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· The City shoreland ordinance establishes a road setback from a lake of 30 feet; The Rott1und Proposal would site Twin Lakes Parkway over three times this distance back from the lake. · The AUAR worst case scenario contemplated a hospital and housing south of Langton Lake. Elimination of these uses, and movement of Twin Lakes Parkway north will, in fact, provide greater control of surface water run off toward the lake, because it will allow greater detention of run off through treatment ponds and street catch basins. · The alleged shifting of the location of Twin Lakes Parkway north would not result in any loss of existing parkland - the size of Langton Lake Park would be unaffected by the proposed Twin Lakes Parkway location. · Langton Lake Park is classified by the City's Park and Recreation Systems Plan, a part of the comprehensive plan, as an "Urban Park", which means the park contains wildlife that is capable of adapting to differing urban development. · Many circumstances exist in the City where a road with the same (or greater) expected levels of traffic exist adjacent to a lake, These include: Lexington Avenue and Lake Josephine County Road C and Lake Bennett Owasso Boulevard and Lake Owasso McCarron's Boulevard and Lake McCarron · In its comment letter to the 2001 AUAR, the Minnesota Department of Natural Resources (DNR) indicated that no species of special concern existed within the Langton Lake Park Area; no information presented as a part of Petitioner's Petition demonstrates that any species of special concern has since been discovered that uses Langton Lake Park as habitat - therefore the alleged shift of Twin Lakes Parkway would not create an increased risk to special concern, threatened, or endangered plants or animals. · Petitioners also allege that MnDOT's determination not to allow Twin Lakes Parkway to connect to Snelling constitutes a "substantial change" in public facilities, but that assertion is not supported for the following reasons: 16