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This letter is to notify the St. Anthony City Council and Planning Commission of the many critical omissions in the proposal for the BLVD Carwash that is going to the council for approval based on the recommendations of the Planning Commission guided by the City Planner. In order for a Conditional Use Permit (CUP) to be given, the existing laws regarding impact of the project must be satisfied. There is much that has not been done. The proposal carwash is in the middle of housing. To the immediate south is the Kensington, a large condominium complex; to the east and south across the street is Autumn Woods, a large apartment complex; to the north and west, single family homes, some of which would be in the neighborhood of 30 feet away from the proposed carwash. The housing is R-1 zoned. There is no precedent in St. Anthony for a carwash adjacent to an R-1. It is a poor choice for the use of the land considering the housing nearby. The Council must find that the use is not detrimental to health, safety, and general welfare of persons residing or working in the vicinity or to the values of property in the vicinity.(A) None of this work has been done. (B) This is a critical oversight. We believe the proposed use of the property is detrimental on all fronts. (B-1) HEALTH/SAFETY/GENERAL WELFARE Car Pollution. No environmental impact study was done by St. Anthony Planning staff. (C) The plans submitted show a maximum capacity of 16 cars in staging---all presumably idling. Once these 16 spaces are used, where will the other waiting cars be? I can only assume they will be on Kenzie Terrace—a county road? People using a carwash may choose to leave their cars idling when using the vacuums. What is the projected emissions and it’s impact on the health of the people in the homes and condos and apartments? How many cars per hour are projected at peak use? I,Tom Deegan, spoke to two staff persons at the nearest carwash similar to the proposed BLVD Carwash---Mr. Carwash at 44th and Central Ave. in Columbia Heights. They told me,Tom Deegan, that at peak the number of cars per day is between 600 -800 cars (hours 7:30am-7pm). What is expected volume of cars projected? What are the proposed hours for the carwash? (D) It is something to note that Mr. Carwash is quite loud and is nowhere near an R-1 zone. Light Pollution. The current lighting at BLVD Auto, right next to the proposed carwash, is exceedingly bright and, we believe, already there is a negative impact to existing housing. We believe that the existing lighting needs remediation and is possibly not within the ordinance. Now with the added light expected at the carwash, there would seem to be an issue of further light pollution. There needs to be an elevation submitted that demonstrates the projection of the lights proposed do not impact the adjacent R-1 dwellings. (E) NOTE A (Full Text) (1) The use is one of the conditional uses specifically listed for the district in which the property is located; (2) The City Council has specified all conditions which the City Council deems necessary to make the use compatible with other uses in the area; (3) The use will not be detrimental to the health, safety, or general welfare of persons residing or working in the vicinity or to the values of property in the vicinity; and (4) The use will provide a service or a facility which is in the interest of public convenience and will contribute to the general welfare. NOTE B: (See remainder of the report) NOTE B-1: Granted the neighbors believe this, but the City must act on factual evidence, not “belief”. NOTE C: No Environmental Impact Study is indicated or required by MN Rules. Cars idling at car wash facilities (rarely exceeding 10 or so) are common throughout Twin Cities and elsewhere, with no reports of air quality violations that staff is aware of. Examples estimate approximately one car being served at competitive locations per minute. NOTE D: PC is proposing max hours of 7:00a.m. to 10:00 p.m. – owner stated 8:30 a.m. to 5:00 p.m. during PC meeting. NOTE E: Applicants submitted a lighting plan, including fixture type, location, and photometric “contour” plan. The City’s ordinance identifies lighting thresholds as a possible nuisance – this is an ongoing operational requirement, and which is also addressed in staff report (Condition 9). 105