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June 16, 2003 <br /> <br />Objections ofErika Sitz (Comment 11) to Responses to Comments, Town Center AUAR <br /> <br />I am objecting to responses to Comments 7.4, 11, and 13, collectively, as they raise <br />common and overlapping issues about the Franconia-Ironton-Galesville aquifer. I'm <br />aware that the AUAR is an insufficient vehicle to address my concerns, but I wish to <br />have my objections on record. My objections are that the Responses show an inadequate <br />consideration for the following points: <br /> <br />(1) <br /> <br />The impact is as extensive as the aquifer. The most prudent step would be an area <br />wide moratorium, and especially a moratorium on the Town Center project, <br />because of its high-impact demands upon State water resources. The DNR could <br />be encouraged to.immediately begin a rulemaking or factfinding hearing. Such <br />agency action would make more sense than merely looking only at the limited <br />question of the enlarging (doubling) of the City's existing well permit, for one <br />single-site project, when clearly other City growth and growth outside of the City, <br />will raise the same question, again and again, until it is adequately addressed and <br />resolved. Review of a single existing use permit is simply an inadequate format <br />for administrative decision of issues of wide scope. <br /> <br />(2) <br /> <br />DNR is the appropriate lead agency to address this aquifer capacity planning <br />issue: (a) because DNR, working as lead agency, with Department of Health and <br />Met Council assistance, is the agency with ultimate state-wide jurisdiction over <br />State natural resources; (b) because Met Council jurisdiction does not reachas far <br />as the aquifer does; (c) because DNR has more staff with groundwater expertise; <br />and (d) because the Met Council has already assumed an advocatory position in <br />favor of this Town Cen~er project (and perhaps others of which I am unaware) <br />which raises the question of actual or apparent bias. <br /> <br />(3) <br /> <br />There are two factors to aquifer sufficiency. They are the rate of water <br />withdrawal, and the rate of charging the aquifer. Charging of the aquifer occurs <br />primarily outside of the City, and while impacts of development within the City <br />impact that part of charging the aquifer that occurs within the City, charging as <br />well as withdrawal is an area-wide issue exceeding the administrative reach of the <br />Metropolitan Council's jurisdiction. <br /> <br />(4) <br /> <br />Department of Health primary jurisdiction over questions of well-head security <br />and the contamination potential from having this development on top of a well- <br />head protection zone can be accommodated to DNR being lead agency. <br /> <br />(5) <br /> <br />Wh/le the City, and Mr. Oberts in behalf of Town Center promoters, are not <br />saying or implying their project is occurring in a vacuum, they focus the AUAR <br />and Responses upon their project's direct local impact, with outside scope'and <br />context being treated as beyond promoter and City impact, control, and direct <br />concern. This clearly ignores non-local "ripple effects" and most certainly does <br />not mean agencies should likewise adopt such a narrowed perspective. <br /> <br />-288- <br /> <br /> <br />