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As part of the approval of the Amended PUD and EAW in April of2001 Veritas prepared an update to the ISP Permit Application submitted to the MPCA and approved in 1997. That application included extensive analysis to estimate the potential impact of the proposed project upon air quality in the vicinity of the site. The analysis focuses upon carbon monoxide (CO), which is the primary pollutant of concern with vehicle emissions. Subsequent to the MPCA approving the ISP in June of2001, the State Legislature has repealed the requirements for preparing an ISP. For purposes of responding to this section of the EA W, calculations predicting carbon monoxide levels in the vicinity of the development were utilized from the April 2001 Amendment. Because the increase in traffic is minimal the following analysis is based on the previously approved EA W. The basic methodological approach used in performing CO calculations for ISP Pennit Applications, and this analysis, is as follows: 1. Establish an assessment year defined as one year following the anticipated occupancy of the project. 2. Determine busiest intersection in the vicinity of the project which will be significantly impacted by the project (source intersection). 3. Project CO levels generated at the source intersection for the assessment year by non-project traffic in combination with project-related traffic. 4. Determine potentially sensitive receptors which could be impacted by CO dispersion from the source intersection. 5. Model CO dispersion from the source intersection to the identified receptors. 6. Add the CO from the source intersection to projected background CO levels, and compare this sum to state air quality standards for CO concentrations. The year 2004 has been established as the assessment year (estimated one year after development). Source intersections modeled in this analysis were determined to be the intersection of Cleveland Avenue and County Road C and Cleveland Avenue and County Road D. Vehicular CO generation for 2004 at the source intersection was projected using MOBILE5a with traffic projection information from Benshoof and Associates, Inc. referenced in Response 22. Receptor locations for the modeling study were selected based upon locations where the general population may be during the appropriate averaging times for the MPCA CO standard (one hour and eight hour). The receptor locations used in the ISP analysis for the proposed project are identified in Figure 10. CO dispersion from the source intersections to the receptor locations was modeled using the CAL3QHC model. Background CO levels for the area were based upon historical data projected to 2004 levels taking into account anticipated overall increases in traffic levels and other factors. The methods and procedures used in this analysis were consistent with Indirect Source Permit Application Guidelines provided by the Minnesota Pollution Control Agency. Page 24