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A also incorrecfly include a Parking Ramp (160, 000 s fl. As defined in the Rules, <br />parking lots and approach areas are expressly excluded from the calculation of <br />gross floor space. Minn. R. 4410.0200, subp. 35. <br />3. Comment: The gross floor space of new development proposed under the <br />Master Plan exceeds mandatory EIS thresholds apportioned on a percentage <br />basis between Arden Hilis and Roseville. RUN Comments at 5, and Appendix A. <br />Response: This calculation is not accurate. As noted above, the calculations <br />provided in Appendix A and drscussed on page 5 of the�comment letter <br />incorrectly include a Parking Ramp (160, 000 s�. As defined in fhe Rules, <br />parking lots and approach areas are expressly excluded from the calculation of <br />gross floor space. Minn. R. 4410.0200, subp.`.35: Correcting this error, the gross <br />floor space falls wel! below the applicable thresholds �apportioned between <br />Arden Hills and Roseville as suggested by the commenter.''�;;, <br />4. Comment: It is because of the past record of development (cumulative impact) <br />... that we ask for further environmental review in the form of an EIS., <br />�: ��� <br />Response: The EAW directly addresses cumulative impacts of the proposed <br />development wifh pasf de;velopment on the property. For example, as suggested <br />by EQB guidance, the Traffic lmpact Study attached to the EAW specifically <br />addresses background traf�ic�fr m,existing and other sources as a cumulative <br />impact. See EQB EAW G�dance`a�`1„4.,(noting consideration of background <br />� �#=��, <br />traffic as an example of propebr acco.u..nting;_for�cumulative impacts). <br />�� .____. .__,....�_. <br />5. Comment: Regarding the Metropolitan Council comments on the 1986 EAW <br />(incomplete analysis of lake impacts). <br />��°;;;��.� <br />Response: The Storm Managemenf Plan for the campus improvements includes <br />a Conceptual Plan for Surface Wate�Management that is based on the <br />�� �= ecumu�latrve runoff from all existing and proposed development. It includes <br />��=""prop' osed Best Management Practrces to address existing and proposed runoff. <br />A larger"scal�e assessment of cumulative impacts to lake quality and need for <br />measures fo' protect or improve quality for Lake Johanna and Little Lake <br />Johanna wiJl�occur when the Cities and Watershed District prepare a TMDL <br />_l,mplementation Study for Liffle Lake Johanna. The Metropolifan Council's <br />comment letter of June 20, 2007, regarding the 1986 EAW notes that the Cities <br />14 '°. <br />antl Watershecl Disfrict are the responsible agencies for this analysis. The <br />current IVIPCA schedule recommends such a study be started on Liftle Lake <br />Joharina`'no later than 2010. The study will evaluate the historic nutrients that <br />have accumulated in Liftle Lake Johanna that continue to degrade ifs water <br />quality, as well as the water qualify downstream in Lake Johanna. It will include <br />recommendations for future regulation of storm water runoff fo the lakes, and <br />requirements for Best Management Practices in the watershed area. The final <br />plan for storm water management facilities for proposed improvements to <br />Northwestern College will meet the requirements identified in the TMDL study <br />and other Watershed and State requirements for storm water management at <br />the time that the final plan is completed and constructed. <br />TKDA Project No. 13529.002 Page 17 Draft Date: July 9, 2007 <br />