|
<br />')~:;(.lU1.('f!,:';",'
<br />
<br />;'i'D~;C;\fJF ."FC'.:n,:;(
<br />\f,/,i(k, "FT')!:.!:,' <:H
<br />
<br />";;!:"
<br />".,0,
<br />
<br />~\lV","
<br />'71 ~'"
<br />DSI.l
<br />
<br />
<br />/u
<br />
<br />., '.C' J ) ~i br) '1
<br />
<br />'Jj'![1
<br />
<br />\1:;,,,,;[,,,.>.,.,,,, f'P,;
<br />
<br />ffH:1: DSUi)L; !'J,e')t.,j
<br />
<br />5'lJ/'"N' [~,!(:('j
<br />
<br />MEMORANDUM
<br />
<br />DATE: October 16, 2006
<br />
<br />TO: John Stark, Community Development Director, City of Roseville
<br />
<br />FROM: Ciara Schlichting, AICP, Senior Planner, DSU/Bonestroo
<br />
<br />RE: Twin Lakes Alternative Urban Areawide Review (AUAR) Update
<br />
<br />You have asked for my opinion regarding whether updating the Twin Lakes AUAR or requiring a
<br />project specific EIS is preferred, The AUAR process can substitute for any Environmental
<br />Assessment Worksheet (EA W) or Environmental Impact Statement (EIS) required for a specific
<br />project (e,g" the Rottlund Homes, Inc. project), provided that the project complies with the Twin
<br />Lakes AUAR Update assumptions and mitigation plan (Minnesota Rules 4410-3610 subp 2), It is my
<br />opinion that updating the 2001 Twin Lakes AUAR is preferred for the following reasons:
<br />
<br />1. An AUAR is a hybrid of the EAW and EIS review process, The AUAR uses a standard list of
<br />questions adapted from the EA W form and requires a level of analysis comparable to an EIS
<br />(Minnesota Rules 4410,3610 sUbp 4), It is important to understand that the level of analysis
<br />required for an AUAR is no less rigorous or detailed than that for an EIS,
<br />
<br />2, An AUAR is a comprehensive planning tool that reviews the cumulative impacts of multiple
<br />projects in a given area, whereas EISs are best suited for distinct projects with
<br />environmental impacts that do not overlap, The AUAR can review both the Rottlund Homes
<br />project as well as the redevelopment envisioned in the Comprehensive Plan, Updating the
<br />2001 AUAR will provide a more comprehensive analysis of environmental Impacts as it will
<br />address the entire 270-acre Twin Lakes area compared to preparing an EIS limited to the
<br />56-acre Rottlund Homes redevelopment area. In my opinion, an EIS for the Rottlund Homes
<br />project is not preferred as the environmental impacts of this project overlap with the
<br />environmental impacts of redevelopment throughout the Twin Lakes area (e,g" traffic,
<br />noise, and stormwater issues cross project boundaries),
<br />
<br />3, The Court of Appeals ruling determined that the 2001 Twin Lakes AUAR was not a valid
<br />substitute form of environmental review for the previous Rottland Homes project that was
<br />approved by the City in 2005 since the inclusion of the Rottland project into the Twin Lakes
<br />Master Plan, which the Court determined was a comprehensive plan update that would allow
<br />an increase in the development levels assumed in the 2001 AUAR, triggers a mandatory
<br />update to the 2001 Twin Lakes AUAR under Minnesota Rules 4410.3610 sUbp 7,B, Updating
<br />the 2001 Twin Lakes AUAR can serve as a valid substitute form of environmental review for
<br />the Rottland Homes project submitted to the City on October 6, 2006, The Twin Lakes AUAR
<br />update will also provide an opportunity to revisit the development scenarios and the
<br />blocks/subareas to address the Court's ruling,
<br />
<br />4. Preparing and processing individual EAW/EISs for projects as they are submitted to the City
<br />for review and approval is likely to be more costly (direct costs and/or staff time) than
<br />preparing an update to the 2001 AUAR, The City would be the RGU for each EAW/EIS
<br />responsible for preparing and processing each document Given the size of the Twin Lakes
<br />area, numerous EAW/EISs would be required
<br />
|