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''� Submittal by Neighbors Against the Asphalt Plant November 29, 2010 to the Roseville City Council � Item #1: Mischaracterization of the status of the Environmental Assessment Worksheet (EAW) In a letter dated November 10, 2010 written on behalf of Bituminous Roadways, Gregory Korstad of Larkin Hoffinan Attorneys states: •"The result of the environmental review process to date is that an environmental assessment worksheet has been prepared which concludes that the proposed facility does not present a potential for significant environmental impacts from the proposed project." •"The present status of the environmental review is that the technical and scientific analysis of the project demonstrates the lack of adverse effects from the proposed project." It is inaccurate and misleading to state that the EAW "concludes" or "demonstrates" anything authoritatively. The EAW's current status is that: l. It is a draft document. 2. The MPCA received 167 comments on the EAW, many of which raised specific and significant questions about the methodology used and conclusions drawn in the EAW. 3. The City of Roseville submitted comments and requested that an EIS be required because "the City believes the proposed project will have significant environmental effects that need to be further studied and finds that the current EAW response inadequately addresses the environmental effects of the proposed asphalt plant" (City letter to the MPCA, Sept. 10, 2010). 4. The MPCA suspended the environmental review process without responding to any of the comments or formally accepting or adopting the EAW. The City should consider the EAW to be only a draft document. Additionally, based on the manner in which numerous statements and estimates were revised by the applicant between the CUP submittal materials and the EAW submittals, the City should consider the information in the EAW to probably be underestimates and understatements of conditions on the site and environmental impacts of the proposed project. Neighbors Against the Asphalt Plant submitted formal comments and a contested case hearing petition related to the EAW. The following issues were raised. These issues have not been addressed by the MPCA or any other regulatory body. Issues #1. The traffic analysis in the EAW is insufficient and flawed. Issues #2. The stormwater (surface-water runoffl analysis in the EAW is insufficient and flawed. Issues #3. The dust analysis in the EAW is insufficient and flawed. Issues #4. The air emissions and odors analysis in the EAW is insufficient and flawed. Issues #5. The noise analysis in the EAW is insufficient and flawed. Submittal by Neighbors Against the Asphalt Plant November 29, 2010 page 1 of 4