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SLATE OF <br /> <br />DEPARTMENT <br /> <br />OF <br /> <br />500 LAFAYETTE ROAD · <br /> <br /> NATURAL <br /> <br />ST, PAUL, MINNESOTA <br /> <br />DNR IN FORA~,TION <br /> <br /> May 23, !994 <br /> <br />Rvan Schroeder <br />Rhmse. v Cftv Administrator <br />1~!53 ,~o~hen Boulevard <br />Ramsey, MN 55303 <br /> <br />RE: <br /> <br />Sunwood Drive N\V bern, ecu Kr39ton Street & Counb, Road 116 <br />Enxdronmental A.~sessment Worksheet (fA\V) <br /> <br />RESOURC ,, ............ <br /> 55155-40 .. , <br /> <br />Dear Mr. Schroeder: <br /> <br />The Department of Natural Resources (DNR) has reviewed the EAW for the above-mentioned project. <br />We offer the following comments for your consideration. <br /> <br />\Ve appreciate efforts taken by the Ciw to coordinate v,dth DN'R persorme] the project's design and <br />potential alignment during the plannir{g process. We are concerned that the prbje. Jt will iea~'to <br />urmecessan, impacts to DNR protected water resources, particularly protected waters 2-673W and 2- <br />li4P. The'EAW correctly indicates that a DN-R srotected waters permit is resuired for the project as <br />proposed. 2-ne associated permit process require's demonstration of both publfc need and that no other <br />nractical ahernatJves to protected waters impacts exist. Although safer5.,, cost, and future development <br />botentials are important components of the roadway planning process, only alignment designs v,;hich mos~ <br />hmit protected waters impacts would likely be permitted. <br /> <br />The alternatives analysis provided in the EAW minimalh, considers the emdronmental costs associated <br />with the various alignments and nrovides little detail regkrding potential mitigation of wetland impacts. <br />The preferred ahgnments, (iA ~ 2B), will result in the disruption and partial loss of two protected <br />wetlands. Although the EAW indicates that the proposed roadway will fill approximately 0.8 acres of <br />Type IE wetland, uncertainty., exists because a formal wetland delineation was not completed at the time <br />o~ EAW preparation. It is ven, likely that this 0.8 acre estimate is low. Furthermore, regardless of the <br />amounu, the EAW should deta{il proposed mitigation for all expected project-related wetland impacts. <br /> <br />We also note that the preferred alignment results 52 the permanent conversion of 11.1 acres of wildlife <br />habitat rather than the 6.3 acres indicated in the EAW. <br /> <br />When reviewing other alignment options, use of roadwa'¢ ahgm:nents lB & 2C would require less wetland <br />~Jll. Tn_is approach avoids one wetland crossing, require~ less clearing and grubbing of wooded areas, and <br />provides a good align_mere along w/th the shortest driving distance. The EAW indicates that the <br />disadvantages of this approach consist of more excavation, a more curved and slower route, the purchase <br />and relocation of one residence, and a short sigh~-distance at one road crossing. The environmgma] costs <br />of this approach are less than those associated with the preferred alignment. <br /> <br />Other enviromnentalh, sound approaches could signxificantly reduce wetland/mpacts by either routing the <br />roadway north of Sunfish Lake or by bridging wetlands along the routes already considered. <br /> <br />h is uncertahn from the information provided whether stormwater runoff will be directh, dischareed into <br />wetlands from the roadways or stree:~ storm sewers. The DN'R does not support place~em of ur~rreated <br />s:ormwater runoff 52to wetlands. ,AJthough sedimentation basins and sNm.mers are mentioned as <br />~retreatmem measures, Figures 15 & ~6 do not show detention basin placement. These measures <br />require further ctarLfication to better assess proposed protection measures for wetlands. <br /> <br />AN EQUAL OPPORTUNITY EMPLOYER <br /> <br /> <br />