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A also incorrectly include a Parking Ramp (160, 000 s�. As defined in the Ru/es, parking lots and approach areas are expressly excluded from the calculation of gross floor space. Minn. R. 4410.0200, subp. 35. 3. Comment: The gross floor space of new development proposed under the Master Plan exceeds mandatory EIS thresholds apportioned on a percentage basis between Arden Hills and Roseville. RUN Comments at 5, and Appendix A. Response: This calculation is not accurate. As noted ove, the calculations provided in Appendix A and discussed on page 5 of �ti' omment letter incorrectly include a Parking Ramp (160,000 sf}. As ciefined in the Rules, parking lots and approach areas are expressly �x�clUded from the calculation of gross floor space. Minn. R. 4410.0200, sub�. 35. Garre�ting this error, the gross floor space falls well below the applicable tliresholds aj�F , ioned between Arden Hills and Roseville as suggested by the commen '� 4. Comment: It is because of the past record of development (cu� ci�tive impact) � ... that we ask for further environmental review in the form of an=��w Response: The EAW directly addresses cumulative impacts of the proposed development with past c�e,velopment on the property. For example, as suggested by EQB guidance, the ��`t��l,.�npact Study attached to the EAW specifically addresses background ts '�c��a�xisting and other sources as a cumulative impact. See EQB EAW �� ance a� 74 {noting consideration of background traffic as an examp/e of prc� ` accoi�ia�trt�grfor cumulative impacts). 5. Comment: Regarding #he Metropolitan C�ouncil comments�6n the '�986 EAW (incomplete analysis of lake impacts). Response: The Storm Manageme '' lan for the campus improvements includes a Conceptual Plan for Surface Wa : anagement that is based on the �� cumulative runoff from all existing and proposed development. It includes �`prop�� Best Management Pracfices to address existing and proposed runoff. A larger "_. assessment of cumulative impacts to lake quality and need for measures otect or improve quality for Lake Johanna and Little Lake Johanna wi �� cur when the Cities and Watershed District prepare a TMDL �mplementati "`, Study for Little Lake Johanna. The Metropolitan Council's �ment le�� of June 20, 2007, regarding the 1986 EAW notes that the Cities at�� Watershe`d District are the responsible agencies for this analysis. The current MPCA schedule recommends such a study be started on Little Lake Johar�na' nc� later than 2010. The study will evaluate the historic nutrients that have accumulated in Little Lake Johanna that continue to degrade its water quality, as well as the water quality downstream in Lake Johanna. It will include recommendations for future regulation of storm water runoff to the lakes, and requirements for Best Management Practices in the watershed area. The final plan for storm water management facilities for proposed improvements to Northwestern College will meet the requirements identified in the TMDL study and other Watershed and State requirements for storm water management at the time that the final plan is completed and constructed. TKDA Project No. 13529.002 Page 17 Draft Date: July 9, 2007