99-8680r
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RESOLUTION NO. 8680
THE CITY OF RICHFIELD, MINNESOTA
RESOLUTION APPROVING NEGATIVE DECLARATION AND RECORD OF DECISION
WHEREAS, Richfield State Agency, a Minnesota corporation (" RSA"), is the Proposer
of a 14.4 acre mixed use development located between 66th Street and 67th Street and
between Lyndale Avenue and Pleasant Avenue in the City of Richfield ("Project"); and
WHEREAS, the Project is proposed to include 207,000 gross square feet of retail and
office space, 216 housinQ units, and total parking of 1,065 spaces; and
WHEREAS, the City requested that the Proposer voluntarily prepare an environmental
assessment worksheet ("EAW'); and
WHEREAS, the City is the Responsible Governmental Unit ("RGU") pursuant to Minn.
Rules Part 4410.4300, subp. 14 (1995); and
WHEREAS, an EAW was prepared by the City with assistance from the Proposer,
who submitted completed data portions of the EAW to the City consistent with Minn. Rules
Part 441Q.1400 (1995); and
WHEREAS, the EAW was prepared using the form approved by the Minnesota
Environmental Quality Board ("MEQB") for EAWs in accordance with Minn. Rules Part
4410.1300 (1995); and
WHEREAS, the City issued the EAWon December 8, 1998, and provided a copy to
the MEQB on the same day; and
WHEREAS, the City with assistance from the Proposer has prepared a proposed
Record of Decision on the EAW for the Project for consideration by the City Council ("Record
of Decision"), which is attached hereto as Exhibit A; and
WHEREAS, the City staff has reviewed the proposed Record of Decision and has
found the Record of Decision to be consistent with the evidence submitted to the City and the
applicable statutes and regulations, to the best of their knowledge, and has recommended
that the City Council approve the Record of Decision and determine that no environmental
impact statement ("EIS") is necessary, reasonable or warranted with respect to the Project
under the circumstances; and
WHEREAS, the City Council desires to make the Findings of Fact and Conclusions
which are contained within the Record of Decision and to conclude that no EIS is required
with respect to the Project ("Negative Declaration").
Resolution No. 8680
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NOW, THEREFORE, BE IT RESOLVED that the City Council does hereby:
1. Adopt and approve the Record of Qecision on the Urban Village EAW in the form
which is attached hereto as Exhibit A and hereby makes the Findings of Fact and
Conclusions which are contained therein; and
2. Find and determine that, based upon the Record of Decision, no environmental
impact statement is required for the Project pursuant to the Minnesota
Environm~ntal Policy Act or Minnesota Rules Parts 4410.0200 to 4410.06500
(1993).
Adopted by the City Council of the City of Richfield, Minnesota this 22nd day of
February, 1999.
ATTEST:
~~1 f?Cf.v-,
Thomas P. Ferber, City Clerk
Res. No. 8680
RECORD OF DECISION ON THE URBAN VILLAGE
ENVIRONMENTAL ASSESSMENT WORKSHEET
The Environmental Assessment Worksheet (EAW) for Urban Village (Project) is before
the City Council of the City of Richfield to determine whether an Environmental Impact
Statement (EIS) is required for the Project. The City Council has reviewed the record in this
matter, including the EAW, comments from governmental agencies and a citizen, and
proposed responses to comments. Based on this review, the City Council makes the
following findings of fact and conclusions:
FINDINGS OF FACT
A. Compliance with Procedures of the Minnesota Environmental Policy Act and
Minnesota Rules Parts 4410.0200 to 4410.6500 (1993)
1. The Proposer of the project is Richfield State Agency (RSA).
2. The Project is a 14.4 acre mixed use redevelopment project located at the
southeast corner of 66th Street and Lyndale Avenue. The Project includes a
mixture of new housing choices, retail, office and public spaces. The Project area
currently includes a 95,000 square foot bank building, 22,000 square foot medical
clinic, and 15 single family homes. The Project maintains the two commercial
structures and incorporates an additional 90,000 square feet of office/retail space,
a free-standing McDonald's building, 138 townhome and flat-style apartments, 78
assisted living units, and 1,065 parking stalls both on-grade, below-grade and in a
central parking ramp.
3. The EAW is not mandatory but is being prepared voluntarily by the developer.
4. The Responsible Governmental Unit (RGU) is the local governmental unit, the
City of Richfield (City).
5. An EAW was prepared by the City with assistance from the Proposer, who
submitted completed data portions of the EAW to the RGU.
6. The EAW was prepared using the form approved by the Minnesota
Environmental Quality Board (MEQB) for EAWs.
7. The City issued the EAWon December 8,1998 and provided a copy to the
MEQB on the same day.
8. On December 15, 1998 the City mailed one copy of the EAW to all agencies
listed on the official MEQB mailing list.
9. Notice of availability of the EAW was published in the EQB Monitor on December
14, 1998.
10. On December 30, 1998 the City provided a press release to the Sun-Current,
which contained a notice of availability of the EAW for public reivew. The press
release also included the name and location of the Project, a brief description of
the Project, the location at which copies of the EAW were available for review, the
date the comment period would expire, and the procedures for commenting.
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11. The comment period on the EAW began December 14, 1998. The comment
period ended at 4:30 p.m. on February 6, 1999. Minn. Rules pt. 4410.2100,
subp. 3 (1995).
12. The Sun-Current published the notice of availability in its Wednesday, January 6,
1999 edition.
13. During the 30 day comment period, copies of the EAW were available for public
review at the Richfield City Hall, 6700 Portland Avenue, and at the Augsburg
Branch of the Hennepin County Library, 7100 Nicollet Avenue, both in Richfield,
Minnesota.
14. During the comment period, the following written comments were submitted:
A. Metropolitan Council letter dated January 11, 1999.
B. Minnesota Department of Natural Resources letter dated January 12,
1999.
C. Minnesota Pollution Control Agency letter dated January 13, 1999.
D. Minnehaha Creek Watershed District letter dated January 13, 1999.
E. Larry Wozniczka letter and petition delivered to the City on February 1,
1999.
F. Larry Wozniczka letter dated February 4, 1999.
15. During the comment period, the U.S. Fish and Wildlife Office and the Minnesota
Department of Transportation reported that they had no concerns regarding the
EAW or the Project.
B. Responses to Comments
A. Metropolitan Council
1. Comment: Current Council housing policy encourages the expansion of availability
and quality of housing choices, regarding both type and price, throughout the region.
This proposal is for the addition of 78 assisted living units and 138 multifamily units.
Richfield is a participant in the Livable Communities Act Housing Incentive Program
and has negotiated housing goals related to affordability, diversity and mix. Because
there are no details in the EAW submittal regarding the anticipated prices or rents for
the units, it is not possible to determine if this project will assist the community in
meeting its housing affordability goal. However, the addition of multifamily units will
assist the community in meeting its goals to diversify its housing stock.
Response: For Richfield, the Metropolitan Council's Livable Communities Program
encourages more housing choices and fewer affordable choices. The stated Richfield
goal is to increase the ratio of higher rent units to affordable rent units. To accomplish
this goal, 250 units that provide higher rents should be added by 2001. The 138
town home and flat-style apartments in the Urban Village development accomplish part
of this objective. The rents are as follows:
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Bedroom Mix, 138 units Square feet Est. Rent/Month
6 - efficiencies 750 $750
3 - 1 bedroom 800 $800
3 - 2 bedroom 1 ,000 to 1,100 $1,000
26 - 1 bedroom 771 to 895 $900
80 - 2 bedroom 972 to 1,296 $1,200
20 - 3 bedroom 1,296 to 1,450 $1,500
Some affordability, 12 units to be rented to households with incomes of less than 70
percent of the median for the metropolitan area, is being provided. However, these
units provide a higher rent than existing Richfield apartments and remain a part of the
total number of units which help to achieve Richfield's Livable Communities objectives.
2. Comment: The EAW states that runoff will increase, but the increase will not be
significant. However, no effort is made to quantify the change in stormwater quantity
or quality. Without this information, the water quality and quantity cannot be compared
before and after the project. Given the limited scope of this project and its location, the
reviewer agrees that the stormwater impacts are likely to be minimal, but this
statement should be supported by, at a minimum, a simple pollutant load calculation.
An example of a simple pollutant load calculation is given in Protecting Water Quality
in Urban Areas (MPCA 1989).
Response: Current calculations based on mixed-use models, both before and after
development indicate a 26 percent increase in phosphorous loading. This would
represent a worst case scenario.
Note: Design revisions as noted in item #3b (below) are underway to reduce and
provide more effective filtering of stormwater runoff. More accurate modeling will be
completed once these design revisions are identified, and the current condition
assumptions will be updated to more accurately reflect the residential area loading
now that survey information is available.
3. Comment: Sections a and b also discuss efforts to treat runoff using stormwater
detention ponds; however, no information is provided that can be used to assess the
probable treatment efficiency of the proposed ponds. If a standard pond design is
being used, then the EAW should state it. For non-standard pond designs, an
estimated treatment efficiency should be provided. Without this information, the net
impact of the receiving water body cannot be determined.
Response: According to Pete Willenbring, P.E., WSB, City of Richfield Drainage
Consultant, the specific treatment efficiency for the proposed Richfield Lake treatment
ponds is not available at this time. However, it is anticipated that the regional pond
system proposed for construction in the year 2000 will provide treatment for over 80
percent of the suspended solids and over 40 percent of the phosphorus generated by
this project on an annual basis, prior to discharging into the main basin of the lake.
4. Comment: The metropolitan interceptor has adequate capacity to accommodate the
additional flows generated by the development. MCES interceptor I-RF-490 is located
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immediately adjacent to the site (north within West 66th Street), which lends itself to
direct service connection for the site. If additional service connections to the
interceptor are proposed, or if changes to existing service connections to the
interceptor are necessary, then a permit application for Connection to and Use Permit
to the MCES is required.
Response: A permit application will be submitted to the MCES for this project.
5. Comment: The EAW should include text explaining why no background growth is
assumed for traffic.
Response: During the development of traffic forecasts for the Richfield Urban Village
site, the growth in background traffic was considered. At that time it was determined
that the effects of background traffic on the traffic forecasts were negligible. This was
based on a historical review of traffic data that showed no significant increase (less
than half a percent per year) in traffic volumes on either 66th Street or Lyndale Avenue
in the past ten years.
6. Comment: The Urban Village Project east property line is a regional trail. The trail is
planned on the existing railroad right of way. The EAW should be revised to answer
affirmatively the question under Item 26, that the regional trail is in proximity to the site.
Hennepin Parks and Richfield Recreation Services should receive copies of the EAW
for review and comment.
Response: The regional trail referred to is currently a proposed trail. If completed, the
trail would be in direct proximity to the east edge of the proposed development.
Copies of the EAW have been sent to Hennepin Parks and the City of Richfield
Recreation Services Department. The Recreation Services Department has
responded that they see the project as a positive enhancement to the future trail.
B. Minnesota Pollution Control Agency
1. Comment: As noted in the EAW, an Indirect Source Permit (ISP) is required for this
project. Included in the EAW is a detailed traffic impact study, which includes ADT,
trip generation, and level of services (LOS) capacity analysis. The LOS analysis
indicates that all of the key intersections in the project area are expected to operate at
LOS D or better using post-development traffic volumes and existing roadway
geometry and intersection traffic control. The proposed revision to the left turn signal
phasing at the 66th Street/Lyndale Avenue intersection should be implemented to
decrease the left turn queue lengths during peak traffic periods.
Response: An Indirect Source Permit (ISP) application has been completed and was
submitted to the MPCA on February 3, 1999. The ISP identified revising the left turn
signal phasing to mitigate queue lengths that could potentially exceed the available left
turn storage during peak period traffic periods. The need to modify the signal phasing
will be monitored by the City.
2. Comment: The EAW also addressed air quality impacts of the increased traffic. The
air quality analysis conducted for the project shows that both the one-hour and eight-
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hour maximum carbon monoxide (CO) concentrations are below the state ambient air
quality standards. The air quality arialysisis based on the results of the traffic impact
study, and the traffic analysis. was performed for both the existing and post-
development conditions. However, it is not clear what year the post-development
conditions and the predicted maximum CO concentrations represent. Because an ISP
is needed for the project, the traffic and air quality analysis should be completed for
one year after project completion. The project proposers' consultant is in
communication with Mary Hoffman-Lynn of our Policy and Planning Division regarding
ISP issues.
Response: Post-development traffic volumes in the EAW represent the Year 2001.
Predicted maximum CO concentrations were analyzed in the EAW using Year 2000
emission factors to represent the first year of operation. However, the analysis has
been revised for the ISP application utilizing Year 2001 emission factors to represent
the first year after expected completion of the proposed development. All of the Year
2001 worst-case predicted CO concentrations are below the state ambient air quality
standards, including estimates of background CO concentrations of 3.5 ppm (one-hour
average) and 2.9 ppm (eight-hour average). Year 2001 worst-case predicted CO
concentrations are also below those predicted for Year 2000 in the EAW.
3. Comment: As noted in the EAW, a general National Pollutant Discharge Elimination
System (NPDES) permit for construction activities is required. Should you have any
questions about stormwater issues, please contact Keith L. Cherryholmes, Ph.D. at
(651) 296-6945.
Response: An NPDES permit will be obtained.
C. Department of Natural Resources
1. Comment: Item 14 correctly notes that the site is subject to the planned unit
development (PUD) section of the Shoreland Management rules because it falls within
the shoreland district of Richfield Lake (#27-21P) and Wood Lake (#27-26P). A
project plan must be submitted to the DNR Division of Waters for approval. The
review process evaluates a number of project parameters, including unit densities as a
function of site tiering, the amount of impervious surface creation, and the amount of
open space designation. Ceil Strauss, DNR Area Hydrologist, should be copied with a
project plan once it becomes available for review; she can be contacted at (651) 772-
7910.
Response: The project plans will be submitted to DNR for review. Ceil Strauss, DNR
Area Hydrologist has been contacted regarding the upcoming project submittal.
2. Comment: Regarding the project-related increase impervious surface, we are
disappointed that the project does not include impervious surface reduction as a
project feature. Opportunities can be present in redevelopment projects such as this
to reduce the amount of impervious surface present at a site. Increasing impervious
surface creates additional storm water treatment and management requirements. This
project results in a 2.2 acre increase in impervious surface, which represents
approximately a 16% increase post-project.
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Response: The project's landscape Architect is currently refining the design to reduce
the hardscape concrete impervious area. Additionally, a turf area will be considered
that is planned to capture a portion of the project area's stormflow and provide
infiltration into the ground instead of discharging into the public storm sewer piping
system.
3. Comment: Item 18 indicates that runoff will be directed to a regional stormwater pond
that will be created concurrently with this project. We strongly recommend that the
regional pond be constructed prior to the start of mass grading for this project.
Regardless of the erosion control methods employed, a large storm event at the wrong
time could introduce a large, concentrated amount of sediment into Richfield lake over
a short period of time. Therefore, it is prudent to have the regional pond prepared to
accommodate project-related flows off the site.
Response: According to George Atkinson, City of Richfield Engineering Department,
the regional stormwater treatment pond system planned to intercept the stormwater
prior to discharging into Richfield lake is scheduled to be constructed in the year
2000. The existing storm sewer currently flows through a 100 foot vegetated swale,
which will continue to provide a level of treatment during the construction period.
4. Comment: Also regarding the regional storm water treatment pond, it should be noted
in Item 12 as a related project that has the potential to result in physical impacts on
water resources.
Response: The City of Richfield acknowledges that the regional pond system
proposed for Richfield lake will impact existing water resources, and intends to submit
the project for a DNR permit this month, according to George Atkinson, City of
Richfield Engineering Department.
5. Comment: During the PUD review, opportunities to reduce runoff by increasing
infiltration onsite will be evaluated. Measures include infiltration trenches, bioretention
areas adjacent to parking areas, or use of advanced turfs in overflow parking or similar
areas.
Response: The project plans will include extensive unpaved areas throughout the
project area that will allow infiltration of stormwater. Additionally, as noted in ESG item
number 3b above, a centralized turf area is being considered that will capture a portion
of the project area stormflow and provide infiltration into the ground instead of
discharging into the public storm sewer piping system.
6. Comment: We recommend use of native species where applicable in landscaping
efforts.
Response: The complete project will be characterized by extensive landscaping at
building sites and common spaces. Where feasible and appropriate, plant species
native to the Twin Cities will be incorporated into the design.
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Res. 8680
D. Minnehaha Creek Watershed District
1. Comment: A major area of concern by the Minnehaha Creek Watershed District
(MCWD) is erosion control. The EAW address that concern adequately in the listing of
temporary erosion control measures. A regular (daily or weekly) schedule of cleaning
soils tracked onto public streets from the construction site should be established
before the project begins. The MCWD will require an erosion control permit for the
project.
Response: The Contractor will be responsible for developing and enforcing an erosion
control plan for the project to include regular street cleaning. In regard to an erosion
control permit, we have been informed by George Atkinson, City of Richfield
Engineering Division, that the Richfield City Council is now the authority to review and
approve erosion control plans instead of the MCWD, and we have been instructed to
submit the project to the City for permit requirements.
2. Comment: We recommend the inclusion of best management practices (BMPs) to
supplement the treatment of stormwater runoff. Such devices as sump catch basins
and/or oil and grit separators will improve the efficiency of the proposed stormwater
management plan.
Response: Construction plans will show typical BMPs for use during construction.
The Contractor and the City will be responsible for the operation of the stormwater
management plan. The final design will consider permanent BMPs for construction
and use during the operation of the site.
3. Comment: The proposed retention pond near Richfield Lake should be designed and
constructed to NURP standards to ensure maximum removal efficiency.
Response: According to Pete Willenbring, P.E., WSB, City of Richfield Drainage
Consultant, the specific treatment efficiency for the proposed Richfield Lake treatment
ponds is not available at this time. However, it is anticipated that the regional pond
system proposed for construction in the year 2000 will provide treatment for over 80
percent of the suspended solids and over 40 percent of the phosphorus generated by
this project on an annual basis, prior to discharging into the main basin of the lake.
4. Comment: The MCWD may require a stormwater permit for this project. We
encourage discussion with the Richfield Bloomington WMO concerning the drainage
and stormwater issues.
Response: According to George Atkinson, City of Richfield, as noted above, the
Richfield City Council is now the authority to review and a approve stormwater permits
instead of the MCWD, and we have been instructed to submit the project to the City for
permit requirements.
E. February 1, 1999 Letter from Larry Wozniczka and Petition
1. Comment: Provide access to McDonald's Restaurant from 66th Street.
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Response: Additional vehicular circulation routes through the site are considered to
be at odds with the developer's and the City's goals of providing additional public open
space that is pedestrian-friendly. Vehicular access as proposed has been reviewed
and determined to be adequate to serve the anticipated traffic.
2. Comment: Connect 66th Street to Lyndale Avenue through the project to reduce
added loading at the intersection of these two streets while serving the project's
business needs.
Response: The possible connection of these two streets through the project was
reviewed. In consultation with the City of Richfield's Engineering department and
neighborhood group planning meetings, it was agreed that a "bypass" traffic pattern
was not desirable due to the potential for increasing traffic on streets immediately
adjacent to single-family residential neighborhoods. The traffic studies and analysis
done indicated no decrease in service level at the 66th & Lyndale intersection.
3. Comment: Require that all traffic points within the project can be traversed without the
need to leave and return to the project using 66th Street and Lyndale Avenue.
Response: The project as designed allows movement throughout the site through the
parking structure. This access connects all commercial aspects of the site and the
majority of the housing parking. Only the 27 stalls of multifamily housing guest parking
east of the multifamily building would require the use of Lyndale Avenue or 66th Street
to gain access.
4. Comment: Work to achieve a business bypass south of 66th Street to reduce
residential pass through traffic which occurs whenever 66th Street or Lyndale Avenue
are obstructed.
Response: 70th Street is the next collector street with a traffic signal. 66th Street and
70th Street provide adequate collector capacity for the area.
5. Comment: Preserve 67th Street as a state-aid street, extending it over the railroad
tracks to serve Academy of the Holy Angels and St. Peter's Church and School as a
means of offsetting growth in traffic on residential streets resulting from the Urban
Village project.
Response: 66th Street is a currently a collector street; the spacing of collector streets
should not be that close. Running a collector through the Academy of the Holy Angels
and St. Peter's Church and School would also be disruptive to these two properties.
6. Comment: Encourage the addition of a north access to the Academy of the Holy
Angels allowing entry of traffic from the west and exit to the east and west at 66th
Street and Pillsbury Avenue
Response: Additional access points on 66th Street are not advisable. Good access
management attempts to limit the number of driveways on arterial streets for safety
and traffic flow reasons. The Urban Village project is eliminating an access onto 66th
Street.
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Kes. OOOU
E. February 4, 1999 letter from Larry Wozniczka
1. Comment: The operations analysis on page 12 states the traffic increase on 68th
Street as 34 percent. The increase is 52 percent using the figures of 600 additional
vehicles per day over existing 1150 vehicles per day.
Response: The comment is correct; an increase of 600 vehicles per day is 52 percent
over the existing daily traffic volume of 1,750.
2. Comment: The expected directional distribution of traffic shows 66th Street carrying
20 percent and 68th carrying 10 percent of the traffic to the east. On this basis the
additional 3825 daily trips resulting from the project will add 382 trips on 68th Street.
Additional increases result from the disconnect of Grand and Pleasant Avenues. A
concern is that 68th Street will carry half as much traffic as 66th Street from the
project.
Response: This comment appears to be correct. Of the new traffic generated on the
site, 66th Street is being assigned twice as much traffic as is being assigned to 68th
Street.
3. Comment: Locating the drive-through elements of the project at Lyndale Avenue and
67th Street creates a situation where residential 68th Street enables traffic from south
Nicollet Avenue a shorter path, with two less turn lanes, and three fewer traffic lights.
A concern is the lack of access to McDonald's Restaurant and Auto Tellers from 66th
Street.
Response: Orienting the drive through elements of the project to 67th Street was
primarily a site layout issue that was based on recommendations by the site planners
and architects (Fred Hoisington, Art Bartels and David Graham). However this
decision is also supported by the fact that 66th Street is a Hennepin County arterial
roadway with access spacing guidelines that would not allow closely spaced individual
commercial driveways. 67th Street is a local roadway whose function is to provide this
kind of local access. Safer traffic movements also result from removing the current
access to McDonald's at 66th Street.
4. Comment: Internal streets should enable vehicular movements between any two
elements within the project without the need to exit onto and reenter either 66th Street
or Lyndale Avenue. Use of a major street to enable intra-project travel adds to
congestion, pollution and delays which encourage traffic to cut-through nearby
residential streets. A concern is that streets connecting all elements within the project
are not provided.
Response: Additional vehicular circulation routes through the site are considered to
be at odds with the goals of providing additional public open space that is pedestrian-
friendly. Vehicular access as proposed has been reviewed and determined to be
adequate to serve the anticipated traffic. The project as designed allows movement
throughout the site through the parking structure. This access connects all
commercial aspects of the site and the majority of the housing parking.
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5. Comment: Lack of a street to carry local business traffic through or around the project
between Lyndale Avenue and 66th Street adds to congestion at the intersection of
those streets. A concern is that the absence of such a business access street restricts
business operations, jeopardizes emergency service and invites traffic to use
residential 68th Street.
Response: The lack of a reliever street adds to traffic, but it does not cause
congestion. Emergency service will be altered but not jeopardized. The Public Safety
Department has reviewed and approved the traffic circulation plan. The traffic analysis
does not support the conclusion that business traffic will use 68th Street.
6. Comment: Multiple entry points to the project on 66th Street and Lyndale Avenue
contribute to delays on those major streets. A concern is that a business access street
with one entry on each of 66th Street and Lyndale is not planned.
Response: Planning for access must balance access with the safety and mobility of
the arterial streets. The Urban Village plan has been reviewed and considered
acceptable from the City and County's access management guidelines.
7. Comment: Vacation of Grand and Pleasant Avenues between 66th and 67th Streets
creates a span of about a half mile without public access between 66th and 67th
Streets. Property owners have tolerated pedestrian trespassing of St. Peter's and
Academy of Holy Angels properties in route to busses [and] shopping. The project
includes pathways that would also serve pedestrian needs. Concern about the rights
of pedestrians to use these private paths raise questions such as liability, public safety
access, and the possibility that at some future date pedestrians from neighborhoods
south of 67th Street will have to hike to sidewalks on either Nicollet or Lyndale
Avenues to go north.
Response: The project is providing more pedestrian access with less vehicular conflict
than presently exists. The future Soo Line regional trail further enhances north/south
movements. Nothing in the plans for the project lead to a conclusion that public paths
are private.
8. Comment: Worst case carbon monoxide concentrations are predicted at 8.7 ppm
compared to a maximum safe standard of 9.0 for the 8-hour average in the project
quadrant. The safety of locating an Assisted Living Facility in an area of marginal air
quality is questioned.
Response: Subsequent to the EAW, the worst-cast predicted carbon monoxide (CO)
concentrations analysis has been revised for the purpose of an Indirect Source Permit
application utilizing Year 2001 emission factors to represent the first year after
expected completion of the proposed development. All of the Year 2001 worst-case
predicted CO concentrations are below the state ambient air quality standards and are
also below those predicted for the Year 2000 in the EAW. The Year 2001 predicted 8-
hour average value at Receptor 3 (southeast quadrant) is 6.4 ppm, which is lower than
the 8.7 ppm predicted for Year 2000. The worst-case predicted CO concentrations
include estimated background CO concentrations of 3.5 ppm (one-hour average) and
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2.9 ppm (eight-hour average) as recommended by the MPCA. These estimated
values were determined by using Year 1996 maximum observed CO background
concentrations at a site (Heredia. Park) located one mile from the proposed
development and applying adjustment factors to convert 1996 concentrations to 2001
concentrations.
9. Comment: The extent of air quality degradation in the single family residential
neighborhood as a result of this project is not presented. Neighbors should be
informed and be given consideration in cases of medical risk.
Response: The air quality analysis focused on the worst-case condition in the vicinity
of the proposed project which is the intersection of 66th Street and Lyndale Avenue.
Other locations further from the major intersections would experience CO
concentrations less than those predicted immediately adjacent to the intersection. The
state ambient air quality standards are set at levels to protect the most sensitive
portions of the population. The air quality analysis was based on worst-case
meteorological assumptions to identify the maximum potential future CO
concentrations. The analysis did not indicate any potential for CO concentrations in
excess of the state standards so no significant health risk is indicated.
10. Comment: Increased traffic on residential 68th Street, in addition to air quality effects,
presents a hazard to students and pedestrians who walk to Academy of Holy Angels,
Blessed Trinity School and the Church of St. Peter.
Response: While there may be increased traffic on 68th Street, it does not present a
hazard for pedestrians. The traffic increase represents vehicular movements by the
neighborhood, not due to business traffic short cuts.
11. Comment: Single family residences along 68th Street typically have side yards with
reduced setback distances along 68th Street. In addition to making environments
impacts more critical, increased traffic on 68th Street presents a hazard to families
with children.
Response: Again, while there may be increased traffic on 68th Street, it is not at the
level that would present a hazard to families with children.
12. Comment: Taking of a block of affordable single family residences which are not
blighted for the purpose of adding up-scale rental requires evaluation. Concerns
include: Will the present owners be given relocation costs assure them of comparable
housing? Is there a public purpose to justify condemnation? Will the planned rental
maintain an appeal or will it depreciate more quickly than existing residential over
time? With 33 percent of Richfield's housing units now in rental, is additional rental
appropriate for Richfield? Does valuation history of similar developments, such as The
Colony at 1-35 and 76th Street, keep up with residential standards?
Response: These questions are part of the development review process rather than
the EAW. As indicated on page 2, in the response to the Metropolitan Council,
Richfield as a "Livable Communities" objective to provide higher value rental housing.
At a November 23, 1998 public hearing, the City Council determined that there was a
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public purpose for redevelopment and that the single family residences were
sufficiently blighted to qualify the area for redevelopment. The "Contract for Private
Redevelopment" approved by the HRA, November 16, 1998, requires relocation
compensation with comparable housing. The proposed housing has a high level of
low maintenance, durable finishes planned. Village Shores (1986), the newest rental
housing in the area, continues to have appeal and value.
13. Comment: The increased density of the proposed development raises the question of
increased City services. City code for high density multi-residential requires a
minimum of 2000 square feet of land for each unit. Within a block estimated at 600
feet by 300 feet, the project includes 138 dwelling units or only 1304 square feet per
unit. It is likely that upscale clientele will require additional city recreational services.
A concern is that the EA W does not consider resulting costs.
Response: The City Council, Planning Commission and HRA have dealt with the
issues of density in evaluating and approving the Planned Unit Development. The
PUD is contingent on the EAW only because the EAW finding is sequentially the last
decision to be made to ensure the public had sufficient time to review the EAW.
Findings on density are not required in the EAW. The HRA and City Council project
approvals in November, 1998 considered the cost of services to the new development.
City services will stay level or decrease.
14. Comment: The project's impact on property taxes requires special scrutiny since the
project is planned as a tax increment district, not just for the redeveloped block, but
including the larger commercial portion of the project which has been in a tax
increment district for nearly 25 years and is planned to be decertified from the LHN
Tax Increment District and brought into the Urban Village Tax Increment District.
Concern is that the added costs for local services to the project will have to be covered
by property tax increases outside of tax increment districts and that there is no
disclosure of estimates.
Response: The City Council and HRA approved the formation of the Urban Village
Tax Increment district in November, 1998. The EAW does not evaluate the use of tax
increment. Eligible project costs are paid for with tax increment on a pay as you go
basis. Tax increment is sufficient to pay for the designated costs. Added cost of
service is not anticipated.
15. Comment: The project proposes to vacate part of 67th Street, which is not a state-aid
street. The economic impact to the City for loss of state aid and maintenance of new
loop streets is a concern.
Response: State Aid is not evaluated in the EAW process. However, the following
information may clarify the role of 67th Street in the City's system. The City may
designate as much as 20 percent of its streets as MSA roads. We currently designate
the limit of 20 percent. The City's annual MSA allotment is, in part, based on the
condition of those streets which comprise our MSA system (20% of our streets).
Removing MSA designation from 67th Street will reduce our overall allotment by
approximately $7341. Richfield's overall allotment for 1999 is $958,768 of which 25
percent or $239,692 will go toward maintenance. The staff plans to go to the Council
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Res. 8680
to request removal of designation of various streets in of our system and the
designation of other streets.
16. Comment: A business access street, either through or along the south and east
boundaries of the project, would serve the project needs and mitigate a number of
impacts by connecting Lyndale Avenue at 67th Street to one point on 66th Street. The
Urban Village project provides an opportunity to implement a business access street
east of Lyndale Avenue.
Response: This option was considered; however, traffic circulation studies showed
there was and would be low demand for this movement. Further, retaining a full
service 67th Street prevents the proposed traffic separation between the development
and the south residential neighborhood; a separation desired by the neighborhood.
17. Comment: Continuation of 67th Street to the east of Pleasant Avenue enables the
business access street to serve the Academy of the Holy Angels (AHA), the sports
facility and the Church of St. Peter. This more direct traffic route would reduce traffic
on 68th Street, thus offsetting some of the predicted increase from the project.
Response: While this solution might reduce neighborhood traffic on 68th Street, it
would split AHA's property and greatly diminish the value and function of both AHA's
and St. Peter's properties. Since business traffic is not a significant impact on 68th
Street, this proposal is not relevant to the analysis of the Urban Village project.
18. Comment: Access to AHA from 66h Street at Pleasant Avenue has been suggested.
An entry from the west and exit to the east and west at the existing 66th and Pleasant
traffic signal would be compatible with movements into the Hub Center. The reduced
AHA traffic on neighborhood streets would offset some of the increases from the
Urban Village project.
Response: Additional access points on 66th Street are not advisable. Good access
management attempts to limit the number of driveways on arterial streets for safety
and traffic flow reasons. The Urban Village project is eliminating an access onto 66th
Street. The addition of an access at east Pleasant would also interfere with
stormwater ponding and other improvements at AHA.
19. Comment: Promote pedestrian walkways around the project, especially to serve the
schools to the east. A pedestrian crossing over the rail tracks at 67th Street would
enable access to AHA and proposed City operation of shared ball fields. Reduction of
some vehicular traffic would also offset some of the traffic increases from the project.
Response: This is a good suggestion. The connection may not be possible at this
time given the current railroad operation and ownership, but when the corridor is
converted to a trail, the City would encourage this type of access. Pedestrian
movement is enhanced if vehicular access is not provided at 67th Street and Pleasant
Avenue.
20. Comment: Several comments concerning the process and the availability of the EAW
are made.
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Response: The City Council resolution and the first part of these Findings of Fact
explain the process that was followed in making the EAW available for review.
CONCLUSIONS
1. The EAW was prepared voluntarily by the City and the developer. An EAW was not
required for the Project by statute.
2. Substantive comments received during the comment period have been responded to
by the City and Richfield State Agency.
3. The type and extent of the environmental impacts described in the EAWand in the
comments are minimal.
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