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Mr. Dennis Welsch Page 2 . The traffic study reported in the EA W appears to have used almost the same trip distribution percentages that were assumed in the 1985 traffic analysis that was done when this project was first proposed. . The traffic analysis also included the same text that was used in the November 1985 traffic study memorandum prepared by Benshoof & Associates. Some of the information is outdated. The analysis should have reflected most relevant, reliable and current data. For example, since 1985, County Road C and Cleveland Avenue have been classified as 'minor arterials', but were incorrectly labeled as 'collectors' in the EAW. . The EA W should have addressed impacts of adjacent developments that have gone through final approval from the city of Roseville's City Council, including the potential impacts rrom Phase III of the Twin Lake development which is to be constructed at a site on County Road C near Fairview Avenue. . The document fails to estimate the Clli-rent and projected availability of mass transit service to the project area. Finally, we have a couple comments regarding the air quality impacts described in the EA W. Based on the traffic volume and signal information rrom the EA W' s traffic impact analysis report, the analysis showed that both the one-hour and eight-hour concentrations were below the state standards. The EA W states that Ramsey County plans to upgrade County Road D/Cleveland Avenue intersection with improved geometric and traffic signal control in 1997. As such, traffic assignments, future conditions, and traffic volumes as well as capacity calculations were based on the premise that these improvements were completed and were operating as functional facilities. Since these improvements were assumed in the air quality analysis, a legally binding document guaranteeing funding for the completion of these improvements should have been submitted with the Indirect Source Permit (ISP) application. An ISP will not be issued in final form without this document. Given the type and size of the development with its daily variations in traffic, and the projected increase in traffic anticipated for the proposed project, the staff stresses the need to carefully monitor the actual land uses and traffic generation at the site to ensure continued compliance with the state eight-hour standard. We look forward to receiving your responses to our comments and your decision on the need for an Environmental Impact Statement (EIS). If you have any questions regarding our comments, please contact Kathryn Kramer of my staff at 612/297-8604. Sincerely, ~~ Paul Hoff, Director Environmental Planning and Review Office Administrative Services Division PH:jap