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? ,� �� s�'�"'� � "�"�'"� ��- i � E iE i ' a ti � � � �'i L ' i �k� � � " r E�rt .� �;. ��: ,,� �iS. � A,W, Y� , g �i)� -s� ,`E'r� � �', Co��a�a�s i`ar �/20/07 k2��vi�le C��y ��r��cil 1V.[e�tia�g 'T'�Y� l�c�� 1. When is an "updaie" no longe� art "update?" This "u}�daie" appears ta be a r�ew AiJAR. This assertion is based upor� the changes in fY�e underlying assumptions as we[f as the changes in subareas. Bpth of th�se al�erations make it �ery di�fic�l# to actua[ly campare and anafyze the changes �ar�icufarfy with respect to density, ir�tensity, and traffic. These key facfors are essential ta any meanir�gful en�ironmental review. Furihermore, if thi5 is a new AUAR and not art update, then the review prncass iay the agenei�s and ti�e publie should be greafer. 2. An At�AR under �QB t'ules must have a scenario cortsistent with tE�e Corr�prehensive Pian. When the �win l.akes M�st�:r Plan was amenc�ed intp the Compref�ensive Pfan it specifica[iy outlined the developm�nt �pproved in this area. �n the Friends csfi Twin �akes litigation the cour� statect that this plan was part of the Camprehensi�e Pfan. ihis "upda�ed" AUAR has no scersario consister�t with the Twin Lakes Mast�r Plan as Arnended to the Carnpreher�siv� Pian nn June 26, 2f3�1. Transcripts of the Council Meeting where i�e Amendmen� was discusse� and passed clearly out[ine the r�asons that the "Retail 5cehario 1A° w�s speeifically deleted from the amend�-r,ent. !t a[so pr�vides a c�ear and comprehensive disctrssion of the r�asor�s ik�e st�ff sup�aorted and the Co�ncil ap�rov�c! arsly Scenar€o 1 for ihe area. (f more sttpport than the transcript of ihe meeting is needed, Page 9 of �he Twir� L.akes Master Plan ir�cS�des a char# sta�Eing 0% retail bath before ancf after redevelopment. 3. ]t appears frorr� the sc�narios proposect in this AUAR "update° that �he ir�crease in density and reiail is consisieni with �xac#ly the "�2etaiE 5cenario 9A" of the Twin Lakes Master #'lan— exaetly the scenario that was re�ected by tF�e Council and is nat part of the Comprehensiv� P1an. �. As for t�e additianaf anvironmental re�iew rec{uested by ft�e Couri in t�e Tv�+ir� La�Ces Iitigaiion, it has not been done {with the exc�ptinn of a bit for Xtra L��se �nd Olcf Dominion). There has been na additionaf work trying ta identify the source af TC� canfar�inaf�on irt the ground water. In fact, it is known t[�at th�re is TC� in the ground water fror€� the five monitoring wel�s. What the cify h�s failed to do at eitf�er �he request of citizens or the caurt is to cons�ruci additional wells fa see if the TC� is fiowing acrass th� sit� or originating on the site in iso[ated pqekets, The AUAR cannot conclude that there are "no kr€own hazards tQ groundwater" wl�en there are known t€� be at leas� pockets of TC� w�ich are now qr couid be due to eanstruction ieaking into the groundwa#er. ]n spite of comment�ry in the newspaper and comments by fhe DNR and the U.S. Fish and Wifdlife Serviee in tl�e �AW review pracess fot� the proposect t�orthwesterrr Cof�ege expansion, tf�is ALiAR faiis tn pro�ide any ar��lysis of perm�nent or rnigratory wifdlife in the area. Th'ss AfJAR wishes to rest uppn the fact that ti�ere are no "endangered species" here rath�r than address the requests of the D[�R and U.S. Fis� anc4 Wildlife Ser�ice regarcling great coneern �ar tY�� s�-na[I amount and continuir�g loss of wild[ife habitat in the norfhern suburbs. The wildiife corridor from Langton �ake tfl Oasis Pond alang the d'€teh to �itt[e La1ce Johanna and on to Lake Johanna is a critic�l wildiife habifat area. Testimony during the Twin Lakes re�i�w and lifigation by a noied birder and facu�iy merx�ber of the �lniversity of