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I realize that this document is for the Town Center development project and focuses on <br />that geographical area. It's my understanding (though I am not certain of the scope) that <br />it also takes into account other development, and thus effects on water, in Ramsey. But <br />the nature of this kind of document is that it isn't the vehicle for a comprehensive <br />approach that examines a broad enough scope to answer questions about its effect beyond <br />this city. My greatest concern is that there has not been enough attention paid to the <br />cumulative effects of the development that is happening in the northern metro area, for <br />which I'm using the extended Metropolitan Statistical Area definition rather than the <br />seven -county Metropolitan Council definition. This also more realistically covers the <br />range of the Franconia -Ironton -Galesville (FIG) aquifer that is the drinking water source <br />for this area, since the prolific Prairie du Chien -Jordan Aquifer is absent. <br />I am not a technical professional. I'm expressing a concern as a citizen that this kind of <br />review by done by those who are so qualified, and who are removed from any <br />involvement in this project, and that this review occur before the momentum for such a <br />massive undertaking makes it impossible to do a thorough and competent professional <br />job. I'm not picking on the Town Center project per se, but because of its scope it's a red <br />flag to me to say we must look at a broader picture now rather than later. <br />I'm familiar with the tension that results from the current two-step process, first a general <br />examination of environmental effects in the review document and then the "we'll address <br />the details in the permitting process later" second step. My experience is that this always <br />results in a question of "how can we ameliorate the effects of ?" rather than "is this <br />a wise thing to do, or more precisely to do on such a scope and scale, and how can we <br />modify to prevent or minimize negative effects?" I don't think that's a wise way <br />to look at a specific proposal, but I'm even more certain that the piecemeal approach is <br />not the best way to look at the broad picture. A comprehensive review should be done <br />by an entity that is not involved in any project anywhere and thus can examine the issue <br />from the broadest context and without any bias. This to me is the Minnesota Department <br />of Natural Resources, Division of Waters. <br />I'm not technically competent to address the specific issues raised, e.g. relationship <br />between the FIG and the surficial aquifer, but I'm eager to see agency responses to these <br />issues. <br />Response: The City appreciates the input from Ms. Sitz as a concerned citizen. The State <br />AUAR process was developed by the State Environmental Quality Board (EQB) to <br />address the need for a more thorough cumulative assessment on large-scale projects. The <br />extensive analyses in Item 13 and Appendix F were done to specifically address the <br />impact of this site on the Franconia -Ironton -Galesville (FIG) aquifer. Extending this <br />analysis beyond the immediate Ramsey vicinity to the Metropolitan Area is well beyond <br />the scope of this AUAR. However, the City is willing to undertake whatever studies will <br />be required by the DNR for amending the City's water appropriation permit. In addition, <br />the joint study of the FIG aquifer referred to in the Minnesota Department of Health <br />comments (Comment #13) will also assist in assuring the long-term viability of this <br />resource in Anoka County. Both of these efforts will be done in cooperation with state <br />agency staff having no involvement in this project. <br />34-23 <br />