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," Mr. Timothy 1. Nelson -8- December 3, 1996 . No transportation improvement program is presented that will resolve the issues identified in Barton-Aschman's 1989 traffic study and that will adequately fulfill current anticipated traffic needs. CONCLUSIONS As described in this letter, we have carefully reviewed 13 documents that pertain to previous development plans and traffic studies for Twin Lakes Business Park area in the City ofRoseville. The three principal conclusions that we have established through this review are: 1) As presented in the 1988 Barton-Aschman report, the total planned development for the Twin Lakes Business Park consists of 1,412,900 square feet of office/retaiVservice/residential development plus 131 dwelling units. For this type of development, the Minnesota Environmental Quality Board Rules stipulate that an Environmental Impact Statement must be prepared for any development that exceeds 750,000 square feet in size. Since the size of the Twin Lakes Business Park is nearly double the threshold value, we have determined that an Environmental Impact Statement must be prepared for this project in order to comply with State Rules. 2) Current development in the Twin Lakes Development Subdistrict meets the definitions established by the Minnesota Environmental Quality Board for both phased actions and connected actions. The total scope of the phased and c.onnected actions exceeds 1,500,000 square feet of office/warehouse/showroom development, which is more than double the 750,000 square foot threshold that requires preparation of an Environmental Impact Statement. 3) Substantial additional traffic studies are necessary to analyze the impacts of current development plans on the affected roadway system. A fundamental question is whether current development plans can be accommodated without causing serious traffic problems. In correspondence dated 1989 and 1990, Metropolitan Council staff expressed major traffic concerns and needs for additional study. To our knowledge, the City has not yet completed the further traffic work requested by the Metropolitan Council. Two additional reasons Why a thorough traffic study needs to be completed are: a) recent comprehensive plan documents do not present complete information regarding changes that these developments would cause to the traffic forecasts prepared in 1989 by Barton-Aschman Associates or to the associated 'analysis results and b) the referenced documents do not include a comprehensive transportation improvement program that demonstrates an ability to meet the ~ticipated future traffic needs.