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Bruce Westby Page 2 October 26, 2021 • The cumulative affects portion of the EAW discusses the effects of the increased development in the area in relation to climate change and increased runoff and heat island effects, but does not indicate ways the development can help offset those impacts. The Project is located adjacent to flood plain and has the potential to increase flood risk to the area. It is strongly advised the Project proposer incorporate green stormwater infrastructure practices to help offset the effects of increased rainfall and potential flooding impacts along with the heat island effects of increasing development.The Project will be converting 25 acres of woodland to development with 7 acres of tree avoidance. It is advised that mature trees are preserved to the greatest extent possible or that trees are replaced on the site to reduce runoff, heat island effects and building energy use.The Project can maximize infiltration with the use of green space planted to native vegetation and reduce the amount of impervious surfaces through construction of narrower streets and use of pervious pavements.These efforts will also reduce or eliminate the need for salt application in winter,which is a major water pollutant in urban areas. The Project proposer should consider tree islands or native planting bump outs along streets to capture street runoff at its source in addition to designated stormwater basins to further reduce stormwater runoff and flood risk. Please direct questions regarding CSW Permit requirements to Roberta Getman at 507-206-2629 or roberta.getman@state.mn.us. We appreciate the opportunity to review this Project. Please provide your specific responses to our comments and notice of decision on the need for an Environmental Impact Statement. Please be aware that this letter does not constitute approval by the MPCA of any or all elements of the Project for the purpose of pending or future permit action(s) by the MPCA. Ultimately, it is the responsibility of the Project proposer to secure any required permits and to comply with any requisite permit conditions. If you have any questions concerning our review of this EAW, please contact me by email at karen.kromar@state.mn.us or by telephone at 651-757-2508. Sincerely, <aive4vV KV0rVt alt-, This document has been electronically signed. Karen Kromar Project Manager Environmental Review Unit Resource Management and Assistance Division K K/J B/RG:vs cc: Dan Card, MPCA,St. Paul Jim Brist, MPCA,St. Paul Roberta Getman, MPCA, Rochester