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2. Comment: Permits: Any work impacting Mn/DOT right-of-way requires a permit. Response: Comment acknowledged. For the projects as described in the EAW, permits and approvals will be applied for and obtained as required by the various agencies and permitting bodies in accordance with the rules and regulations of these entities. VIII. Residents United for Neighborhoods (RUN) A. Lillian Chiarella, Spokeswoman for RUN � Comment: Under the Minnesota Rules this project is both "phased" and "connected." Response: The Master Plan is noi a phased or connected action with prior development at the College. As defined in the Minnesota Rules: Two projects are "connected actions" if a responsible governmental unit (RGU) determines they are related in any of the following ways: (A) one project would directly induce the other; (8) one project is a�t`� �quisite for the other or (C) neither project is � �� justified by itsel .'; i�� 4410.0200, subp. 9b. "Phased action" m : the same proposer � environmental effects substantially certain to period of time. Minn. R s to be undertaken by (A) will have hic area; and (8) are �ntiallv over a limited 0200, subp. 60. The College's past and proposed lopment do not meet either definition. ast development at the College ditl not directly induce the presently proposed ster Plan. Nor was the Master Plan a prerequisite to or necessary to justify pr�ar development at the College. Although developmenf envisioned by the Master Plan would affect generally the same geographic area as past developmet�t it has been more than 20 years since the Co//ege sought approval for any sub � tial modification to its campus. At fhe time of those prior approvals, tl��Master Plan as currently proposed was not planned or bstantiallycerfain to be undertaken. In fact, the Master Plan itself envisions elopmerrt twenty-plus years into the future. Neverthe%ss, the College has p c�actively conducted environmental review on the entire project in order to facili�� lear and comprehensive planning over the site. Comment: The gross floor space of all existing and proposed buildings exceeds mandatory EIS thresholds. RUN Comments at 6, and Appendix A. Response: This calculation is not accurate or appropriate under the Minnesofa Rules. The applicable thresholds at Minn. R. 4410.4400, subp. 11 are applied on a project-by-project basis. Because this project is not a phased or connected action with prior development at the College (see Answer to Comment VIII.A.1.), existing structures are not included in the calculation of gross floor space for purposes of the mandatory EIS threshold. The calculations provided in Appendix TKDA Project No. 13529.002 Page 16 Draft Date: July 9, 2007