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Page Three February 26, 1997 Mr. Timothy J. Nelson Everest Group, ltd. Re: EAW for Centre Pointe Business Park Roseville, Minnesota (96-023) Whenever environmental review is required, by the EQB rules, a moratorium is automatically placed on approval of the project and on the initiation of construction of the project. Had the EAW disclosed that a proposed regional pond was to be constructed within the Centre Pointe site, as it should have, project approvals and construction of the regional pond would have been delayed to allow for the proper review of environmental issues by the public as intended by the EQB processes. The permit processes should have been considered within the context of the entire environmental review process. The "Wetland Permit Application" mentioned above, page 4, includes discussion of "keeping the wetland impact below the EAW threshold to avoid time delays and costs that could result with an EAW . This calls attention to the City's and developer's concern with bringing their project under the EAW perusal, not in the interest of the public for environmental reasons, but because of potential of time delays and costs to them. This is not in following the intent of the EQB processes. Additionally, the 'Wetland Permit Application" purports to address the. alternatives to wetland alteration that were considered. It goes on to identify two other potential sites for the regional pond that would not impact the wetland. These alternative sites were rejected by the City, as stated in their application. Yet, there is no analysis of the these alternative sites only statements as to economic impacts. There is no substantive data presented to support the conclusions. The rational for rejection of one alternative was that the pond would occupy 2,0 acres of otherwise developable land. As stated, this is a conclusion based solely upon financial considerations. The other alternative referenced in their application is one that would put the pond at approximately the same vicinity, but slightly removed from the wetland on a portion of the upland area of Centre Pointe Business Park. This site was rejected because of 'ongoing litigation and Tax Increment Financing requirements' . Agai~, this appears to mean some legal and financial consideration, made without supporting analysis and data. The preparer of the EAW, and the RGU, is the City of Roseville, The City of Roseville is responsible for any "Tax Increment Financing" requirements. The City claims that the pond cannot be located outside of the public wetland because of "financing requirements. made by the City. A complete and thorough review of alternatives should include analyses of such factors as hydrological design, proposed land uses, and potential for location within developable site's setbacks or lawn areas. In my opinion, the evaluatior' of alternatives within the permit application was not adequate. Perhaps different conclusions would be reached by the public and by the owners' of the properties in question if only the data were presented, --~----