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2. Comment: Permits: Any work impacting Nln/DOT right-of-way requires a perm�t. 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 not a phased or connected action with prior development at the Co//ege. As defined in the Minnesota Ru/es: 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 direcfly induce the other; (8) one project is a,prerequisite for the other; or (C) neither project is justified by itself zM�nn:` R�4410.0200, subp. 9b. "Phased action" me�s two" o"`�`ore projects to be undertaken by the same proposer tli'a�a RG �-$det m�anes: (A) will have environmental effects�'on the s me g og�phic area; and (8) are substantially certain to'�be;;undertaken sequentially over a limited period of time. Minn. R. 44.1,0.0200, subp. 60. The College's pasf and proposed'�c�e�zelopment do not meet either definition. Past development at the College ditl�not directly induce the presently proposed Maste,r Plan. Nor was the Master Plan a prerequisite to or necessary to justify pr�or�`development at the College. Although development envisioned by the Master�Plar� would affect generally the same geographic area as past u.�.,... �.� k. . development,;�if has been more than 20 years since the College sought approval for any substantial modificafion to its campus. At the time of those prior approvals, tFi;e' Master Plan as currently proposed was not planned or substantially, ceitain fo be undertaken. In fact, fhe Master Plan itself envisions development,#wenty-plus years info the future. Neverfheless, the College has proactively;,conducted environmental review on fhe entire projecf in order to facilitate clear and comprehensive planning over the site. 2. 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 Minnesota Rules. The applicable fhresholds 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 VIIl.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