exposure and prevent further spreading of the
contamination. MDH further recommends landscaping options be implemented to create
significant buffers in order to restrict public access to Horseshoe Lake.
Preliminary data suggests PFC contamination is primarily in the Prairie du Chien aquifer (OPDC),
but excessive use of Jordan aquifer (CJDN) wells may cause downward migration of the
contamination, potentially placing downgradient CJDN wells at risk. MDH recommends the
project proposer work with MDH, MPCA, and DNR to evaluate water quality in the existing wells
and surface waters on the project property and determine appropriate use of these to mitigate for
these potential impacts.
Section 12 – “Contamination/Hazardous Materials/Wastes”
The sub-section titled “Investigation History” indicates a “disposal area” is located on an adjoining
property to the southeast. The location is not shown on any figures and no information is provided
regarding this disposal area and its proximity to the project property.
The sub-section titled “Response Action Plan” indicates that contaminated soils excavated at the
site are to be managed in a “Regulated Soil Management Area” beneath a 2 ft. cover. The figure
shown in the Phase II Investigation Report (Appendix D) indicates the area proposed for this
management area has a significant slope and may be prone to erosion. MDH assumes MPCA will
be consulted in the design and construction of this facility to ensure it provides long-term
encapsulation of these soils to prevent exposures.
The sub-section titled “PFCs and Area Groundwater Contamination” (page 27) should be revised
to reflect that PFCs above levels of health concern are present in the groundwater in this part of
Lake Elmo. Although the concentrations detected in the CJDN wells on the property do not exceed
levels of health concern, as noted above continued extraction of water from the CJDN may result
in increased PFCs in this aquifer over time.
Appendix D – Table 3
Although the table correctly identifies the current MDH Health Risk Limits for PFOS, PFOA,
PFBA, and PFBS, it should be noted that MDH now uses the new EPA health advisory levels of
70 ng/L for PFOS and PFOA when evaluating health risks.
Health starts where we live, learn, work, and play. To create and maintain healthy Minnesota
communities, we have to think in terms of health in all policies. Thank you again for the
opportunity to provide comments on this EAW for the Royal Golf Club Residential Development
project. Feel free to contact me at (651) 201-4907 or david.bell@state.mn.us if you have any
questions regarding this letter.
Sincerely,
Stephen Wensman
The Royal Golf Club Residential Development
Page 3
November 23rd, 2016
David Bell
Environmental Review Coordinator
Environmental Health Division
Minnesota Department of Health
PO Box 64975
Saint Paul, MN 55164-0975
MINNESOTA DEPARTMENT OF NATURAL RESOURCES
CENTRAL REGION
1200 WARNER ROAD
SAINT PAUL, MN 55106
651-259-5800
mndnr.gov
PRINTED ON RECYCLED PAPER CONTAINING A MINIMUM OF 10% POST-CONSUMER WASTE.
AN EQUAL OPPORTUNITY EMPLOYER.
November 22, 2016 Transmitted electronically
Stephen Wensman
3800 Laverne Ave. N.
Lake Elmo, MN 55042
RE: The Royal Golf Club Residential Development EAW
Dear Stephen Wensman,
The Minnesota Department of Natural Resources (MNDNR) has reviewed the Environmental Assessment
Worksheet (EAW) for the Royal Golf Club Residential Development EAW.
General Comments
To date, MNDNR has provided formal comments on the concept PUD to the City of Lake Elmo and
informal comments to the developer on the PUD density analysis. These comments have been based on
the assumption that the PUD will have City water and sewer. MNDNR will formally review the
preliminary PUD and plat when these are submitted to the City, to determine if they meet the PUD
provisions in State shoreland rules.
MNDNR review of shoreland PUDs looks for consistency with the density allowances, setbacks, and
height as well as a variety of more subjective performance standards dealing with protection of vegetation
and sensitive slopes. While we look for compliance with the numerical standards, we recognize that good
environmental design cannot be reduced to compliance with a set of numbers. The shoreland PUD
standards were part of the 1989 State shoreland rules and were an early form of conservation design
regulations. A lot has been learned about conservation design since 1989 and many communities in
Minnesota have adopted different shoreland PUD standards to limit density, ensure better natural
resource/open space protection, and provide for greater alignment with the community’s vision.
MNDNR has concerns on the design of the Royal Golf Club Residential PUD because the proposed
development is too dense for the natural resources on the site. In making this evaluation, MNDNR is
considering overall project suitability by looking at how the design impacts the existing natural
environment on the site. From our perspective, a development is not suitable if it is consuming areas of
high quality vegetation and areas with slopes greater than 12 percent (which MNDNR considers steep
slopes). Ultimately, however, it is up to the City of Lake Elmo to evaluate project suitability, natural
resource protections, and transportation concerns associated with this proposal.
Specific Comments
• Page 3 - Rewrite the statement on page 3 so that it does not imply that the City has determined
that this project meets shoreland overlay district requirements. At this stage of the PUD process,
it is premature to state that the proposed project design complies with shoreland overlay district
requirements. The City of Lake Elmo has not approved this development yet nor has the City
MINNESOTA DEPARTMENT OF NATURAL RESOURCES
CENTRAL REGION
1200 WARNER ROAD
SAINT PAUL, MN 55106
651-259-5800
mndnr.gov
PRINTED ON RECYCLED PAPER CONTAINING A MINIMUM OF 10% POST-CONSUMER WASTE.
AN EQUAL OPPORTUNITY EMPLOYER.
fully evaluated whether the development plans are in conformance with City ordinances and State
shoreland rules.
• Page 3 states that this project minimizes effects on floodplains. However, page 10, states that
there will be about 15.6 acre-feet of fill in the flood fringe to accommodate 15 residential lots and
streets. The statement on page 3 is misleading since there will be significant changes to the
existing floodplain configuration. What layout design modifications could be made to avoid the
need for floodplain fill and rerouting of flood waters into storage ponds? How will floodplain
storage outside of the PUD boundary be managed (i.e., who will own and maintain these storage
ponds)?
• Page 3 – Please correct the MNDNR PWI # for the unnamed public water wetland from 82-117W
to 82-417W. The MNDNR ID # for the unnamed public watercourse is M-050-009-001.
• Page 8 states that the City’s ordinance requires only two conditions to be met to allow for PUDs
(the City’s PUD ordinance and the State shoreland PUD rules). PUDs, by their very nature, are a
negotiation between the local government and the proposer. The City, through the PUD process,
can require additional conditions in exchange for the increased density that is allowed under a
PUD. Through the PUD process and negotiations with the developer, the City can also exert
influence on how a property is developed and what the design of that development looks like. For
example, the City can require greater tree preservation, slope/erosion protection,
interconnectivity, conservation easements, or other environmental or public benefits.
• Page 9 and Appendix A - Please update the shoreland PUD suitable area, open space, and density
calculations (Tables 5 and 6 and Appendix A) to match those numbers provided in analyses
completed after the submittal of the EAW. Include with this analysis a map showing areas
suitable for development and those areas not suitable for development and their acreages. Also
include with this analysis a map showing areas of open space and those areas not included in
open space and their acreages.
• Page 11 states that the proposed project is compatible with surrounding land uses. Describe in
more detail in what ways the PUD’s design plan is compatible with surrounding land uses. Please
provide more detail on the preservation of forest buffers and how they provide compatibility with
surrounding land uses. Has this proposal considered ways to preserve existing forest areas to
allow for plant and wildlife preservation?
• Figure 7 – Please show the location of steep slopes on Figure 7, to help the reader determine the
location of proposed lots, structures, and roads in relation to steep topographic areas.
• Has a tree preservation and replacement plan been prepared for this proposed development that
meets City ordinance?
Thank you for the consideration of our comments.
Sincerely,
/s/ Rebecca Horton
Regional Environmental Assessment Ecologist – Central Region
Division of Ecological and Water Resources
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 I 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
From:Corbett, Michael J (DOT)
To:Stephen Wensman
Cc:Scheffing, Karen (DOT); Sherman, Tod (DOT); Moynihan, Debra (DOT)
Subject:The Royal Golf Club Residential Development EAW
Date:Monday, November 07, 2016 2:05:01 PM
Hello Mr. Wensman,
Thank you for the opportunity to review the Environmental Assessment Worksheet (EAW) for The
Royal Golf Club Residential Development EAW, located in Lake Elmo, MN. The Minnesota
Department of Transportation (MnDOT) has reviewed the EAW and has no concerns.
If you have any questions, please let me know.
Michael Corbett, PE
MnDOT Metro Division – Planning
1500 W County Road B-2
Roseville, MN 55113
651-234-7793
Michael.J.Corbett@state.mn.us
The Minnesota Department of Transportation invites you to take our two-minute
survey to help us improve our services. MnDOT External Customer Survey
Thank you for telling us about your experience
Supervisors: Louise Smallidge ▫ Bob Rosenquist ▫ George Weyer ▫ John Rheinberger ▫ Jim Levitt
November 22, 2016
Stephen Wensman, Planning Director
City of Lake Elmo
3800 Laverne Ave N.
Lake Elmo, MN 55042
RE: The Royal Golf Club Residential Development EAW
Dear Steven,
The Washington Conservation District (WCD) has received and reviewed the above-mentioned EAW.
The WCD review focuses on wetlands, erosion and sediment control, natural area management, and
stormwater management. Based on this review the WCD offers the following comments:
Section 7 – Cover Types
Use of native vegetation and habitat restoration is encouraged in the open space areas, including native
vegetated buffers around stormwater treatment systems. Enhancing the greenway cooridor that
connects Lake Elmo to natural areas to the east is encouraged.
Section 10 – Geology, Soils and Topography / Land Forms
Section b. Soils and Topography
• Compliance with NPDES, watershed, and local requirements will minimize adverse impacts of soil
erosion and sedimentation. The WCD can provide support to the City to ensure compliance as
needed. The WCD recommends phasing the earthwork and grading to the greatest extent possible
to limit the scale and duration of exposed soils during construction.
• Preserve HSG B soils to the extent possible. Protecting zones of optimum infiltration from
compaction is preferred
• Minimize soil compaction and provide soil restoration in landscaped areas to enhance infiltration
• Deep-rip the soils with a toothed bucket in low or compacted areas to promote infiltration after
major construction is complete
Section 11 – Water Resources
Section iv. Surface Waters
• The EAW indicates the site will meet City and VBWD infiltration guidelines, which recommend
retaining the 1.1” rain event on-site. WCD encourages the use of bioretention to meet the onsite
volume retention standards. Bioretention promotes both infiltration and evapotranspiration which
more effectively mimics terrestrial hydrology than pure infiltration systems. These systems are
designed to be distributed throughout the site and treat small contributing drainage areas, breaking
up larger catchments into smaller, more manageable parts. Minimizing the drainage area provides
multiple benefits to stormwater treatment, including the potential for reduced infrastructure
conveyance costs.
To ensure the long-term effectiveness of volume control, the following design specifications are
presented for consideration:
• Do not rely on long-term infiltration from unlined stormwater ponds or wet detention basins
• Install bioretention/infiltration practices off-line
• Include flow-splitter and high-flow bypass
• Provide pre-treatment (especially for sediment to prolong the life of a practice)
• Keep the max water depth to acceptable levels based on soil types and actual infiltration rates
• Refer to the Minnesota Stormwater Manual, 2013 (on MN PCA website) for additional design and
implementation considerations
The WCD is also serving on the WCA TEP and will provide comments on the wetland permiting through
that process.
Section 13 – Fish, Wildlife, Plant Communities and Sensitive Ecological Resources (Rare Features)
Section d.
• Buckthorn removal from entire project area rather than leaving visual barrier along exterior
roadways will minimize spread of this restricted noxious weed. Replace visual barrier of
removed Buckthorn by replanting native trees and shrubs.
Conclusions
There are no known impacts that have not already been addressed in this EAW that warrant an
Environmental Impact Statement. The Washington Conservation District appreciates the opportunity to
review this EAW. Please call me at 651-330-8220, extension 20, if you have any questions about our
review.
Sincerely,
Jay Riggs, District Manager
Washington Conservation District
Cc: John Hanson, VBWD
From:archyeagle@gmail.com on behalf of Matthew Archibald
To:Stephen Wensman
Cc:Matthwew Archibald
Subject:Royal Golf Club Environmental Assessment Worksheet 30-day comment period
Date:Friday, November 18, 2016 4:11:05 PM
Hello Mr. Wensman,
I write in comment of the EAW that was filed for the Royal Golf Club Residential
Development as a concerned local resident. I live at 11365 24th Street Court North, Lake
Elmo.
What else do I need to complete to fully document my concerns regarding this EAW other
than writing my comments in this format here? I do not agree with the completeness of the
prepared file, here are the features that I feel need more due diligence in Sections 8, 12, 15 and
20:
Section 8. Permit and Approvals required.
Missing an Approval from the city. I see no record of a Tree Preservation plan or tree inventory as
required by the Lake Elmo Zoning Code Chapter 154. In the EAW, Table 2 summarizes the Before and
After Cover types. Included in this out line there is a 53% reduction in the woodland cover.
30% is the limit of the allowable tree removal rate within the City Code. With this documented plan
to reduce woodland cover by more than 53%, this is a "potential impact that warrants detailed
further investigation" and documentation. The Developer should hired a registered Forrester to
inventory all the onsite trees to be added to this Environmental Impact Statement.
Unit of Government Type of Application Status
City of Lake Elmo Tree Preservation Plan Not outlined, Prepared,
Submitted or Approved
154.257 TREE PRESERVATION.
A. Purpose. Within the City of Lake Elmo, trees and woodlands are considered a valuable
asset to the community. The City places a priority on protecting this asset and finds that it is in
the best interest to regulate the development and alteration of wooded areas within the
community. All builders, developers and subdividers shall comply with all the provisions in
the Zoning Code which address the preservation of existing significant trees. All builders,
developers and subdividers are encouraged to preserve all healthy trees of significant value
even if the trees do not meet the size requirements to be considered significant trees.
Section 12. Contaminatio/Hazardous Materials/ Wastes
Within the Regulated Soil Management Area - what isthe potential impact to local residential
groundwater of managing all of the excavated hazardous soil on-site, at the west end of the Driving
range? What type of impervious barrier was laid below the transferred Regulated soil? I see you no
description for the layer used in the HELP model referenced in the report by Carlson McCain, Inc.
Additional, expansion on the assumptions and outputs from this model are a gap from this report in
Appendix D. By concentrating the hazardous soil at the west side of the driving range - how has this
minimized the impact of these hazards on the local Groundwater? I see how this has minimized the
impact to the planned development but what about the rest of the community in Lake Elmo?
Section 15 &/or Section 20 “Visual” and “Other Potential Environmental
Effects”
Light pollution – What are the project details related to minimizing escapement of light into the
environment. The proposal needs to address light pollution and the impact on the regional
ecosystem and wildlife. I think a documented report detailing the baseline local night-time
brightness compared to the expected increase will be an important feature to outline as part of the
Environmental Impact Statement.
Thank you for your work and attention to these comments,
Matt