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K:\020256-000\Admin\Docs\20256-000 MEMO - Comment Responses - DRAFT.docx 540 GATEWAY BLVD | BURNSVILLE, MN | 55337 | 952.737.4660 | WSBENG.COM Memorandum To: EQB Agency Distribution List Copy: Rachel Juba, City of Hugo From: Alison Harwood, WSB Date: October 7, 2022 Re: Everton Avenue Neighborhood AUAR Update – Responses to Comments WSB Project No. 20256-000 The City of Hugo issued the Draft Everton Avenue Neighborhood AUAR Update for review to the EQB’s distribution list on September 6, 2022. The comment period ended on September 20, 2022 and the city received comments from the MN Department of Natural Resources, Washington County, and Washington Conservation District regarding the Everton Avenue Neighborhood AUAR Update. Each comment, and the city’s responses are provided below. Agency comment letters are attached. Department of Natural Resources Comment 1: Rare Species: Please see the attached DNR Natural Heritage letter that contains requirements to avoid impacts to state-listed species. Please include this letter with DNR’s comments in the Record of Decision. Response: The City reviewed the DNR’s Natural Heritage letter and updated the AUAR to reflect the protected species present in the vicinity of the project area. Mitigation measure 71 was added to reflect the need for a habitat assessment for bristleberry, swamp blackberry, and lance-leaf violet prior to development of undisturbed areas. Mitigation measure 16 was also updated to reflect the requirements for avoidance of blandings turtles. Comment 2: Stormwater: As the project area continues to be developed, it will greatly increase the amount of impervious surfaces as well as the amount of road salt used in the project area. Chloride released into local lakes and streams does not break down, and instead accumulates in the environment, potentially reaching levels that are toxic to aquatic wildlife and plants. Consider promoting local business and city participation in the Smart Salting Training offered through the Minnesota Pollution Control Agency. There are a variety of classes available for road applicators, sidewalk applicators, and property managers. More information and resources can be found at this website. Many winter maintenance staff who have attended the Smart Salting training — both from cities and counties and from private companies — have used their knowledge to reduce salt use and save money for their organizations. We also encourage cities and counties to consider how they may participate in the Statewide Chloride Management Plan and provide public outreach to reduce the overuse of chloride. Here are some educational resources for residents as well as a sample ordinance regarding chloride use. Response: The city appreciates the need to chloride management and will consider implementing the DNR’s recommended measures. Mitigation measure 72 has been added to the AUAR to reflect this consideration.