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STATE OF DEPARTMENT OF 500 LAFAYE']-rE ROAD DNR INFORMATION May 23, 1994 Ryan Schroeder Ramsev C/tv Administrator 15153 Nowt'hen Boulevard Ramsey, MN 55303 NATURAL ST. PAUL, MINNESOTA · RESOURC 55155-40__ RE: Sunwood Drive NW between Krypton Street & County. Road 116 Environmental Assessment Worksheet (EAW) Dear Ix~r. Schroeder: The Department of Natural Resources (DNR) has reviewed the EAW for the above-mentioned project. We offer the following comments for your consideration. We appreciate efforts taken by the City to coordinate with DNR personnel the project's design and potential alignment during the planning process. We are concerned that the project wilt lead to unnecessary impacts to DNR protected water resources, particularly protected waters 2-673W and 2- l14P. The EAW correctly indicates that a DNR protected waters permit is required for the project as proposed. The associated permit process requires demonstration of both pubhc need and that no other practical ahernarives to protected waters impacts exist.. Although safety, cost, and future development potentials are important components of the roadway planning process, only alignment designs which most limit protected waters impacts would likely be permitted. The alternatives analysis provided in the EAW minimally considers the environmental costs associated with the various ali~mmaents and provides little detail regarding potential mitigation of wetland impacts. The preferred alignments, (IA & 2B), will result in the disruption and partial loss of two protected wetlands. Although the EAW indicates that the proposed roadway will fill approximately 0.8 acres of T)~pe III wetland, uncertainty, exists because a formal wetland delineation was not completed at the time of EAW preparation. It is very., likely that this 0.8 acre estimate is low. Furthermore, regardless of the amount, the EAW should detail proposed m/tigation for ail expected project-related wetland impacts. We also note that the preferred alignment results in the permanent conversion of ~t1.1 acres of wildlife habitat rather than the 6.3 acres indicated in the EAW. When reviewing other al/gnment options, use of roadway alignments lB & 2C would require less wetland FLll. This approach avoids one wetland crossing, requires less clearing and grubbing of wooded areas, and provides a good alignment along with the shortest driving distance. The EAW indicates that the disadvantages of this approach consist of more excavation, a more curved and slower route, the purchase and relocation of one residence, and a short sight-distance at one road crossing. The env-/ronmental costs of this approach are less than those associated with the preferred alignment. Other environmentally sound approaches could sigrdficantly reduce wetland impacts by either routing the roadway north of Sun_l~ish Lake or by bridging wetlands along the:roUtes already considered. It is uncertain from the information provided whether stormwater runoff will be directly discharged into wetlands from the roadways or street storm sewers. The. DN'R does not support placement of untreated stormwater runoff into wetlands. Although sedimentation basins and skimmers are mentioned as pretreatment measures, Figures 15 & 16 do not show detention basin placement. These measures require further clarification to better assess proposed protection measures for wetlands. AN EQUAL OPPORTUNITY .. EMPLOYER