pf09-010 - Laserfiche WebLink

Home

`�.� ... November 18, 201Q PatTrudgeon Community Development Director Roseville City Hall Roseville, MN 55113 Mr. Tt-udgeon, Attachment I Thank you for inviting public findings in your report to City Cauncil on November 29, 2010. `I'he focus of my comments is on the A) unreliabiiity of the data presented by $ituminous Roadways, and B) prohibition of this plant on account af allowable uses as determined in the pre-amended (Ord. 1397; 10-11-10) industrial zoning codes. I'm well aware that tliere ai�e additional health, economic, and environmental issues at hand, however I simply couldn't include all the evidence possible. I ask that you please review botli of my personal letters submitted to the MPCA, as �vell as the NAAP contested case hearing petition letter for additional findings. Misleading Data First, it is imp�rtant to note that the information provided by Bituminous Roadways is sometimes misleading, contradictory, confusing, and/or insufficient, as notec! in many of the comment letters, and below. � For one, the data presented in the EAW implies a significant increase in project scope from what was presented in Bituminous Raadways' original application on March 6, 2009. The original application alludes to warm mix technology and its benefits in eliminating odor and smoke (including a flyer with detailed information on such benefits), whereas in the environmental review process it became apparent that warm mix technology was not acceptable to local construction companies, and therefore the plant would be using entirely hot mix technol�gy. Additionally, the odor figures preseizted in the EAW seem illogical. For instance, the data presented in Table 12 (pg. 29) indicates that the golf course would have slightly higher odor levels than the nearest residence (3.63 vs. 2.95 ug/m3 respectively). Yet according to BR's i►lformation and MPCA's documenCation, the primary source of odor is at the LAC storage tanks in the NE corner of the site. One would presume that the point closest to the odor source would experience more odor, unless of course wind is considered. However, as we all know, and according to meteorologist Patil Huttner, the prevailing wind directio�l for Minneapolis/St. Paul is fram the northwest to the southeast (in the direction of the residence), especially in the spring and fall. Finaliy, in the technical memorandum provided by Wenck Assoc. to the MPCA (dated Oct. 24, 2010), updated odor estimates are provided, as requested by the MPCA, yet they contradict information in the EAW and in tlie MPCA presentation slides. WiLh regard to the EAW, thE ....