pf09-010 - Laserfiche WebLink

Home

� ��i�i Moss & Barnefit -� A Professional Association September 21, 2010 Members of the Roseville Gty Councii City of Roseville 2660 Civic Center Drive Roseville, MN 55113 Re: Bituminous Roadways Proposed Asphalt Plant Our File No.: 51429.2 Dear Members of the City Council: We represent Gladstone Commercial Corporation and its affiliate, UC06 Roseville MN LLC, the owner of the office building at 2501 Walnut Street (also 2470 Highcrest) in Roseville (the Unisys building). Gladstone's building is directly across the Walnut and Terminal intersecdon from the asphait plant proposed by Bituminous Roadways. Gladstone, like other businesses and residents in the area, opposes the project. Recognizing that the quality of the technical analysis for the EAW is critical to a determination as to the potential public health and environmental impact, Gladstone hired an environmental consultant to complete a technicai review of the EAW and proposed air permit. The consultant identified fundamental concerns with the EAW and proposed permit, and Gladstone submitted to the MPCA the enclosed August 11, 2010 letter, When the MPCA'extended the EAW comment period, Gladstone had its consultant examine the MPCA's file. The consultanYs technical anafysis caused us to submit to the MPCA the enclosed September 10, 2010 letter. The letter � desaibes at length the technfcal grounds for Gladstone's request that the MPCA require an EIS. In short, the technical review determined that there are too many uncertainties and too much missing information and incomplete study for the MPCA to conclude (a) that there will not be public health effects and adverse environmental impacts, and (b) that the proposed air permiYs operating conditions will adequately protect the public heaith and the environment. This letter is to draw your attention to the items in the consultant analysis that we rnnsider absolutely critical, each of whlch is consistent with City of RoseviBe concerns regarding the potential for adverse effects on the community. Specificatly, piease note the following: 1. The proposed emission control technology essential for Iimiting the environmental impact is untested. The EAW does noi provide an adequate analysis establishing that it will work. 2. The carbon bed filter proposed for controlling emissions and protecting public health and the environment may not be as efficient and effective as assumed in the EAW. Excess emissions could result. The analysis is incomplete. 3. The EAW modeling of emissions, including odor (hydrogen sulfide), Is inmmplete. The modeling fails to take into account air intakes and roof vents on Gladstone's building, and similar issues with respect to other buildings and uses in the immediate area. The modeling needs to be redone and recalculated. 4800 WELLS FARGO GEN7ER � 90 Sou�h Seventh Sveet Mioneapolis. MN 55402�9129 P�617-Q77.SOD0 E61h87J-5999 W:moss-Oa�neu.com