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05-21-01 AgendaCITY OF RICHFIELD, MINNESOTA SPECIAL CITY COUNCIL MEETING MONDAY, MAY 21, 2001 COUNCIL CHAMBERS 6700 PORTLAND AVENUE IMMEDIATELY FOLLOWS CITY COUNCIL STUDY SES.SION_ AGENDA Call to order Roll call 1. Consideration of resolution regarding petition requesting Environmental Assessment Worksheet for 76th Street road project Staff Report No. 107 Notes: 2. Consideration of request for outside service of alcohol to cover patio service area for Wiltshire Restaurant, LLC d/b/a Houlihan's Restaurant & Bar, 6601 Lyndale Avenue Staff Report No. 108 Notes: Adjournment Auxiliary aids for individuals with disabilities are available upon request. Requests must be made at least 96 hours in advance to the Administrative Services Director at 612-861-9702. • AGENDA ITEM # 1 REPORT # 1 ~ 7 • STAFF REPORT CITY COUNCIL MEETING MAY 21, 2001 REPORT PREPARED BY: JULIE URBAN, COMMUNITY DEVELOPMENT SPECIALIST Nance, TITLE REPORT PRESENTER:. BRUCE PALMBORG, COMMUNITY DEVELOPMENT DIRECTOR NAME, TITLE DEPARTMENT DIRECTOR REVIEW: ~~~ REVIEWED BY CITY MANAGER: 1~ ITEM FOR COUNCIL CONSIDERATION: Consideration of a petition requesting an Environmental Assessment Worksheet for the 76th Street road project. I. RECOMMENDED ACTION: By Motion: Adopt the attached resolution denying the petition requesting an Environmental Assessment Worksheet for the 76th Street road proiect. III. BACKGROUND I A petition was filed with the Environmental Quality Board (EQB) requesting the preparation of an Environmental Assessment Worksheet (EAW) for the reconstruction of 76th Street between Penn Avenue -and I-35W. The EQB referred the petition to the City as the Responsible Governmental Unit (RGU) for response. 0521-76thEAW • III. BASIS OF RECOMMENDATION A. POLICY • The policy ofthe City is to determine which, if any, environmental evaluation thresholds are met by a proposed project. In this situation, the City studied the impacts of the reconstruction of 76th Street in the Best Buy Environmental Impact Statement (EIS) although the EQB Rules For Environmental Review (EQB Rules) do not require a mandatory EAW on the reconstruction of 76th Street. B. CRITICAL ISSUES The EQB .Rules do not require a mandatory EAW on the reconstruction of 76th Street; however, the City studied the impacts of the 76th Street project in the Best-Buy EIS: The analysis of 76th Street in the Best Buy EIS shows that, with the improvements included as part of the Project, all intersections would operate at acceptable levels of service and local streets would not experience traffic congestion due to Project traffic. In addition, no violation of state or federal air quality standards for carbon monoxide would result from the Project. Also, the impacts on property owners adjacent to 76th Street were studied and mitigation will be addressed on a case-by-case basis. Thus, a mandatory EAW is not required. • • Responses to each contention made by the petitioners are provided in Attachment A for the Council's information. The conclusion is that the contentions do not make the case for a mandatory EAW. • A petition requesting that an EAW be prepared for the Penn Avenue bridge project was also submitted. The EQB designated the Minnesota Department of Transportation (MnDOT) as the RGU for the bridge project and MnDOT was directed to respond to the petition. C. FINANCIAL • Creation of a second, separate. study of the impacts of the 76th Street road project would be a duplication of efforts, an inappropriate use of public funds and is not required by the EQB Rules. D. LEGAL • EQB Rules require an EAW for the following highway projects: 1) For construction of a road on a new. location over one mile in length that will function as a collector roadway; 76th Street does not qualify; 2) For construction of additional travel lanes on an existing road for a length of one or more miles; 76th Street does not qualify (the widening to the south is designed to accommodate turn lanes and a median); and 3) For the addition of one or more new interchanges to a • completed limited access highway; 76th Street does not qualify. The reconstruction of 76th Street does not fall into any of these categories: the project is approximately one-half mile in length and does not involve the addition of a new interchange. . A full analysis of the 76th Street project was prepared as part of the EIS, and the City Council determined that the EIS was adequate on December 11, 2000. • Consideration of the petition does not require a public hearing. Notice of the Special City Council meeting was published in the Sun-Current on May 16, 2001. Petitioners were also mailed notification of the meeting as a courtesy. • EQB Rules require the City to respond to an EAW petition within 30 working days after receiving the .petition from the. EQB. The ,City received the petition from the EQB on -April 11 and -must respond by May 23, 2001. IV. ALTERNATIVE RECOMMENDATION~S~ • Do not to adopt the resolution and direct staff to prepare a separate EAW for the 76th Street project. V. ATTACHMENTS • Attachment A: Resolution and point-by-point response to petition contentions. • Attachment B: Petition and supporting documentation from the petitioners. • Attachment C: Selections from the Best Buy EIS studying the impacts of the • reconstruction of 76th Street, between Penn Avenue and 35W. VI. PRINCIPAL PARTIES EXPECTED AT MEETING • The petitioners and their attorney were given mailed notice of the City Council meeting and may be present. • Karen Cole, attorney for Kennedy and Graven, Chartered. :7 RESOLUTION NO. • RESOLUTION DENYING A PETITION FOR AN ENVIRONMENTAL ASSESSMENT WORKSHEET RELATING TO THE RECONSTRUCTION OF 76TH STREET FROM PENN AVENUE SOUTH TO I-35W WHEREAS, 76th Street from just west of Penn Avenue to I-35W is proposed to be reconstructed; and WHEREAS, on or about April 3, 2001, Paul Walser and other individuals filed a petition with the Environmental Quality Board ("EQB") requesting the preparation of an Environmental Assessment Worksheet ("EAVV"); and WHEREAS, the petition asserts that the highway reconstruction project has the potential for significant environmental impacts and requires preparation of a "mandatory" EAW pursuant to Minnesota Rules § 4410.1D00; subd. land-Minnesota Rules § 4410.4300, subp. 22. WHEREAS, on April 11, 2001, the City received the petition from the EQB and was designated the Responsible Governmental Unit ("RGU") for responding to the petition; and WHEREAS, the Richfield City Council has reviewed and analyzed the issues raised by the petitioner, and has carefully examined the studies, records, and documents previously compiled by the City involving the area in which the proposed project will be located. The record for this determination specifically includes the draft and final scoping documents for the Best Buy Campus EIS, the draft and final Environmental Impact Statements for the Best Buy Campus, and the Adequacy Determination and Record of Decision for the Best Buy Campus EIS; the petition for an EAW with accompanying materials; the letter from the EQB staff transmitting the petition; and the Council Staff Report with attachments; and WHEREAS, the petitioners contend that the 76th Street reconstruction project requires a mandatory EAW under the Rules For Environmental Review ("EQB Rules"); and WHEREAS, the 76th Street reconstruction does not fall under a mandatory EAW category; the project is approximately one-half mile in length and does not involve the addition of an interchange; and WHEREAS, the City of Richfield included an analysis of the impacts of the road reconstruction project, including an analysis of alternative alignments, in the Environmental Impact Statement for the Best Buy Campus ("EIS"); and WHEREAS, the petitioners contend that the 76th Street reconstruction project has the potential for significant environmental effects; and WHEREAS, the impacts of the reconstruction of 76th Street were studied in the EIS, which shows that, with the improvements included as part of the Best Buy Campus Project ("Project"), all intersections would operate at acceptable levels of service and local streets would not experience traffic congestion due to Project traffic. In addition, no • violation of state or federal air quality standards for carbon monoxide would result from the Project. Also, the impacts on property owners adjacent to 76th Street were studied in the EIS and mitigation is being addressed on a case-by-case basis; and WHEREAS, the 76th Street reconstruction project does not have the potential for significant environmental effects; and WHEREAS, the environmental impacts of the proposed 76th Street reconstruction project were studied in the EIS for the Best. Buy Campus Project; and WHEREAS, the petitioners contend that the 76th Street reconstruction proposal is connected to the Project and is either connected to or a phase of the 1-494 reconstruction project, requiring environmental review under EQB rules; and WHEREAS, the 76th Street reconstruction is not a "connected action" or "phased action" under the EQB Rules. Rather, it is a part of the Project, has been identified as part of the Project by both the City and Best Buy and was studied as part of the EIS; and WHEREAS, on December 11, 2000, the City Council found the EIS to be adequate. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Richfield, as follows: 1. The City Council adopts as its Findings of Fact the WHEREAS clauses set forth above and Attachment B to Council Staff Report No. , 2. The City Council determines that the reconstruction of 76th Street from west of Penn Avenue South to east of I-35W does not. have potential for significant environmental effects; 3. The City Council determines in any event that the environmental effects of reconstruction of 76th Street from west of Penn Avenue South to east of -35W have been adequately studied, together with alternatives and mitigation measures, and 4. The petition for a mandatory EAW or a discretionary EAW is hereby DENIED. Adopted by the City Council of the City of Richfield, Minnesota this 21st day of May, 2001. Martin J. Kirsch, Mayor ATTEST: • Nancy Gibbs, City Clerk Q N •~ E L U Q w c c~ O C O (~6 L ++ Q ^~ L I..L ~_ L 0 0 C O O :~. U C ~ ~ '" O O U c ~ O ~ ~ c ~ o 0 U N c 0 Q N N .,_. N ~ N~ O~ N~ 0 0 E m ~ N ~ y-' ,~ O O N _U N ~ - ~:~ ~~ ~ C +~ O U N~ .~' ~ V ~ ~ L ~~ N N u1 N ~ ~ O ~ ~ N ~ ~+ O Q • ~ • ~ ,~ ~ to O cn N O ~ ~ L ~ O ((f >+ O "--' N O }+ U CO ~~ L + Q + L L Q U~~a"ico3 ~ ~~n.~•~~ o ~~ U U ~ L C +~ O ~ O ~ N ~ ~ ~ C •a o~ _ ~ ~ O ~ ca ~ X.. N -_ N L O . - H N N E N U V H V '~ j~ -~ "-' U N O U~ aoi~'`''o~ocLa~c~'o ~ •~°3cao' O~ W c a y ~ a-+ N "~ N C C ~ p ~ ~ U ~ L ~ ~ ~ ~ ( ~ ~. 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Attachment B • Petition and supporting documentation from the petitioners r ~ U L' MINNESOTA PLANNING ENVIRONMENTAL QUALITY BOARD ~s • -al April 6, 2001 Julie Urban, Planner City of Richfield 6700 Portland Avenue South Richfield, Minnesota 55423-2599 RE: Citizens petition for an EAW for the proposed improvement of West 76'j' Street Dear Ms Urban: The Environmental Quality Board (EQB) has received a petition requesting that an EAW be prepared on the project described in the petition, and determined Richfield is potentially the appropriate governmental unit to decide the need for an EAW. The requirements for environmental review, including the preparation of an EAW, can be found in the Minnesota Rules, chapter 4410. The procedures to be followed in making the EAW decision are set forth in part 4410.1100. Key points in the procedures include: L No final government approvals may be given to the project named in the petition, nor. may construction on the project be started until the need for an EAW has been determined. Project construction includes any activities which directly affect the environment, including .preparation of land. If the decision is to prepare an EAW, approval must be withheld until either a Negative Declaration is issued or an Environmental Impact Statement (EIS) is completed (see part 4410.3100; subpart 1, page 35.) 2. A first step in making the decision regarding the need for an EAW-would be to 658 Cedar St. compare the project to the mandatory EAW, EIS and Exemption categories listed in parts st. Paul, MN 55155. 4410.4300, 4410.4400, and 4410.4600, respectively. If the project should fall under any Telephone: of these categories, environmental review is automatically required or prohibited. If this 651-296-3985 should be the case, proceed accordingly. Facsimile: 651-296-3698 3. If preparation of an EAW is neither mandatory nor exempted, the City has the TTY: • option to prepare an EAW. The standard to be used to decide if an-EAW should be done 800-627-3529 is given in part 4410.1100, subp. 6. Note that this requires that a record of decision www.mnp~an. state.mn.us 100% post-consumer recycled content . including specific findings of fact be maintained. 4. You are allowed up to 30 working days (Saturdays, Sundays and holidays do not count) for your decision if it will be made by a council, board, or other body which meets only periodically, or 15 working days if it will be made by a single individual. You may request an extra 15 days from EQB if the decision will be made by an individual. 5. You must notify, in writing, the proposer, the petitioners' representative and the EQB of your decision within five working days. I would appreciate your sending a copy of your record of.decision on the petition.-along with-notification.of your..decson for our records. This is not required,.however. 6. If for any reason you are unable to act on the petitions at this time (e.g., no application has yet been filed or the application has. been withdrawn),. the petitions will remain in effect for a period of one year, and must be acted upon prior to any final decision concerning the project identified in the petition. Notice of the .petition and its assignment to your unit of government will be published in the EQB Monitor on April 16, 2001. If you have any questions or need any assistance, please. do not hesitate to .call. ,The phone number is 651-296-3865. ~ 1 U Sincerely, ~=~~~ Jon Larsen, Principal Planner Environmental Review Program cc: Christopher McGlincey, petitioners' representative • LEONARD, STREET AND DEINARD PROFESSIONAL ASSOCIATION ~~~ J \_I Apri13, 2001 VIA MESSENGER Christopher M. McGlii:cey 612-335-1490 chris.mcglincey@leonard.com Jon Larsen, Principal Planner Environmental Quality Board 300 Centennial Building 658 Cedar Street St. Paul, MN 55155 Re: EAW Petition. on Proposed Pe~:n Avenue/I-494 Interchange EAW Petition on Proposed 76th Street Reconstruction in Richfield Dear Mr. Larsen: Per your letter of March 28, 2001 to Carolyn Wolski of our office, we are resubmitting for • processing the two above-referenced petitions which now indicate the complete mailing addresses. Very truly yours, LEONARD, S ET AND DEINARD B ~ Y 'stopher M. cGlincey CMMaeo Enclosures cc: Carolyn V. Wolski, Esq.. (w/o encls.) Byron E. Starns, Esq. (w/o encls.) 150 $OVTH FIFTH $TAEET $VITE 2j00 MINNEAPOLIS, MINNESOTA 55¢02 TEL GI2-jjs-1500 FAx 612-335-1657 2066398x1 LAW OFFICES IN MINNEAPOLIS, SAINT PAUL AND MANKATO • A PETITION To the Minnesota Environmental Quality Board (EQB) for preparation of an EAW on the proposal by the-City of Richfield for reconstruction of 76th Street from west of Penn Avenue South to east of I-35W in Richfield, Hennepin County We the undersigned believe that the reconstruction proposed byRichfield for a segment of 7601 Street (a/k/a Municipal State Aid Highway # 361) from west of Penn Avenue South to east of I- 35W in Richfield, Hennepin County, may have the potential for significant environmental effects on traffic flow, air quality, quietude and land use in the area surrounding that. segment of highway. In accordance with Minnesota Rules, Section 4410.1100, we hereby petition the EQB to require Richfield to prepare an EAW for this proposed project. Richfield should conduct an EAW on the proposed 760i .Street reconstruction for the following reasons: 1. The highway reconstruction project has the potential for significant environmental effects. (a) Reconstruction requires demolition of ezisting street improvements and will necessitate shutdowns of traffic lanes. • • These shutdowns will occur simultaneously with. planned reconstruction and extended shutdown of nearby segments of Trunk Highway 62 ("the .Crosstown"). Traffic levels on segments of local streets and freeways are akeady expected to be significantly elevated due to the Crosstown shutdown. This congestion will be worsened by traffic detoured or otherwise forced to avoid this segment of 760i Street and will result in more significant auto emissions. (b) Reconstruction will create added capacity to this segment of highway, increasing traffic volumes and aggravating related environmental impacts. • Increased traffic volumes on other local streets and neighboring freeway segments will result in traffic congestion in those nearby areas. • Increases in traffic volumes will cause significant elevations in auto emissions, which have the potential to cause adverse effects on human health and the environment. • The potential inadequacy of the reconstructed highway segment to handle the increased traffic flow could result in adverse effects on vehicular traffic operating on I-35W and even I-494 due to the close proximity ofthe interchange of these two freeways and related vehicle. stacking and weaving problems. These potential effects on adjacent freeway traffic pose a significant threat to public safety. _ • The. proposed reconstruction of this segment of 760' Street will cause added • congestion at the intersection of 76`" Street and Penn Avenue and at other area zo6o9n~i intersections (such as 76th Street and York Avenue) that are akeady experiencing poor levels of service. These congestion problems will occur notwithstanding proposed improvements to traffic controls at the Penn Avenue intersection, as the increased traffic volume will overcome increased capacity at the intersection. Added congestion will cause increased auto air emission impacts with the.potential to adversely effect human health and the environment. • Reconstruction will require partial or complete private property takings and related land use impacts in adjacent residential azeas. • The planned reconstruction to this segment of 76th Street will lead to changes in the traffic circulation patterns in adjacent residential azeas, requiring additional roadway construction, such as loop roads and related property takings, thereby impacting the health, safety and quality of life in adjoining neighborhoods. (c) The 76th Street reconstruction proposal is connected to the. Best. Buy-Campus- project and is either connected to or a phase of the I-494 reconstruction project, requiring environmental review under EQB rules. • The 76th Street reconstruction proposal is connected to the Best Buy Campus project and is therefore a "connected action" as the term is defined in EQB rules because it is being directly induced by the Best Buy Campus project. Stated another way, the reconstruction of the interchange. is a prerequisite for the Best Buy project. Neither project would be justified by itself Environmental review is required to determine the cumulative effects which have not been identified in any other environmental review process. • The 76th Street reconstruction project is either a phase of a phased project involving the reconstruction of the Penn Avenue and I-494 interchange, or it is connected to that project, necessitating a review to determine cumulative effects of the projects that have not been identified in any other environmental review process. 2. The 76th Street reconstruction project requires a mandatory EAW under EQB rules. See Minn. Rules § 4410.1000, subp. 2; Minn. Rules § 4410.4300, subp. 22. However, even if a mandatory EAW is not required, the project clearly requires an EAW under the rules, as EQB guidance states that "[a] discretionary EAW is particularly appropriate for public projects with some possibility of significant adverse environmental impacts or with the perception of such." The 76th Street reconstruction project is a public project that certainly has either some possibility of causing significant environmental impacts or is perceived as possibly leading to significant adverse environmental impacts. Further evidence of the need for an EAW is described in the Informational Attachment to this Petition-and the Affidavit of James A. Benshoof, a registered professional engineer in the State of Minnesota. 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Description of Proposed Project: This is a petition to require environmental review by the City of Richfield (Richfield) on its plan to reconstruct a segment of 76~' Street in Richfield from west of Penn Avenue to east of I-35W. Richfield seeks to widen.. and otherwise reconstruct this segment of 76~' Street, changing the configuration of most or all existing intersections and traffic controls associated with this segment. Richfield would also reconfigure nearby local streets that intersect with this segment of 76~' Street, causing partial or complete takings of a .significant number of private properties.. The proposed reconstruction of 76~' Street will result in a significant expansion of traffic volume along this segment, which will create. added noise and will lead to increased automobile emissions in the adjoining residential area to the north. The proposed Best Buy Campus project was the subject of an environmental review by Richfield. Although reconstruction of 76`~ Street is required to facilitate the proposed Best Buy project, the EIS for that project did not address the specific impacts arising from 76`~ Street reconstruction. The 76t'' Street reconstruction project is connected to the proposedBest.Buy Campus project because the proposed Best Buy project has directly induced the street reconstruction. Further, 76t'' Street reconstruction. is a prerequisite to the Best Buy project and neither project is justified by itself. Project-specific environmental review should be undertaken -prior to reconstruction activities to ensure that any potential environmental impacts are identified and mitigated, and to ensure proper consideration of alternatives. If environmental .review is not carried out, the opportunity to mitigate .potential environmental impacts will be jeopardized, if not eliminated. This request is consistent with the legislative intent to require review at as early a stage as practical to ensure .its effective use in the decision-making- process. Minn. Stat. § 116D.04, Subd. 2a. 2061600v1 B. Proposer of Project: City of Richfield. C. Name, Address, and Telephone Number of Petitioners' Representative: Byron E. Starns, Esq. Carolyn V. Wolski, Esq. Christopher M. McGlincey, Esq. Leonard, Street and Deinard Suite 2300 150 S. Fifth Street Minneapolis, MN 55402 Telephone: (612) 335-1500 Facsimile: (612) 335-1657 D. Description of Potential Environmental Effects: The proposed 76th Street reconstruction will require demolition of existing road improvements, resulting in detours of traffic to local streets and freeways at a time when the shutdown of Trunk Highway 62 (Crosstown) is expected to cause substantial interference with local traffic operations. Demolition will also have impacts on traffic flow in the area, adding to congestion and air emission impacts. In addition, demolition will result in noise that will impact neighbors of the site. Once reconstructed, 76th Street will carry much more vehicular traffic than it can now accommodate. Traffic volume will increase, not only on this segment 'of 76th Street itself, but also along adjoining local streets and nearby freeway segments. Resulting increases in traffic volume on this segment of 76th Street will greatly enhance the potential for adverse health effects relating to concentrations of automobile emissions in .the environment. The permanent increase in the volume of traffic will also subject area residents to increased levels of noise. E. Evidence Re ag riling Potential for Significant Environmental Effects: The potential for significant environmental effects arising out of the proposed reconstruction of 76th Street is summarized in the attached Affidavit of James A. Benshoof. 2061600x1 2 The proposed reconstruction is located along a segment of 76th Street that is • presently experiencing high levels of traffic. The reconstruction will add capacity to this segment of 76th Street, but will also cause more traffic to utilize this segment. Long-range effects of the reconstruction are enhanced traffic volumes not- only on this segment of 76th Street, but also on other local streets, increased noise, and potentially significant adverse health effects-from air emissions. Several intersections along 76th Street east and west of the specified segment are presently -operating near or at capacity (for example, the ~-intersection of 76th Street and York Avenue South in Edina). The increased traffic drawn to -the specified segment of 76th Street is likely to contribute to increased volumes on adjacent segments of the same roadway, thereby significantly contributing: to- increased congestion. at those intersections. Reconstruction of 76th Street will also create major impacts on traffic at the intersection with Penn Avenue. This intersection. already experiences periods in which the level of service is at F {worst level). Higher traffic on this segment of 76th Street, caused by construction of the ~roposed .Best Buy ..project, .increased through-traffic after reconstruction of 76 Street .itself, and increased traffic volumes cause by reconstruction of the Penn / I-494 interchange and the 76th Street / I-35W interchange, will all contribute to congestion at the 76th and Penn Avenue intersection. Increased traffic at the intersection will require taking additional right-of--way, leading to adverse impacts on adjacent residential uses. This petition for an EAW is supported by the fact that state: regulations require a mandatory EAW in circumstances such as those raised by this proposal. Minn. Rules § § 4410.4300, .Subpart 22, requires a mandatory EAW "for the addition of one or more new interchanges to a completed .limited access. highway...." The proposed reconstruction of 76th Street (together with planned reconfiguration of the I-35W and I-494 interchange) will lead to reconstruction of the interchange of 76th Street with I-35W. These changes will result in significant changes in volume of traffic and will require the partial or total taking of several. private properties-all of which is tantamount to the addition of a new interchange. Even if the mandatory threshold is not met, the requirements for discretionary review are nonetheless demonstrated on the evidence presented. Additionally,. given the .connectedness of this- project with the proposed Best Buy Campus project-and the Penn Avenue and I-494 interchange reconstruction, environmental review is .necessary to evaluate cumulative impacts that have not been evaluated in • any other environmental review process. Zobiboo~i 3 • AFFIDAVIT;OF JAMES A. BENSHOOF STATE OF MINNESOTA ) ss. COUNTY OF HENNEPIN ) James A. Benshoof; being sworn on oath, states as follows: 1. I am a registered professional engineer in the-State. of Minnesota, -and president of Benshoof & Associates, Inc., a professional firm that provides services in transportation engineering and planning. I hold two master's degrees-in transportation engineering and traffic engineering, and I have substantial experience in traffic engineering analyses and traffic operations design projects. 2. This .affidavit concerns two petitions :for prepazation of an environmental • assessment worksheet (EAV~, one on the proposed construction of a Penn Avenue / I-494 interchange, and one on the proposed reconstruction of 76a` Street from west of Penn Avenue to I-35W. I have been asked to comment and render my professional judgment in connection with the potential for adverse environmental effects from these proposed projects. PENN AVENUE INTERCHANGE 3. I have personally reviewed the draft environmental impact statement ("DEIS") and the final environmental impact statement ("FEIS") issued by the. City of Richfield on -the proposed Best Buy Project (the Best Buy DEIS and FEIS aze collectively referred to herein as the "Best Buy EIS"). I have also reviewed the "Draft" FEIS dated October 30, 2000 issued by the Minnesota Department of Transportation (MnDOT) on the proposed reconstruction of an 18- mile section of I-494 ("I-494 EIS") that includes segments immediately adjacent to the proposed • Best Buy Project. The I-494 EIS addresses various issues relating to planned changes to the I- 494 / I 35W interchange that will impact the design and future layout of the I-35W / 76a' Street interchange. I have also reviewed many other materials related to the I-494 reconstruction, and I have spoken with several MnDOT officials and personnel concerning these projects. 4. The I-494 EIS and Best Buy EIS differ significantly in stated I-494 traffic volumes, even though these documents were issued on the-same day. The:.I-494 EIS states that the "current" (MnDOT Loop Detector Report, October 1999) average daily traffic on the France Avenue to Penn Avenue segment is 187,000, making this segment of I-494 the busiest reported in the I-494 EIS. See I-494 EIS, § 2.3.1 and Table 2.1. This existing-traffic figure is significantly greater than that presented in the Best Buy EIS, which reports that the 2003 no- build volume on the Xerxes to Penn Avenue segment will be 177,950 vehicles per day. See, e.g., Best Buy FEIS, Table 5.11. Even the lower 2003 no-build volumes estimated in the Best Buy EIS show that the I-494 traffic volumes are at their capacity limits. See Best Buy FEIS, Tables 5.1 S and 5.16. Therefore, the increased traffic volume presented in the I-494 EIS is likely to have significant consequences on the mainline system's ability to handle increased volumes introduced by the Best Buy project at the new Penn Avenue interchange. 5. The 2003 traffic projections in the Best Buy EIS do not account for predicted increases in traffic volume caused by MnDOT's proposed four-year closure of Trunk Highway 62 (Crosstown) from Penn Avenue to .Portland Avenue. MnDOT's Crosstown reconstruction plans call for traffic to be detoured from the Crosstown to I-494. It is also evident that the Best Buy EIS did not consider the substantial traffic volume increases on I-494 (including segments on either side of I-35W) that will result. from the proposed Ma11 of America Expansion and 2 • planned developments in the Airport-South District (generally located between 24~ Avenue and 34~` Avenue and south of I-494) in Bloomington. 6. The I-494 EIS reports serious existing traffic operational problems on a segment of I-494 that includes Penn Avenue. A major factor contributing to these problems is that interchanges on I-494 are spaced too closely together. Specifically, MnDOT recognizes that the half-mile separation distances :between Penn Avenue and I-35W -and -between-=I-35W and Lyndale Avenue, for example, are significantly less than the Federal Highway Administration recommended minimum separation distance of one mile. See I-494 EIS, § 2.4 and Table 2.2. As MnDOT puts it: "These closely spaced interchanges create inadequate distances between on- ramps and .off-ramps. Insufficient ramp spacing causes increased conflicts between traffic entering the freeway from one interchange and traffic exiting the freeway at the next interchange. • These vehicle conflicts reduce the capacity of adjacent lanes and increase the potential for accidents." Id § 2.4. The vehicle conflicts described by MnDOT in the preceding quotation are referred to by traffic engineers as "weaving." The length of roadway available to accomplish such weaving is known as the "weaving distance." 7. The Penn Avenue interchange construction plans call for total replacement of existing interchange facilities. The ramps will be considerably lengthened and widened and will be reoriented. Anew bridge structure will accommodate asingle-point diamond interchange with dual left-turn movements on and off the- ramps. The proposed Penn Avenue interchange will greatly expand the traffic capacity over that of the existing facilities. The configuration of the newly constructed ramps will cause the weaving distances for both directions of traffic flow • 3 on I-494 between Penn Avenue and I-35W to be .shortened by 18 percent {from existing 1280 feet to 1050 feet). 8. The reviewed documents demonstrate that the Penn Avenue interchange is scheduled to be constructed in 2002. MnDOT's reconstruction program for I-494 calls for the I-3 5 W interchange to constructed in 2010 or some time afterward. Therefore, during the interim eight-year period (or longer), the proposed Penn Avenue interchange would result in much greater volumes of traffic entering and exiting I-494 within a significantly shortened weaving distance. In my professional judgment, this proposed arrangement will .greatly aggravate the already serious problems caused by existing weaving. movements in the Penn Avenue to I-35W segment of I-494, as identified by MnDOT in the I-494 EIS. This arrangement .poses a significantly increased risk of accidents. In addition, increasing the volume of weaving traffic in a sigtificantly shortened space reduces the capacity of adjacent lanes of mainline traffic. The mainline capacity reduction will be more pronounced considering that the existing volumes on I- 494 referenced in the I-494 EIS are greater than the 2003 no-build volumes reported in the Best Buy FEIS. See, e.g., I-494 EIS, § 2.3.1 and Table 2.2. The probable end result will be a significant increase in congestion and accidents on I-494 between Penn Avenue a»d I-35W. Reduced through traffic capacity will have a ripple effect on the system, heightening congestion on neighboring I-494 freeway segments. Further, because I-35W interchange weaving is involved, it is highly likely that operations also will be adversely affected on the ramp from southbound I-35W to westbound I-494 and on the ramp from eastbound I-494 to southbound I- 35W. Increased traffic congestion that will be caused by this arrangement will contribute to higher auto exhaust emissions, posing potentially adverse human health effects due to increased 4 • carbon monoxide concentrations. Finally,. all of the foregoing impacts will.. be aggravated by increased volumes over and above simple extrapolated volume increases predicted in the Best Buy EIS, because that document did not consider the Crosstown closure, Mall of America expansion or Airport South development. 9. The I-494 EIS indicates that the proposed Penn Avenue interchange is a project led by the City of Richfield and that a categorical exclusion -determination is being sought (but has not yet been obtained) to preclude further environmental review of the interchange construction. Such an exemption is .not warranted for a number of reasons. First, the interchange should properlybe viewed as an integral part of the I-494 reconstruction. Impacts from construction of the Penn Avenue interchange must be considered comprehensively with other proposed improvements to and reconstruction of the freeway system. Second, while the • Penn Avenue interchange design appears to be appropriate to achieve long-term integration with the proposed redesign of the I-494 / I-35W interchange (including the. ultimate construction of a collector-distributor road), significant negative impacts to I-494 traffic operations are highly likely if the proposed Penn Avenue interchange is constructed eight years or more before construction of the new I-494 / I-35W interchange. Finally, to the extent that MnDOT is deferring to Richfield for the identification of environmental impacts from construction of the Penn Avenue interchange, such deferral is unwarranted because the Best Buy EIS has not addressed. the particular impacts posed by constructing the Penn Avenue interchange at least eight years prior to construction of the I-35W interchange. 10. The I-494 EIS does not address the impacts of constructing the Penn Avenue interchange at least eight years prior to the I-35W interchange. See, e.g., I-494 EIS § 1.8 (no • 5 mention of the 2002 Penn Avenue interchange construction in the project .phasing statement). Nothing in the Best Buy EIS resolves this. issue. Rather, the Best Buy EIS underreports current traffic volumes, ignores impacts from traffic detoured onto I-494 because of the Crosstown closure, and ignores the effects of at least two significant developments -Mall of America expansion and Airport South developments. Further, the Best Buy EIS does not present solutions to the weaving distance problems and other particular operational and safety concerns articulated in the I-494 EIS. Thus, the Best Buy EIS is inadequate for the purpose of analyzing or mitigating the environmental impacts associated with constructing the Penn Avenue interchange years before completion of the I-35W interchange. 11. Based on the foregoing, it is my professional opinion that the facts presented demonstrate that construction of the proposed Penn Avenue interchange has the potential to cause significant environmental effects. Since these potential effects have not been fully evaluated in any other environmental study, an EAW should be prepared. In the alternative, appropriate environmental review could be carved out by MnDOT through the I-494 EIS. 76TH STREET RECONSTRUCTION 12. The City of Richfield proposes to reconstruct a segment of 76th Street from west of Penn Avenue to the I-35W interchange. The proposed roadway reconstruction will involve reorientation of the street, increasing the right-of--way, widening the street and adding a variety of changes, including new traffic controls, at intersections. The project will increase the traffic volume capacity of the street, and Richfield predicts a marked increase in traffic volumes following construction. Much of the added traffic volume is expected to be generated by the 6 • proposed Best Buy development (proposed to be located just south of 76th Street, between Penn Avenue and Knox Avenue). 13. Richfield would also reconfigure .nearby local streets that intersect with this segment of 76th Street, causing partial or complete. takings of a significant number of private ~` properties. Increased traffic on this segment of roadway is likely to have adverse impacts on adjacent residential azeas, most particulazly the azea just north of 76th Street, which will experience increased noise generated by traffic on 76th Street, as well as impacts from increased traffic that will be diverted onto streets. within the neighborhood. These potential impacts to the neighborhood have not been adequately addressed in any environmental review document and should be evaluated through prepazation of an EAW. 14. Reconstruction of 76th Street also interfaces with proposed reconstruction ofahe • 76th Street / I 35W interchange. Reconstruction of the 76th Street interchange will result in the partial and total taking of a substantial number of private properties in the northeast quadrant of the interchange. Increased traffic volumes on the ramp from 76a` Street to northbound I-35W due to the Best Buy project .will potentially cause significant noise and vehicular emission impacts to the remaining properties in this impacted neighborhood. 15. Reconstruction of 76th Street will also create major impacts on traffic at the intersection with Penn Avenue. .Future traffic volumes at this intersection will be greater than reported in the Best Buy EIS due to trips that will divert from the Penn Avenue/I-494 interchange and the 76a` Street/I-35W interchange. The Best Buy EIS did not adequately account for meters on the entrance ramps at these interchanges. Accounting for these ramp .meters, the entrance ramps. will not be able to accommodate the volumes forecasted in the Best Buy EIS. 7 ,~ The result is that more motorists will use local roadways, such as Penn Avenue, 76m Street and nearby residential streets. 16. Based on the foregoing, it is my professional opinion that the facts demonstrate that the proposed reconstruction of 76a` Street has the potential to cause significant environmental effects. Since the potential for these effects has not been fully evaluated in an environmental study, an EAW should be prepared. Further affiant sayeth not. ames A. Benshoof Subscribed and sworn to before me this 2~ day of March, 2001. Notary Public M • EDWARD F. TERHAAR NOTARY PUBLIC' MINNESOTA MY ~~• F-moires Jan. 31.2005 ~~ o g • Attachment C Selections from the Best Buy EIS studying the impacts of the reconstruction of 76th Street between • • • 3.3 .ALTERNATIVE 2 WITH OPTIONS A AND B Under Alternative 2, four buildings would be located in the southwest half of the Project Site, with several ponds located along the southerly and southwesterly side of the. Site. The four office buildings are labeled A through D in Figure 32. An ~ ~Weenathe fou~buildings and the (ranging in height from 15 to 30 feet) would be constructed parking ramp to house uses such as a convenience store, a cafeteria, a day care facility, and a fitness center. Parking would be provided primarily in one parking' structure on ~ all surface to hwouldtalso be (P1). This structure would have-from five to seven levels. A-sm included along the southern portion of the Site along the internal .drive as well as between buildings B and C and adjacent to buildings A and D. Access to the Site would be from Penn Avenue, 76`~ Street at Knox ~Avenentran e76 Best Bu t Newton Avenue. Traffic signals would be added to Penn Avenue at the Y and to the intersections of Knox and Newton Avenues at the entrance to BestBuy on 76`~ Street. Option A: The expected development size would be 1.5 million sq. ft. divided into 6 stories in buildings B and D, and 8 stories in buildings A and C. The commons area would comprise approximately 65,000 sq. ft. of the development. The parking spaces provided would tota17,500, requiring one S level parking structure. The. first level of the parking structure would be below grade. Option B: The maximum development size would be 1• s Aland C.. The commons area would buildings B and D, and 10 stones. m bwlchng comprise approximately 65,000 sq. ft. of the development. The parking spaces provided would tota19,500, requiring one 71eve1 parking structure. The first level of the parking structure would be below grade. 3.4 76~ STREET ALTERNATIVES -The 76`h Street alignment between Penn Avenue and I-35W is currently afour-lane undivided road that serves as an east-west minor arterial in -the City of Richfield. 76`~ Street and a portion of Penn Avenue would need to be widened to accommodate the current traffic levels and the increased traffic. The City has identified three different road improvement alternatives for 76`s Street; one alternative that widens the roadway to the north, one that widens the roadway to the -r south, and one widens the roadway. with some combination to the north and south of the existing right of way. These alignment alternatives are illustrated for each. of the development ;„ alternatives in Figures 3-3 through 3-14. 1 The portion of 76`'' Street to be widened would have the following features: • Anew four-lane section with left-turn lanes and raised medians; • New traffic signals at Knox Avenue and Newton Avenue, with protected left turn lanes that would provide access to the Site; August 21, 2000 Best Buy Campus Page 3-2 Draft Environmental Impact Statement • The intersection of Penn Avenue and 76th Street would have double left turn lanes, two through lanes, and a right turn lane in all four approaches to the intersection. Penn Avenue from 76`~ Street to the new entrance to the Project Site (approximate location of 77~' Street) would also be included as part of the 76th Street reconstruction project. Penn Avenue currently is afour-lane divided roadway. The widened section of Penn Avenue north of 77~' Street would include: • Anew six-lane divided roadway with two through lanes in both directions, a south- bound left turn lane at the entrance to the Site, and a continuous right turn lane in the northbound direction. • The traffic signal at approximately 77`i' Street and Penn Avenue would provide access to the Best Buy Campus from Penn Avenue. Construction on 76~' Street and Penn Avenue would-occur in the 2001 construction season. 3.5 OTHER ALTERNATIVES CONSIDERED BUT DISMISSED 3.5.1 Alternative Sites: Best Buy Campus Site Selection Process ~Y° Approximately one year ago, Best Buy and Opus began an exhaustive analysis of Best Buy's real estate needs. Best Buy has experienced substantial growth as they have become the nation's largest consumer electronics retailer. As a result, Best Buy is located in nine separate facilities located throughout the southwest metropolitan area. After exhaustive review of their employee base and careful consideration of planned growth it was determined that Best Buy would seek a real estate solution that could accommodate at a minimum a consolidated corporate campus of approximately 1.5 million square feet. Best Buy committed to staying in the Twin Cities metropolitan area. After assessing .the metropolitan area, more defined geographic boundaries were established based on the location of Best Buy's current. employee base and other infrastructure needs. The boundaries were T-394 to the north and I-35W to the east. One location, the former Honeywell facility located south of downtown Minneapolis was an exception to the boundaries. In addition to new locations, expansion of their existing facilities in Eden Prairie was also considered. After careful review and consideration of many factors including accessibility, traffic congestion, functionality of existing buildings, proximity of existing buildings, cohesiveness associated with a master planned corporate campus, and financial considerations, the Eden Prairie corporate campus was ruled out as an expansion alternative for the new Best Buy Campus. The Project Site was selected for a variety of reasons that include ideal proximity to the majority of Best Buy's workforce, excellent, access to existing bus service and infrastructure and overall economics. Best Buy Campus August 31, 2000 Draft Environmental Impact Statement Page 3-3 6.0 76TH STREET RECONSTRUCTION 6.1 AFFECTED ENVIRONMENT The current geometry of 76~' Street between an area just west of Penn Avenue and the I-35W west ramps is a four-lane undivided roadway with no protected left or right turn lanes except at Penn Avenue. At the Penn Avenue intersection, right turn movements are shared with a through traffic lane, however, separate left turn lanes are present at all approaches. The segment of Penn Avenue from -just north of 76~' -Street--and=:between 7b~' :Street and 77cn Street has the same geometry as 76`~ Street at this intersection, fiaving 2 through lanes, with a shared right and a separate left in each direction. As described in the Traffic Impact Study, the intersection at Penn and 76~' and the geometry of 76`'' Street is currently insufficient to accommodate projected increases in background traffic volumes. As a result, this roadway is programmed for reconstruction by the City in 2011. As part of the Best Buy Campus redevelopment, this roadway improvement project would be completed in 2002. 6.2 ENVIRONMENTAL IMPACTS The Cit roposes to widen 76`~ Street from afour-lane section to a five-lane section with a 4- YP foot raised median. It is also proposed to reconstruct the intersection of 76`~ Street and Penn Avenue to include dual left-turn lanes and right turn lanes on all of the approaches. Traffic signals are proposed at the intersections of 76~' Street at Newton Avenue and at Knox Avenue. At the Newton Avenue intersection, special traffic signing and striping will be installed to prevent vehicles leaving the Best Buy Campus at Newton Avenue from going north through the intersection into the residential neighborhood. This reconstruction plan does not include noise barriers. The widening at the 76`h Street intersection with Penn Avenue, essentially widens in all directions, maintaining the center of the intersection. Three alignments for the 76`h Street widening have been developed for the remaining portion of 76~' Street to the I-35W west ramps. The first alignment widens 76`h Street entirely to the south holding the north right of way (ROW) constant, the second alignment widens 76`h Street to both the north and south and the third widens 76`'' Street to the north holding the south ROW constant. Operationally, there is virtually no difference between the alignments. There is a slight .reverse curve between Penn Avenue and Newton Avenue in both the eastbound and westbound directions under the south-widening alternative. ~ The center-widening alternative has no noticeable curves in the alignment. All three alignments are acceptable designs.. The biggest difference between the alignments is the amount and location of right of way needed. Best Buy Campus August 21, 2000 Draft Environmental /mpact Statement Page 6-1 • 6.2.1. Reconstruction Impacts Common to all Alignments In order to accommodate the dual left turn lanes and the right turn lanes, the 76`~ Street ~ Penn Avenue intersection will need to be widened in all directions. The impacts of the reconstruction of this intersection will be the same for each of the alignments. The following ROW would be required: • 14 feet on the north side of 76a' Street (east of Penn Avenue for approximately 300 feet); • 10-20 feet on the south side of 76~' Street (east =of Penn -Avenue for .;approximately 175 feet); • 5-10 feet on the north side of 76`t' Street (west of Penn Avenue for approximately 150 feet); • 10-25 feet on the south side of 76~' Street (west of Penn Avenue for approximately. 400 feet); • 26 feet on the east side of Penn Avenue (south of 76~' Street to I-494); • 10-25 feet on the east side of Penn Avenue (north of 76`~ Street for approximately 400 feet). • 5-10 feet on the west side of Penn Avenue (north of 76`t' Street for. approximately 175 feet) The following properties will be affected: • NE corner - 5 properties on east side of Penn Avenue and north of 76`~ Street. 3 properties may be affected enough to warrant full take, and 2 properties will probably require partial take; • SE corner -Best Buy (redeveloped land); • NW corner -Church of St. Richard -partial take (green space); and • SW corner -Century Court Apartments -partial take. 6.2.2 South Alignment Impacts The following Right of Way would be required: • The. proposed 76`~ Street south curb line will be 10-40 feet south of existing curb line except at the intersection with Penn Avenue; • The proposed north curb line will be the same as the existing curb line except at the intersection with Penn Avenue; • The proposed ROW will be approximately 15 feet further from the curb line for sidewalk, utilities, snow storage, etc; • .This alignment comes very close to the garages at Fountainhead Apartments. It is expected that the garages will need be affected; Best Buy Campus August 21, 2000 Draft Environmental Impact Statement Page 6-2 • The access drive to Fountainhead .Apartments, on Knox Avenue just south of 76`~ Sweet, must be modified;. • Access to Oliver Avenue, Morgan Avenue, and the apartment building north of 76`~ Sweet will be limited to right-turn only access; The following properties will be affected: • Best Buy (redeveloped land); and • Fountainhead Apartments -partial take, will need to rebuild garages. 6.2.3. Center Alignment Impacts This alignment would require new right of way on both sides of 76~' Street. The following right of way would be required: • The proposed 76"' Sweet .south curb line will be 10-26 feet .further south of the existing curb line except at the intersection with Penn Avenue; • The proposed 76`h Street .north curb line will be 14 feet further north of the existing curb. line except at the intersection with Penn Avenue; • The proposed ROW will be approximately 15 feet further from the curb line (for sidewalk, utilities, snow storage, etc.); • This alignment may impact the garages at Fountainhead Apartments. The impact is not as great as the south alignment alternative; • The access drive to Fountainhead Apartments, on Knox Avenue just south of 76~' Street, must be modified; and • Access to Oliver Avenue, Morgan Avenue, and the apartment building north of 76`~ Street will be limited to right turn only access. The following properties willbeaffected: • Best Buy.(redevelopedhnd); • Fountainhead Apartments -partial take, may need to rebuild garages; • Three houses on north side of 76`h Street between Newton and Morgan (partial take); and • Three houses on north side of 76`h Street between Morgan and Logan (full take). 6.2.4 North-Widening Impacts The north-widening alternative would require a large amount of the right of way to be acquired from the north side of 76`h Street. The following right of way would be required: • The proposed north curb. line will be 10-26 feet further north of the existing curb line except at the intersection with the Penn Avenue; Best Buy Campus August 21, 2000 Drafr Environmental Impact Statement Page 6-3 the same as the existin curb line except at the • The proposed south curb hne wtll be g intersection with the Penn Avenue; • The proposed ROW will be approximately 15 feet further from the curb line (for sidewalk, utilities, snow storage, etc.); • The access drive to Fountainhead Apartments, on Knox Avenue just south of 76t° Street, may need to be removed; and • Access to Oliver Avenue, Morgan Avenue, and the apartment building north of 76`h - Street will be limited to right turn only access. The following properties will be affected: • Best Buy (redeveloped land); • Six houses on north side of 76~' Street between Newton and Logan (full take); and • Colony Apartments -possibly 2 buildings. 6.3 MITIGATION MEASURES After the preferred 76`~ Street Alignment is determined, the City will coordinate with each affected property owner to determine specific location and size of impacts and mitigation options specific to those properties. Best Bury Campus August 21, 2000 Draft Environmental Impact Statement Page 6-4 6.0 76T" STREET RECONSTRUCTION 6.1 AFFECTED ENVIRONMENT There have been no additions, changes, or corrections to the information, analysis and conclusions in this section of the DEIS. 6.2 ENVIRONMENTAL IMPACTS ' Based on comments to the DEIS, he 76th Street-Alignments have been.modified in order to reduce further the impacts to properties near the intei-sectiori of Penn Avenue-and 76th Street. First, 76th Street has been shifted south which minimizes the partial taking of land on the north ~^" side of 76`h Street. Second, Penn Avenue has been shifted west which reduces the partial taking ,, of land on the east side of Penn Avenue. Third, the westbound right turn lane on Penn Avenue has been shortened by 150 feet to avoid the taking of a four-unit apartment building. With the reduction of the westbound right turn lane from 300 feet to 150 feet, a further queuing analysis showed that the queue lengths would not be expected to exceed the storage lengths for all scenarios. • 6.2.1 Reconstruction Impacts Common to All Alignments In order to reconstruct the intersection of 76th Street and Penn Avenue under any of the three Ali~mment alternatives, the existing curbline would be modified as follows: - • The proposed north curbline of 76th Street between Peart Avenue and. the first driveway to the east will be 14 feet farther north; _ • The proposed north curbline of 76th Street west of Penn Avenue will be 14 feet farther north at Penn Avenue and then taper to match the existing curbline approximately 650 • feet west of Penn Avenue; • The proposed south curbline of 76th Street west of Penn Avenue will be 14 feet farther south at Penn Avenue and then taper to match the existing curbline approximately 350 feet west of Penn Avenue;. and • The proposed west curbline of Penn Avenue north of 76th Street will be 20 feet farther ` west for approximately 200 feet and then will taper back to the existing curbline _ approximately 500 feet north of 76th Street. The following properties will be affected by the reconstruction of this intersection under all three Alignment alternatives: • NE corner -Right of way from one property in the northeast corner of the intersection.. will. be needed. There will be no buildings or access removed; • SE corner -Best Buy will dedicate right of way as part of plat; • N W corner -Church of St. Richard -Some right of way will be needed and the church sign may be impacted. The sign can be moved to a new location on property. There will be no buildings or access removed; and Bc•.+~r Bu.r Campus October 30, 2000 nru/t Enrirnnnrc•ntnl Impact Stutenunt Page 6-1 r • SW corner -.Century Court Apartments -Some right of way will be needed, however no ~, buildings or access will be removed. r The amount of right of way required does not necessitate a full take (acquisition of an entire i„ parcel) of any property. There will be no buildings or access removed in order to reconstruct the intersection of 76th Street and Penn Avenue. 6.2.2 South Alignment Impacts ere have been no additions, changes, or corrections to theinformation, •analysis and Th conclusions in this section of the DEIS, except the City is working with the fountainhead Apartments to determine if a garage will need to be relocated. ~` 6.2.3 Center Alignment Impacts There have been no additions, changes, or cot-rections to the information, analysis and conclusions in this section of the DEIS, except. the City is working with the Fountainhead Apartments to determine if a garage will. need to be relocated. 6.2.4 North Widening Impacts information anal sis and There have been no addtttons, changes, or corrections to the y .conclusions in this section of the DEIS. 6.3 MITIGATION 1\1EASURES Mitigation measures for all 76`h Street Reconstruction Alternatives will consist of one of the L options described in more detail in Sections 6.4 and 6.6. VENUE T" STREET AND KNOX A 6.4 76 Due to the proposed median on 76`h Street, the access to the north will be limited to right-in, right-out only at certain locations. In particular, the I-35W frontage road (Humboldt Avenue) and the driveway to the Colony Apartments will be restricted to right-in, right-out only. The City is not required to provide full access to 76`h Street at every cross street or driveway. Right turns into and out of Colony Apartments would be easier and safer for drivers than. making left turns into or out of the site. 76`h Street is classified as a minor arterial roadway and limiting the amount of access to an arterial roadway improves the traffic tlow. Ne~•rrtheless, several options to provide improved access to the frontage road and Colony i` Apartments are being considered, but a final solution has not been determined. The City is L still designing the 76`h Street alignment and considering options for this intersection. Listed below arc several of the options. (1) Do nothing. This option is the one currently proposed for the 76`h Street reconstruction. It assumes that there is a `T' intersection at 76`h Street and Knox L Brcr Bur Cu- rpus October 30, 2000 Page 6-2 ` nrult F,-rrirr» rnu•ntu! J»rpac7 Stutemenr - ,,~; 1 1 Avenue. The fro~tage road and the Colony Apartments would have right-in, right-out only access to 76 street. (2) Provide east/west access to Logan Avenue. This option would construct aneast/west connector between the Colony Apartments parking lot and Logan Avenue. This would provide full access to 76`h Street for the residents of the apartments, although the access would not be at a signalized intersection. This access, while possible, would increase traffic on asingle-family residential street. The access at the frontage road would remain right-turn only. (3) Curve 76-' street zu reec runner cu «,c wuu, wa~.ui~- av VJ..4 / V vaavv..,.,»... Alignment. This option would curve 76`h Street further to the south approximately 20-25 feet at Knox Avenue. A fourth leg to the intersection could be created, which would provide access to the north into the Colony Apartments parking lot. The access at the frontage road would remainright-turn only. This option would necessitate additional right of way south of 76~' Street both east and west of Knox Avenue and introduce an additional curve in the road. (4) Move 76`h Street 80 feet further to the south than the proposed 76'h Street South Alignment.. This option would curve 76`h Street further to the south approxtmately 80-85 feet at Knox Avenue. A fourth leg to the intersection could be created, which would provide access to the north into the Colony Apartments parking7ot and connect with the frontage road. This option would necessitate additional right of way south of 76`h Street both east and west of Knox Avenue and introduce a sizeable curve in the road. The relocated 76`h Street would require the removal of the garages at Fountainhead, would remo~~e the north access and would be located approximately 20 feet .from the Fountainhead Apartment buildings. (~) Remove apartment buildins;. This option would remove the apartment building in the Colony apartment complex that is north of 76`h Street opposite Knox Avenue. The removal. of this building would allow a north leg to be constructed opposite Knox - :'~~ enue at a 90-degree angle. The frontage road would also be tied into the Colony .Apartments parking lot in order to gain access at Knox Avenue signal. This would pmvide full access for the Colony Apartments complex and the frontage road. -, Holvever, the cost of the right of way would increase significantly in excess of the ,.._ City's budget for widening 76`h Street. (E,) Create skewed intersection. This option would curve Knox Avenue to the west and .- intersect 76`h Street at a skewed angle. A fourth leg of the intersection would be created that would access the Colony Apartments parking lot. A skewed intersection -~ would reduce the operational efficiency of the intersection and may create sight line problems. The access at the frontage road would remain right tum only. ~' (7) Create offset intersection. This option would create an .offset signalized intersection. -~ The location of the Colony Apartments driveway would stay where it is, but would become part of the signalized intersection at Knox Avenue. This signal would be ' operated in split phase mode, which means that the north and south approaches Rrsr liar ('urnlru.~ October' 30, 2000 I)rutt F.•nrir,urmr-uul Inrpuc•t Suttc/nu/nt Page 6-3 operate independently of each other. Split phase operation creates additional delay for an intersection, which decreases the operational efficiency. If the Colony Apartments driveway were included in the signalized intersection, the storage length for the westbound left turn lane would be reduced by approximately200 feet. The access at the frontage road would remain right-turn only. (8) Move intersection west 40 feet._ This option would curve Knox Avenue to the west, which would allow a fourth leg of the intersection to be constructed between two apartment buildings north of 76~' Street. This would require additional right of way both -north. and south of 76`h Street west of Knox Avenue. This option would also allow full access to the Fountainhead Apartments at the Knox=Avenue Intersection. The access at the frontage road would remain right-turn only The preferred option will be selected though meetings with affected property owners. The City will attempt a joint solution, acceptable to all affected property owners and the City, that will be recommended for approval by the City Council. 6.5 KNOX AVENUE • • The increase in traffic on Knox Avenue is not expected to have a significant impact on the surrounding land uses that access Knox Avenue. From the "Interchange West Traffic Study" performed by SEH, Inc. in July 1999 for the City, Knox Avenue has an Average Daily Traffic of approximately 2,200 vehicles per day. It is expected that approximately l 7% of the daily Best Buy Campus traffic will use Knox Avenue to access the Project (2,500 vehicles per day for the 7,500 employee development and 3,150 vehicles per day for the 9,500 employee development). With the addition of the Project traffic, the daily traffic volumes on Knox Avenue are expected to double. However with the addition of the traffic signal at 76`h Street and Knox Avenue, Knox A~•enue has adequate capacity to accommodate the increase in traffic due to the Project. Currently, parking is allowed on the east side of Knox Avenue. With the proposed Best Buy Campus, an access to the parking ramp would be constructed approximately 500 feet south of 76`h Street un Knox A~•enue. Parking would then be restricted on both sides of Knox Avenue bet~t•ecn the Best Buy parking ramp entrance/exit and the 76`h Street / Knox Avenue intersection. This ~ti•uuld eliminate approximately 400 feet (18 spaces) of on-street parking. Fur the Fountainhead Apartments, the traftic from the Best Buy Campus will generally flow counter to traftic from Fountainhead. In the AM peak period, traffic will be entering the Best Buy Campus, and traffic from the Fountainhead Apartments will be leaving the location. The re~•erse is expected during the PM peak period. Trattic exiting the Best Buy parking ramp onto Knox A~•enue will be required to stop for vehicles on Knox Avenue. Brat Rrn• Cumprr,. October 30,.2000 t>r-u(1 Enrrrnrunc•»!u! Impuc•! Stute»rc•»~ Page 6-4 -~ '~~ c~ r ~~ C~ G C C w w ,. a r ~~ J r, 1 1 b.b 7bTH STREET / I-35W SOUTgBOUND EXIT RAMP Additional detail about mitigation options to be considered for the 76a'-Street / I-35W intersection was requested by comm~ente~ and the I35W southbound ttramp. An expanded re studied for the intersection of 76 S description of these options follows: (1) The first option would be to remove the "No Turn On Red" sign from the southbound movement (Figure 6.1). By removing the "No Turn On Red" sign, the right turning vehicles would not have to-wait•:for,a green ball to proceed_through he intersection. The level ~of service of the southbound right turn -lane may improve slightly if right turns on red were allowed, however the queue length wouldn't be drastically reduced. If vehicles were allowed to turn right on red, the conflict between pedestrians and vehicles increases. Motorists wishing to tum right on red will be most concerned about the gap in traffic and may fail to see pedestrians crossing. The "No Turn On Red" sign was originally installed to provide a safer crossing across the north approach of the intersection for pedestrians and bicyclists (Figure 6.2). (2) The second option would be to install a channelizing island, which would allow free right turns. The purpose of the island would be to create afree-right turn condition. However, in order to have a true free-right condition, a merge area downstream of the intersection would need to be constructed. The merge area allows for vehicles turning right to safely merge into the mainline flow. In the case of this intersection, a merge section would need to be constructed west of the I-35W ramp on 76`h .Street. Approximately half of the vehicles turning right at the intersection intend to enter the Project Site and many of them would curn left at Knox Avenue. Therefore, many of the ~•ehic}es would need to merge and then weave over a very short distance. By allowing a free right movement, the pedestrian crossing of the right turn lane would he controlled by a yield sis,'n. Pedestrians crossing the southbound left turn lane would be guided by the traffic signal, but would have to wait for a gap in southbound. right turn traffic in order to cross the right turn lane. A pedestrian signal could be installed to facilitate crossing of the right tum lane (Figure 6.3). (3) The third option studied would be to construct a second southbound right turn lane and keep the "No Tum. On Red" restriction in place. A second right turn lane would help to improve the level of service for the southbound right turn movement and reduce the queue length. The traffic analysis showed vehicles would no longer be hacked up onto I-35W mainlines, thus eliminating this safety hazard. If two lanes ~~•ere constructed, the vehicles destined for the Project Site could use the center-most right turn lane, and all other vehicles could use the right-most right turn lane. Since right turns on red would be prohibited, vehicles would only proceed through the. intersection on a green light.. As a result, there would be no merging into 76`h Street ~~•estbound traffic, and the weave from the southbound I-35W ramp to Knox Avenue ~~•ould not affect the flow of traffic on 76`h Street (Figure 6.4). Also sec Section 12.4 regarding pedestrian safety and accidents. Rcu~! Bur Cunrpu.~ October 30, 2000 Drub Ern•irn»mrn-ul Impact Statement Page 6-S The preferred Option identified by the City of Richfield is Option 3. This design maintains safety for pedestrians/bicyclists. The dual right turn also eliminates weaving problems for vehicles exiting I-35W to enter into the Best Buy Campus via Knox Avenue or to go west on 76th Street. 6.7 76TH STREET /YORK AVENUE The City of Edina is planning to reconstruct of the 76a' Street /York Avenue intersection by adding left turn lanes and a left turn .phasing on the traffic signal on 76'h Street and by adding a second left turn lane on the north approach to the intersection. The reconstruction is planned to begin. in Spring 2001 and to be completed that year,-prior to fheclosure of the Penn Avenue bridge and the opening of the Best Buy Campus. • • Bc'.ct R1n~ Cuntpus October 30, 2000 nrcrlt b'nrrr~nrnte•nta! Intpac•t Statentc n! Page 6-6 • 17.0 RESPONSES TO COMMENTS This section provides responses for all written comments received from agencies, groups and two individuals (Mike Dillon and Larry Wozniczka). Section 17.2 contains comments made by individuals at the public meeting held on September 13~', 2000 and made in letters and faxes sent to the City. Many comments addressed similar issues and the comments are grouped by major issue. Responses are provided regarding their concerns in Section 17.2. Comment letters are included in Appendix E. 17.1 RESPONSES TO WRITTEN COMMENTS Written comments on the DEIS were received during the DEIS comment period from the following agencies or groups: • Minnesota Department of Natural Resources • Minnesota Department of Transportation - • Minnesota Pollution Control Agency • Metropolitan Council • I-494 Corridor Commission • City of Edina " City of Bloomington . ~ • Benshoof & Associates, Inc. on behalf of Walser Automotive Group, Inc. _ • Malkerson Gilliland Martin LLP on behalf of Walser Automotive Group, Inc. • Felhaber, Larson Fenlon & Vogt on behalf of Fountainhead Apartments - • ROP Investment Co., LLP on behalf of Colony Apartment Homes • Drew Backstrand, on behalf of WSL Partnership _ Written comments were also received from individuals, including: • Mike Dillon ' • Larry Wozniczka - • Robert and Marilyn Hanson • Peggy Handt • Cindy Larson "~ • Marian Miller ,. Joe and Pam Krzyzaniak • Gordon A. Anderson .. This section provides responses for all written comments received. from agencies, groups and two _ individuals. Since many of the individual's comments were similar,. many of their comments were summarized by major issue, and responses are provided regarding their concerns in Section ~- 17.2. Comment letters are included in Appendix E. _~ October 30, 2000 Best Buy Campus Page 17-1 Fina! Environmental Impact Statement A, Minnesota Department of Natural Resources • Comment AI: Concur with the characterization of relative habitat value across alternatives as offered in Section 12.2, Wildlife. Although both alternatives can improve habitat diversity, Alternative 2 makes this alternative the more desirable approach from a wildlife management perspective. Use of native species. wherever possible in landscaping can further serve to mitigate any minor habitat impacts found with either alternative. Response Al: Comment noted. Alternative 2 is in fact the expected alternative. See response to Comment O.1 regarding the use of native species in the landscape plans. The general Site landscape plan is shown in Figure 12.3 and is also: briefly described in Section 12.4 d. B. Minnesota Department of Transportation Comment Bl: Access off Penn Avenue is problematic for the following reasons: a. Proximity to a single point with .inadequate stacking. b. Properties to the west of Penn Avenue should .access Penn Avenue at the Best ' Buy entrance, which would provide a 4-legged intersection. . ~~ c. On-site stacking appears to be inadequate. d. A single point at Penn Avenue will. be stressed to its limits and will affect the operation oft-494 and 1-35W. e. The size of the development (i.e., land use) may be too large or intense for ~'''~• the supporting transportation network. Response Bl : Upon reading this comment, the City was unclear whether it applied to Option A (7,500 employees), Option B (9,500 employees) or both. Tom Foley, the City's engineer, wrote an iriquiry letter to MnDOT suggesting how the City intended to respond and asking for clarification. MnDOT responded that its concerns were directed primarily ~~ at Option B and given the suggested responses, it believes that the City has satisfactorily addressed each of these issues. See MnDOT letter in Appendix H. See Tom Foley's letter in Appendix H. The responses below are the suggested responses sent to MnDOT by Tom Foley. a. Proximity to a single point with inadequate stacking. The draft EIS showed no queuing lengths that exceeded the storage lengths provided on the single-point diamond interchange for Option A (7,500 employees) development. The City agrees that Option B (9,500 employees) leads to excessive queue lengths. at the Penn Avenue interchange. See DEIS Section 5.0). b. Properties to the west of Penn Avenue should access Penn Avenue at the Best Buy entrance, which would provide a 4-legged intersection. _ The City's long-range plans for the area include making the Best Buy entrance afour- legged intersection to improve access for properties west of Penn Avenue. However, at October 30, 2000 Best Buy .Campus page 17_2 Final Environmental Impact Statement this time the cost of acquiring the affected property, the Century Court Racquet Club, exceeds the City of Richfield's road budget. The reconstruction to afour-legged !' intersection is not in MnDOT's reconstruction plans for the final I-494 improvement project at this time either. c. On-site stacking appears to be inadequate. On-site stacking at the Best Buy entrance on Penn Avenue was analyzed in Appendix B Section 8.2.2 B. and 8.2.2 C. in the DEIS. It was determined that on-site storage lengths were adequate to accommodate Option A. The DEIS did show that stacking was a problem for the Best Buy entrance on Penn Avenue under Option B. d. A single point at Penn Avenue-will be stressed to its limits and will affect the operation of I-494 and I-35W. Based on a MnDOT study of other weaving areas,-and simulation of the existing and proposed conditions, the proposed Penn Avenue improvements are expected to improve operations on I-494 during peak hour conditions.. -See discussion in Section 12.3. e. The size of the development (i.e., land use) may be too large or intense for the supporting transportation network. • Traffic management depends on a robust network of arterial streets in addition to the regional highway network. The cities of Bloomington, .Edina and .Richfield • have developed and continue to expand a network of arterial streets .that parallel both I-494 and I-35W. These arterials serve as relievers to the freeways when traffic volumes exceed the freeway capacity. The reliever arterials for I-494 are 79th/80th Streets in Bloomington and 76thJ77th Streets in Edina and Richfield. The north /south reliever arterials are Portland, Nicollet, Lyndale, Penn, York. and France Avenues. Further improvements are planned to improve the arterial network including the Project Roadway Improvements to 76`h Street and the 79`h/80'h Street Bridge over I-35W. • As traffic disperses further and further from the Best Buy Site, its impact on the regional highway network is lessened. • The Site was selected in-part because it closely matched the centroid ofhome locations of current Best Buy employees. This means that Best Buy employees will travel shorter distances to the Site than if the Site were located .elsewhere. Employees already use the regional highway network to commute to and from work. • A number of roadway improvements are planned for both I-35W and I-494 in the coming years. The Penn Avenue Bridge will enable Best Buy traffic to disperse quickly. Furthermore, the Lyndale Avenue Bridge will improve traffic flow on Lyndale Avenue in the vicinity of I-494. Improvements are planned for I-35W • that will increase capacity and provide a High Occupancy Vehicle Lane from I- 494 to 46th Street in Minneapolis within the next five years. This same Best Buy Campus Oetober 30, 2000 Final Environmental Impact Statement Page I7-3 62 Crosstown improvement will increase both the capacity and safety. of the • Highway that serves as an alternate route for I-494 traffic. ' the o ortunity to promote transit. The Best Buy site plan has been developed with pp and carpooling and vanpooling to encourage employees to use alternative forms of transportation that will lessen the impact on the supporting transportation network. Yet the traffic analysis does not count on travel demand management to make the traffic volumes work under Option A. ^ Comment B2: Revised grading and drainage plans will need to include before/after hydraulic computations for 1 D and 100 year storm events. -For the existing conditions,-additional detail is needed for the selection of times of concentration and curve numbers. In addition, detail on the outlet control structures is needed for the proposed conditions. Since the development will treat the onsite runoff, the development should also treat additional runoff from the north-rather than bypass the Best Buy Campus. The hydraulic computations will have to show that the ponding can handle the additional runoff. Response B2: See Section 4.2. Comment B3: Utilities located on future I-494 right of way should be relocated as part of this development. Response B3: The City and Best Buy have agreed that Best Buy will provide capacity on-Site to replace the public water and sanitary sewer facilities currently located within the frontage road on future I-494 right of way. The Project will include the construction ~ of a public water main and public sanitary sewer trunk along the south part of the Site ` that will also provide services for the Project: The existing water and sanitary sewer facilities within the frontage road will be abandoned prior to completion of the Project. • The construction of the utilities will be coordinated with the construction of the I-494 ramp improvements to ensure that utility services are not disrupted. Existing storm sewer facilities within the future MnDOT right of way that conflict with the future expansion of I-494 to the north will be reconstructed and/or removed as part of the Best Buy Project. Comment B4: Penn Avenue is County State Aid Highway 32 and 76'h Street is Minnesota State ° Aid route 361. These routes need to meet State Aid rules and policies. _ . Response B4: The City recognizes that Penn Avenue is a County State Aid Highway ^ and 76`" Street is a Municipal State Aid Route. The designs for the Penn Avenue/I-494 interchange have been coordinated with MnDOT staff over the past several months. The 76`" Street corridor is in preliminary design phase. The plans for both road improvement projects will be coordinated with MnDOT's State Aid office and will be designed to meet , • State Aid policies. October 30, 2000 Best Buy Campus Page 17-4 Frnal Environmental Impact Statement comment will be provided on the FEIS, which will be published on October 30, 2000. The period for written comments will extend through November 13, 2000. ~• In addition, the City has participated in several coordination meetings with individual local businesses and residents to discuss their concerns regarding both projects.. T ...-~ As a result of the opportunities made available to the community, the City will not be extending the comment period on the DEIS. -- H. Benshoof & Associates, Inc. -~- .- ••- r .y .~ .~ ~. c Comment HI: Discrepancies between .traffic forecasts and existing volumes at intersections on 76`h and 77`h Streets. Response H1: Volume counts were collected at two locations by Benshoof & Associates, Inc. on September 6, 2000 during ttie P1VI peak period. These locations included all turning movements at the 76"' Street and I-35W northbound entrance ramp intersection and at the 77`h Street and Lyndale Avenue intersection. The counts .show that some of the turning movement volumes collected at these locations on this date were greater than the predicted volumes in Year 2003 included in the DEIS and that some of the turning movement volumes were lower that the predicted average volumes in the DEIS. It is expected that on any given day. traffic volumes will be different (higher or lower) from a predicted average. However, an analysis was performed for the two locations using the volumes counted in September of 2000 by Benshoof to determine the impacts based on these counts of background traffic volumes. The. analysis showed. the. following: Table 17.1: i.eve) of Service at Two Selected Intersections, Year 2003. Intersection Level of Service (LOS) Projected in Best Buy DEIS Based on Volume counts in September Intersection 2000 7,500 9,500 7,500 Employees 9,500 Employees Em lovees Em lovees 76` Street / I-35W NB B g C C Entrance Ramp 77` Street / Lyndale D D C C Avenue Table 17.2: Level of Service at Two Selected Intersections, Year 2022 Intersection Level of Service (LOS) Projected in Best Buy DEIS Based on Volume counts in September Intersection 2000 7,500 9,500 7,500 Employees 9,500 Employees 76"' Street / I-35W NB A B 13 B Entrance Ramp 77` Street / Lyndale C C C C Avenue Best Buv Campus October 30, 2000 Fina! Environmental Impact Statement Page 17-17 For the Year 2003, the 76~' Street / 1-35W North Ramp intersection operation is expected - r to decrease from a LOS B to a LOS. C for both development scenarios. Although the level of service for this intersection decreased with the volumes collected by Benshoof, the intersection level of service and the individual levels of service are expected to ' operate at acceptable levels. At'the 77~' Street / Lyndale Avenue intersection, the overall intersection operation increased from a LOS D to a LOS C, .The improvement occurred because the volume collected by Benshoof was 100 vehicles less than the predicted average used in the DEIS. For both intersections in the Year 2022, the overall intersection level of service and the `' individual movement levels of service-did not significantly change-between the volumes . used in the DEIS .and the volumes collected by Benshoof. .~i Comment H2: DEIS does not present a means to implement needed improvements at 76``' Street _ , ;,# and York Avenue. Res onse H2: See res onse to Comments F 1 and F2. P P ;~-a ...: i l d t 494 l l w r not ana ze . - e e y rne anes of Comment H3: Potential traffic rmpacts on the marn ~ Response H3: See Section 5.2. 1 . !" Comment H4: Traffic impacts were not :analyzed during the approximate five year period in 1h Avenue) will be significantly disrupted due which traffic flow on I-494 (between TH 100 and 34 ~-~ to reconstruction of I-494. .,.,,,~~ Response H4: See response to Comment E2. The reconstruction of I-494 is not part of this Projector this EIS. The impacts of I-494 construction were addressed in the -1994 Draft I-494 Environmental Impact Statement, and will be updated in the Final I-494 Environmental Impact Statement being prepared by MnDOT, which is to be published iri January 2001. Comment HS: Traffic analysis did not address potentially serious safety and congestion impacts to traffic flow on 1-494 between Penn Avenue and 1-35W due to shorter weaving distances and _- _~ increased weaving volumes. ~..~ Response H5: See Section 5.3. .~._~.; -_~.; Comment H6: Traffic analysis did not account for metering of entrance ramps to 1-494 and I- _ 35W,• the volumes projected to use those ramps far exceed their capacity: • • PM peak hour volumes projected in .the DEIS for the ramp from 76`h Street to northbound I-35W are within the ramp capacity for both 2003 analysis scenarios, buf the projected ~-~--- Best Buv Campus October 30, 2000 ~" '~ Final Environmental Impact Statement Page 17-18 ,.--- volumes exceed the ramp capacity for both. 2022 analysis scenarios. • PMpeak hour volumes projected in .the DEISfor both ramps from PenmAvenue to 1-494 substantially exceed the ramp capacities for all 2003 and 2022 analysis scenarios. Response H6: See Section 12.5. The ramp capacities would be exceeded at the longer cycle lengths identified by the commentor. However, because MnDOT adjusts meters to shorter cycle lengths, based on traffic volumes, the capacity of the ramps would not be exceeded. y Comment H7: The traffrc analysis did not account-for potentially major traffic impacts on nearby local streets, due in part to trips diverted from freeway entrance ramps: Response H7: See Section 5.5. for analysis oflocal streets. As described in Comment H6, the ramp meters will be adjusted to accommodate the traffic volumes predicted. Additionally, with the design improvements programmed on the local arterials (76`h Street, Penn, and 79`" and 80`h Streets), there will be little incentive for traffic to use local side streets as alternative routes. I. Malkerson Gilliland and Martin LLP on behalf of Walser Automotive Group, Inc. ;~ The City made four attempts via voice messages to obtain clarification on Mr. Malkerson's comments. The calls were not returned.. Afollow-up letter requesting clarification was mailed. See Julie Urban letter to Bruce Malkerson in Appendix H. No reply has been received. The comments provided are general and do not identify specific defects in the analysis. Therefore, the responses provided are also general. Comment II: The noise analysis does not include impacts on other relevant receptors. Response I1: The commentor does not identify where other relevant receptors are located. Based on standard noise modeling procedures, the noise analysis was completed using receptors near the intersections most impacted by Site-generated traffic. See. Section 8.0 of DEIS. Comment 12: There is not an adequate analysis of the noise which will emanate from the Best Buv Campus. Response I2: Given the proximity of the Project Site to two major, high-volume, transportation corridors, the Site-generated noise would not be distinguishable from the background noise levels at the perimeter of the Site. Project-generated noise considerations are focused on mechanical vibrations, and audible noise from rooftop equipment such as air conditioners. Noise control systems for rooftop • equipment will be used to mitigate rotating equipment and casing radiation noise, duct- borne noise from supply and return fans, and breakout noise from the fans and- compressors ducted into the space below. Best Buv Camp:~s October 30, 2000 Final Environmental Impact Statement Page 17-19 "" The Best Buy Campus will comply fully with state noise regulations.: -•~ • Comment I3: There is not an adequate analysis of the impacts of noise from vehicles traveling to and from the Best Buy Campus. Response I3: A full traffic noise analysis was. presented in DEIS Section 8.0. The commentor has failed to identify any specific deficiencies in the analysis. Comment I4: The carbon monoxide analysis does not include a suj~cient number of receptor sites which are affected by the Project and the analysis to date was based on a faulty and incomplete traffic analysis. Response I4: A full air quality analysis was presented in DEIS Section 7.0. The commentor has failed to identify any additional receptor sites which should be studied or the "faulty and incomplete" portions of the traffic analysis specific deficiencies in the analysis. Comment IS: The DEIS does not adequately address the alternatives of No Build , or limiting the scale or magnitude of the Project • Res onse I5: The DEIS addresses the No-Build Alternative and the other alternatives P selected in the scoping process in great detail. The commentor has failed to identify any specific deficiencies in the analysis. Comment I6: The DEIS does not adequately address the alternative of moving the Project to another location. Response I6: The Scoping Decision did not require that an alternative of moving the . Project to another location be addressed in the DEIS. The commentor did not raise this issue during the scoping process and has not challenged the Scoping Decision. Comment I7: The DEIS does not adequately address the impacts of the Project on the public roadways for the years between .2003 and 2022. The DEIS does not adequately address. the impact of the Project if certain assumed improvements to the public roadways are not completed by the times assumed in the DEIS. Response I7: The DEIS presented a detailed traffic analysis in Section 5.0 and Appendix B. The commentor has failed to identify any specific deficiencies in the analysis. The commentor should also see Sections 5.0 and 12.5 of the FEIS for additional information. For Project Roadway Improvements, there is no impact because Best Buy • Campus cannot be occupied until they are completed. October 30, 2000 Best Buy Campus Page 17-20 Final Environmental Impact Statement 3.5 DETERMINATION OF ADEQUACY After reviewing the comments on the FEIS, the City determined that certain questions. and concerns merited additional analyses. This additional work performed included: • For traffic, additional description and analysis of ramp metering was prepared, further description and analysis regarding weaving distance and traffic safety on I-494 was done, the two traffic software models used to predict intersection and. intersection movement levels of service were compared in detail; a mistake in the mainline analysis was corrected and mitigation analyzed,.and-arterial street capacity was completed; • For the Proposed TDM Plan, the Plan was refined by adding car and van pool preferential spaces and certain financial .incentives; • For the 76`h Street reconstruction alternatives, further analysis was performed and discussions held regarding impacts on, and mitigation for, the Fountainhead and Colony apartment complexes; and • For noise, additional analysis was performed for the AM Peak Hour, impacts in-2022 and impacts on a school at the Penn Avenue / 76a' Street intersection; additional study was done of potential temporary noise impacts during construction of the Penn Avenue Bridge on the 82na Street detour route. This additional work was incorporated in this Adequacy Determination And Record Of Decision For The Best Buy Campus Environmental Impact Statement (Record Of Decision). This Record Of Decision contains responses to the FEIS comments in Appendix A. Copies of this Record Of Decision were distributed to the City Council on December 7, 2000. Commentors requesting the Record Of Decision were also .provided copies on December $, 2000, even though the City is not required by the MEQB Rules to distribute the document until after the City Council makes its adequacy decision. 4. FINDINGS After considering the Scoping EAW, the Scoping Decision, the DEIS, the FEIS, the responses to comments on these documents, other documents referenced in these documents, the report of its staff, and public testimony, the Richfield City Council makes the following Findings with regard to the alternatives studied, the significant environmental, social and economic effects expected to result from the proposed Best Buy Campus, and potential mitigation measures identified to reduce or eliminate those effects. Adequacv Determination and 6 December Il, 2000 Record Of Decision Best Buy Campus r 4.1 ALTERNATIVE STUDIED 4.1.1 Project Alternatives As provided in the Scoping Decision, three Project Alternatives were studied -the No-Build, Alternative 1 with five buildings and Alternative 2 with. four buildings. The No-Build Alternative was studied with respect to all expected significant impacts. Two Site design concepts, Alternative 1 and 2, were also .studied. The Alternatives differed as to number of buildings and building locations; sizes and heights. Both layouts-could accommodate the minimum and maximum options for square footage and parking spaces by adding floors to one or more buildings and levels to the parking ramps. Each. design plan provided a commons area and storm water ponds. Alternative 1 would contain five buildings clustered around a central pond that would extend out among the buildings. A commons area would be constructed between two of the buildings. Parking would be provided in three structured ramps and one surface lot along the southerly side of the property. This lot would eventually be taken for the expected expansion of I-494. Alternative 2 would contain four buildings in the southwest half of the Site with ponds located along the southerly and southwesterly sides of the Site. A commons azea would be constructed between the four buildings and the parking ramp. Parking would be provided in one structured ~~ ramp in the northeast portion of the Site and in three surface lots. The surface lots would be off Newton next to the daycare center; off Penn Avenue between two buildings for visitors, and along the southerly side of the property. The latter would eventually be taken for I-494 expansion. 4.1.2 76`h Street Reconstruction Alternatives As provided in the Scoping Decision, three alternative alignments for reconstructing 76ei Street were studied -widening the roadway to the north, widening it to the south or widening it both to the north and south. The property impacts were identified for all three alternatives, with the south alternative affecting the least number of properties. 4.2 EROSION CONTROL 4.2.1 Impacts The Project Site does not contain any excessively steep slopes nor does it lie within any shoreland or wetland zones within the approximate 42 -acre drainage azea. All of the Site would be graded with approximately 300,000 cubic yards of material moved on-Site and 15,000 cubic yards removed from the Site. Adequacy Determination and ~ December Il, 2000 Record Of Decision Best Buy Campus i• • 4.2.2 Mitigation A sediment and erosion control plan has been prepared and will be submitted to the City for final approval as required by the City's Fina] Development Plan and Conditional Use Permit. Best management practices described in the DEIS will be incorporated into the control plan to minimize erosion and sedimentation during construction. 4.3 SURFACE WATER RUNOFF 4.3.1. Impacts Under Alternative 1, a single on-Site storm water treatment and storage pond would be constructed to accommodate runoff from the Site. Under Alternative 2, two treatment and storage ponds would serve the same function. Both alternatives would result in substantial reductions in the peak discharge rate of the Site. Flooding of areas in the vicinity of the Project, that has historically been a problem for the City due to lack of adequate detention and piping facilities, would be significantly reduced. Both alternatives greatly improve the quality of the storm water runoff from the Site through construction of storm water ponds and additional piping. Total phosphorus in Site runoff would drop by 58%; total suspended solids by 82%; biochemical and chemical oxygen demand by 40%; and metals by 40% to 85%. 4.3.2 Mitigation Neither alternative addresses storm water runoff from property and streets to the north of the Site which now flows through the Site on City streets. However, two mitigation options were described in the DEIS to handle storm water drainage from areas north of the Site. Option l would reroute the off-.Site drainage to flow around the Site. Option 2 would reroute off-site drainage into the Site ponds which would be designed to treat and contain the additional volume. The City and Best Buy have identified Option 2 as'the preferred mitigation measure. This would provide additional flood mitigation and water quality improvement in the Project area. A storm water management plan has been prepared and will be submitted to the City for final approval. as required for the City's Final Development Plan and Conditional Use Permit. 4.4 TRAFFIC The traffic analysis completed for the Project included the evaluation of potential impacts on 19 intersections, on the regional transportation system (specifically I-35W and I-494), on trafl'ic weaving at Penn Avenue and I-494, and on residential streets. A Proposed TDM Plan has also been prepared. Adequacy Determination and 8 December 11.2000 Record Of Decision Best Buy Campus 4.4.1 Intersection Impacts. The intersectionanalysis was conducted for the Years 2003 and 2022 in both the AM and PM peak hours, with and without the Project. The analysis assumed the following improvements (collectively the Project Roadway Improvements): • Reconstruction of the Penn Avenue Bridge over I-494 to a single-point diamond interchange and the widening of Penn Avenue between the Southtown Access and the Project Site West Access in the City; • Reconstruction of the Penn Avenue / 76`~ Street intersection to include two through lanes, dual left turn lanes, and a dedicated right tum lane in each direction; • Reconstruction of 76~' Street between Penn Avenue and I-35W to include two through lanes in each direction, protected left turn -lanes and dedicated right turn lanes at Knox and Newton Avenues; and • Installation of traffic signals at the Penn Avenue /Project Site West Access intersection, the 76~' Street /Newton Avenue intersection and the 76`~ Street / Knox Avenue intersection. In the Year 2003 without the Project, a number of intersections and movements at intersections in the vicinity of the Project Site would operate at level of service (LOS) E, poor conditions, or LOS F, failing conditions; due to background traffic.. a. Option A .For the Year 2003, assuming construction of Project Option A (7,500 employees), all intersections impacted. by Site-generated traffic are expected to operate at a LOS D, acceptable conditions, or better in both the AM and PM peak hours. The Project Roadway Improvements are expected to improve significantly the operation of the Penn Avenue / 76`~ Street intersection (from LOS F to LOS C) and to eliminate queue lengths exceeding storage lengths at the Penn Avenue / I-494 intersection ramps. At the 76`'' Street / I-35W intersection, the north approach right turn movement queue in the AM peak hour is expected to exceed storage length and impact the I-35W mainline. A number of mitigation options for this intersection were identified. The ~ preferred mitigation is described in the mitigation section below. - For the Year 2022, assuming construction of Project Option A (7,500 employees), all intersections impacted by Site-generated traffic are expected to operate at a LOS D (acceptable conditions) or better in both the AM and PM peak hours. The Programmed Roadway Improvements are expected to improve significantly the operation of the Penn Avenue / 76~' Street intersection (from LOS F to LOS C) and to eliminate queue lengths exceeding storage lengths at the Penn Avenue / I-494 intersection ramps. At the 76~' Street / I-35W intersection, the north approach right turn movement queue in the AM peak hour is no longer expected to exceed the storage length because the I-35W / I-494 Interchange would have been rebuilt. Nevertheless, the queue is long enough that Minnesota Department of Transportation (MnDOT) may require mitigation. I Adequacy Determination and 9 December Il, 2000 Record Of Decision Best Buy Campus b. Option B For the Year 2003, assuming construction of Project Option B (9,500 employees), all intersections impacted by Site-generated traffic .are expected to operate at a LOS D or better in both the AM and PM peak hours, except the. 76~' Street / I-35W intersection which is expected to operate at LOS F in the AM peak hour. Site-generated traffic in the AM peak hour is expected to cause the queue length at the Penn Avenue / I-494 West Ramp intersection to exceed storage length and impact the I-494 mainline. Option B would require mitigation measures for the 76~' Street / I-35W intersection and the Penn Avenue / I-494 -West Ramp intersections. .For the Year.2022,-assuming~construction ofProject.-Option B {9,500 employees), all intersections impacted by Site-generated traffic would operate at a LOS D or better, excepf the Penn Avenue /Project. Site West Access intersection, which would operate at a .LOS F in the PM peak hour. At the 76~' Street / I-35W intersection, the north approach right turn movement queue in the AM peak hour is no longer expected to exceed the storage length because the I-35W / I- 494 Interchange would have been rebuilt. Nevertheless, the queue is long enough that MnDOT may require mitigation. However, Site-generated traffic in the AM peak hour is expected again to cause the queue length at the Penn Avenue / I-494 West Ramp intersection to exceed storage length and impact the I-494 mainline. Site generated traffic also causes deficiencies in the PM peak hour at the 76~' Street / Knox. intersection and the Penn Avenue / 80~' Street intersection. Mitigation would be required at these last three intersections. Based on the impacts identified in the intersection analysis, Option A is the preferred density option for the Project since it has less impact on traffic and requires the least amount of mitigation to minimize traffic impacts. 4.4.2 Intersection Mitigation A range of mitigation options is provided for each substantial intersection impact including, design improvements for specific intersection movements, a reduction in Site-generated trips through use of a TDM Plan and a reduction in the size of Option B to less than 9,500 employees. The City has identified a preferred mitigation for AM queue length impact at the northbound I- 35W ramp at 76~' Street. The City would. retain the "No Right Turn On Red" sign, and add a second lane to the ramp to increase queuing capacity. 4.4.3 Mainline Impacts In the Year 2003, the traffic generated by either Project Option A or Option B would not affect -_ the level of service on I-35W, however both Options would have an impact in 2003 in the AM peak on the mainline of I-494 between Penn and Xerxes, changing the level of service from E to F. In the Year 2022, the traffic generated by Project Option A would not affect the level of service on either I-494 or I-35W. Option B would cause the level of service on the segment of I-494 between Xerxes Avenue and Penn Avenue to drop below an acceptable level of service in the AM and PM peak hour. Adequacy Determination and ~ ~ December 11.2000 Record Of Decision Best Buy Campus 4.4.4 Mainline Mitigation Option A is the Selected Alternative. Mitigation for the mainline traffic impacts in 2003 resulting from the Project will be completed by MnDOT with their proposed I-494 reconstruction project. 4.4.5 Weaving Impacts A study prepazed by MnDOT on weaving .issues, which can be compazed to construction of the Penn Avenue single-point diamond bridge, concluded that the reconstructed bridge will provide longer ramps and higher ramp speeds which-would lessen weaving conflicts and improve performance on eastbound I-494 west of the bridge. Benshoof and Associates,- Inc. representing Walser Automotive Group, disagrees with this conclusion and presented information in support ' of its position. 4.4.6 Weaving Mitigation Based on the MnDOT study findings, no mitigation is required. 4.4.7 Residential Streets The best way to prevent traffic from cutting through residential neighborhoods is to maintain an arterial street system with an adequate level of service. The traffic analysis indicates that the Project Roadway Improvements would increase the level of service on Penn Avenue and 76`~ Street significantly. Improved travel times on these streets would give drivers less reason to use nearby residential streets. Additionally, data provided shows that the arterial streets that are near the Project area have adequate capacity to accommodate additional. traffic from the Project.. It was also found that ramp meters have sufficient capacity, with adjusted timing to minimize traffic. on residential streets. Benshoof and Associates, Inc. representing Walser Automotive Group, disagrees with these conclusions and presented information in support of its position. 4.4.8 Residential Street Mitigation Based on the expected level of development, worst-case trip distribution and the capacity and present volumes of the arterial streets, the Project Road Improvements provide the capacity necessary to minimize impacts to residential streets. 4.4.9 Proposed TDM Plan The Proposed TDM Plan goal has been revised to reduce trips to the Best Buy Campus in each peak hour by 450 to 750 trips. The Plan outlines a combination of strategies including transit, carpooling, vanpooling, staggered hours, .flex-time and telecommuting to reach this goal. A full time Campus Transportation Coordinator will oversee these efforts. The Proposed TDM plan will be submitted to the City for final approval as required by the Final Development Plan and Conditional Use Permit. Adequacy Determination and 11 December 11, 2000 Record Of Decision Best Buy Campus . 4.5 76`n STREET. RECONSTRUCTION 4.5.1 Impacts Three alternatives for the reconstruction of ?6`n Street were analyzed - ntrtrocerttresl. Ad south alignments. This road reconstruction would impact a number of ad~ac p p alignments impact eight properties at the Penn Avenue intersection. The North alignment impacts eight additional properties for a total of 16. The Central alignment also impacts eight additional properties, for a total of 16. The South alignment would have the fewest property impacts with only two additional properties affected for a total of'i0. 4.5.2 Mitigation First, the South alignment has been selected bythe-City as the preferred alignment since it has the least impact to adjacent property owners. The City will coordinate with each affected property owner to determine specific location and size impacts and identify mitigation options specific to those properties. Second, the City has reconfigured the 76`n Street /.Penn Avenue intersection to avoid the taking of any buildings. or full pazcels. Third, the loss of twenty pazking garage stalls at Fountainhead Apartments could be mitigated through. payment of a damage awazd by the City for right-of--way that can be used to construct ' ~ new garage stalls at a different location on the property. The City is proposing no net loss in on- site pazking. _ Fourth, a mitigation measure has been identified which has Knox Avenue as afour-legged intersection that is shifted~slightly to the west. The details of the intersection layout are being designed. as part of the 76 Street Reconstruction project. This alternative allows Fountainhead to retain their northerly access, and also provides the opportunity to allow the Colony Apartment Complex access to be connected at the intersection. 4.6 AIR QUALITY 4.6.1 Impacts The air quality analysis completed for the Project concluded that all applicable Federal and State. regulations are satisfied and that the Project alternatives and options will not cause exceedances of carbon monoxide (CO) standards based on representative analysis at worst-case locations, under worst-case conditions. For all conditions modeled, the highest one-hour and eight-hour predicted concentrations will be 6.9 and 6.6 parts per million (ppm) respectively. These values aze below the State standazds of 30 ppm for one-hour and 9 ppm for eight-hours. 4.6.2 Mitigation No mitigation is required since the increase in air pollutants is inconsequential. 12 December 11, 2000 Adequacw Determination and Best Buy Campus Record Of Decision 4.7 TRAFFIC-RELATED NOISE 4.7.1 Impacts Traffic noise analyses were completed for Options A and B for both the AM and PM Peak Hours in both 2003 and 2022. In addition, a noise analysis for the temporary construction detour for the Penn Avenue Bridge was performed. In 2003 during the AM Peak Hour, the additional noise from Option A traffic would be just perceptible at Receptors N-1 (77~' Street and Penn Avenue) and N-2 '(Newton Avenue at 76~' Street). The additional noise from Option B traffic would be clearly perceptible at Receptor N-l . In 2003 during the PM Peak Hour, the additional noise from Option A traffic would be just perceptible at Receptor N-2. The additional noise from'Option B-traffic would be just perceptible at Receptor N-2. In 2022 during the AM Peak Hour, the additional noise from Option A traffic (compared to 2003 No-Build) would be clearly perceptible at Receptors N-1 and N-4 (Penn Avenue at 76`~ Street). The additional noise from Option B traffic would be clearly perceptible at ReceptorN -1. In 2022 during the PM Peak Hour, the additional noise from Option A traffic would be just perceptible at ReceptorN-2 and clearly perceptible at Receptor N-4. The additional noise from Option B traffic would be just perceptible at Receptor N-2. The additional noise from temporary detour traffic at Receptor N-5 (Logan Avenue and 82"a Street) would not be perceptible. 4.7.2 Mitigation No mitigation is required. A screen wall could be constructed for a two block-long segment north of 76`h Street from Logan Avenue to Newton. Avenue. However, residents in the neighborhood will need to support the wall and the changes in access that would be needed to build a wall. Several homes that have direct access to 76~' Street would need to relocate their driveways to the north-south avenues. 4.8 HAZARDOUS MATERIALS, STORAGE TANKS, AND GROUNDWATER CONTAMINATION 4.8.1 Impacts The Phase I Environmental Site Assessment (ESA) identified a number of potential environmental hazards on the property including petroleum leaks, underground storage tanks, and water wells -both abandoned and in use. Adequacy Determination and 13 December 11, 2000 Record Of Decision Best Buy Campus _, • 4.8.2 Mitigation A Phase II Investigation Report and Voluntary Investigation and Cleanup Plan (WIC) has been prepared in .accordance with the recommendations of the ESA .and State regulations. Prior to .and during redevelopment of the Project Site, all contaminants will be removed and properly disposed, and wells will be sealed by a licensed contractor... 4.9 SOLID WASTES 4.9.1 Impacts - `V Waste generated from the demolition of the existing structures will be removed from the Site. Solid waste and recyclable materials generated from the activities in the office buildings will be removed from the Site and disposed of according to.local and State regulations. 4.9.2 Mitigation No mitigation is required. 4.10 CULTURAL RESOURCES 4.10.1 Impacts The State Historical Preservation Office (SHPO) conducted a site$les search, and an on-site reconnaissance was conducted by BRW cultural resources staff. Neither search produced sites or potential for intact. archaeological materials. A Phase I Historic Architecture Survey was completed on the Wally McCarthy Oldsmobile property because of the year built (1947) and distinctive building characteristics. It was determined by the State Historic Preservation Office (SHPO) that the property did not meet the minimum requirements for further investigation. 4.10.2 Mitigation No mitigation is required. 4.11 WATER SUPPLY 4.11.1 Impacts Current water demand for the residences and commercial businesses within the Project Site is approximately 35,000 gallons per day (gpd). Anticipated demand for domestic water for the Project will be 187,500 gpd for 7,500 employees (Option A) and 237,500 gpd for 9,500 employees (Option B). There will also be water needed for maintenance of the pond. and lawns. A 12-inch water main will be installed along 76a' Street to connect existing water mains, and additional water supply piping improvements will be constructed. Two wells. maybe installed Adequacy Determination and 14 December 71, 2000 Record Of Decision Best Buy Campus on-Site to supplement water supply for pond and landscape maintenance. Estimated demand would be 75,000 gpd. A Minnesota Department of Natural Resources (MnDNR) permit would regulate this use. If wells were not installed, this demand could also be met by the City water system. The water well capacity for the City is 19 million gallons per day. The current average daily demand in the City is 4 million gallons per day. Therefore, there is adequate capacity for the increased water demands by this Project. The .Project will. require.the relocation of two.water-mains that supply-water to -the:City of Bloomington. The timing of this reconstruction will impact that City's water supply. 4.11.2 Mitigation No mitigation is required as there is adequate water capacity within the current City system. A utility plan will be submitted to the City for final approval. Best Buy will continue to coordinate with the City of Bloomington and Richfield. on the timing of the water main relocation. 4.12 WASTE WATER 4.12.1 Impacts Current flow into the nearest lift station is approximately 203,000 gpd. The proposed sanitary. discharge from the Project is estimated to be 187,500 gpd for Option A, and 237,500 gpd for Option B. Based on the estimated waste water demands of the Best Buy Campus, the existing lift station and its wet well storage will bemodified as part of the Project to accommodate additional flows. Collection system pipes will be relocated and improved to maintain the current pumping rates in the Metropolitan Council Environmental Services (MCES) wastewater collection system. The lift station improvements will be completed prior to occupancy of the Project Site. a. Mitigation No mitigation is required. 4.13 VISUAL IMPACTS 4.13.1 Lighting Impacts The proposed lighting plan is in conformance with the City lighting code and the lighting guidelines set forth by the Illuminating Engineering Society. Landscaping will be designed to minimize lighting impacts. on the surrounding property. A final Lighting Plan and a-Final Landscape Plan will be submitted to the City for approval as required be a condition in the Final Development Plan and Conditional Use Permit. Adequacy Determination and iS December ll, 2000 Record Of Decision Best Buy Campus 4.13.2 Shadow Impacts A shadow analysis was completed for all four seasons for both alternatives. The study indicated that for Alternative l the shadows from the five buildings and parking facilities would be contained on the Project Site for much of the year, with Option B shadows extending slightly further. In spring and fall the properties to the eastand west of the Site would be affected by shadows in the early morning and late afternoon.. In the winter months, properties to the north would be in shadow for portions of the day. In Alternative 2, the shadows from the four buildings and parking facility would extend further out into the road right of way during the winter and affect additional properties than Alternative 1. The affected areas for both Alternatives .will primarily be streets and sidewalks where the potential for slow ice and snow melt and refreezing situations could pose a problem if the areas are not regularly sanded and salted. Under current city maintenance programs, 76`h Street, Penn Avenue and Knox Avenue are regularly salted and sanded therefore no mitigation is ~ , recommended. An additional analysis was completed for the partial parking deck which could be built to replace surface stalls lost to future I-494 expansion and found no additional impact. 4.13.3 Mitigation. No mitigation is required. 4.14 COMPATIBILITY WITH COMPREHENSIVE PLAN AND ADJACENT LAND . _ USES 4.14.1 Impacts The type of redevelopment proposed by Best Buy for this area of Richfield is consistent with the type of land use designated in the proposed amendment to the Comprehensive Plan for the Project Site. The Metropolitan Council has approved the plan amendment. Commercial development is already a large component of the Site and is also a major. component of the property adjacent to both sides of I-494 east and west of the. Site. 4.14.2 Mitigation No mitigation is required. 4.15 PUBLIC SERVICES 4.15.1 Impact The effect of the Project on roadways is discussed in the Traffic Section (Section 4.4 of this Record Of Decision) and includes information on the planned road improvements in relation to the increased volume of traffic. The effect of the Project on services such as sewer and water is `° discussed in Section 4.11, Water Supply Changes and Section 4.12, Waste Water. The effect on Adequacy Determination and 16 December Il, 20fl0 _~: Record Of Decision Best Buy Campus emergency services such as police, fire, and ambulance is discussed in Section 11.5 of the DEIS. The FEIS added supporting data on police calls expected. The data demonstrated no increase in police services. 4.15.2 Mitigation Any required mitigation is specifically described in the sections mentioned above. 4.16 SOCIAL AND ECONOMIC 4.16.1 Impacts The impact of the proposed development on various social and economic. factors is described in Section 11.6 in both the DEIS and the FEIS. Quantifiable costs and benefits to the City are measured and indicate that the development creates the following impacts: • Residents and businesses will be displaced by the Project; however, they will be financially compensated for their property and businesses. The.loss of residents to the City and school will be replaced through the use of a Housing Fund, to which a portion of the Project tax increment will be directed. • There will be a net benefit from the Project in direct and indirect employment and in consumer spending. • Increased City administrative costs in some areas will be offset by decreased costs in other areas. The highest administrative cost to the City will occur during the development and construction phases; however, fees and administrative tax increment will be collected to cover these costs. w w r • The City has an existing utilities infrastructure in place to serve the Project. The Project will use and pay for more of this infrastructure than the current uses do, which will allow for greater utilization of the City's existing resources. • The road network in the area currently operates below acceptable levels of service of several intersections. The Project Roadway Improvements will be made to accommodate Project traffic.. The City will benefit from these roadway improvements, which, without the Best Buy Campus, are not expected to occur for approximately 10 years. 4.16.2 Mitigation No mitigation would be required. Adequacy Determination and 1 ~ December Il, 2000 Record Of Decision Best Buy Campus `~ • ` 4.17 PEDESTRIAN SAFETY 4.17.1 Impacts Hennepin County crash data indicates that the pedestrian crash rate for 76`~ Street was 7.5 times lower than the Hennepin County average for similar roadways. In addition, based on Minnesota Department of Safety data, intersections with signals .and/or crosswalks are safer for pedestrians. The Project will ads signalized intersections with crosswalks at the 76`~ Street /Newton Avenue intersection, the 76 Street / Knox Avenue intersection and the Penn Avenue/ Best Buy entrance intersection. All three should enhance pedestrian safety in the area. The City also looked more closely at the mitigation options for the AM queue length'impact at the northbound I-35W ramp / 76`h Street intersection. 4.17.2 Mitigation As noted above, the City has identified a preferred mitigation for the northbound I-35W. ramp. at 76~' Street. The City would retain the "No Right Turn On Red" sign and add a second lane to the ramp to increase queuing capacity. 4.18 RAMP METERING 4.18.1 Impacts Examination of ramp metering in relation to Project-generated traffic indicates that ramp meters have sufficient capacity assuming the timing is adjusted. Specifically, MnDOT would reevaluate the metering at Penn Avenue and I-494 after reconstruction of the Penn Avenue Bridge and the opening ofthe Best Buy Campus. MnDOT also adjusts ramp metering every six months and, in response to complaints, conducts field surveys and adjusts ramp meters. Finally, ifaignificant queuing that impacts local streets is seen on MnDOT's CCTV cameras, MnDOT can manually override any ramp. connected to the system. Benshoof and Associates representing Walser Automotive Group, disagrees with this conclusion and presented information in support of its position. 4.18.2 Mitigation Based on MnDOT ramp metering practices, no mitigation is required. 4.19 DEWATERING Based on the estimated water table at the Site, construction dewatering is not expected for a building construction. Reconstruction of the wet well at Lift Station #3 would require small amount of dewatering for a period of a week or less. The amount of water that would be pumped under worst-case • conditions would not exceed 1 million gallons. and therefore would not likely require a permit. Details of the construction would be coordinated with the DNR hydrologist prior to any Adequacy Determination and 18 December Il. 2000. ~~ Record Of Decision Best Buy Campus. dewatering to verify permit requirements. BMP's for sedimentation would be implemented with any dewatering that may be necessary. 4.20 WILDLIFE HABITAT The DEIS (Section 12.2) identified the general landscape plans for both development alternatives. Both would provide improved habitat diversity over exiting conditions, however the layout of Alternative 2 provides connectivity with adjacent habitats, maintaining species mobility whereas Alternative 1 creates isolated habitat within pazking structures. 4.21 STATIONARY EMISSIONS Emergency generators aze the only potential source for stationary emissions. However, given the size and hours of operation anticipated for these generators, the emissions are not expected to trigger MPCA Registration Permit requirements. The specific generator types and locations on the site will be coordinated with MPCA. 4.22 CUMULATIVE IMPACTS Cumulative impacts and appropriate mitigation measures are addressed in the specific sections of the Draft and Final EIS. 4.23 .FINDINGS RELATIVE TO THE NO-BUILD ALTERNATIVE Under the No-Build Alternative, the following impacts would be expected: • The Penn Avenue / I-494 Interchange would continue to operate LOS F in the PM Peak Hour and the Penn Avenue / 76`~ Street intersection would continue to experience severe congestion for certain turning movements; • StornZ water runoff from the Project Area and the azea to the north would continue to flow into storm sewers without containment or treatment and intermittent flooding could be expected in the area; • Existing contaminants and hazardous waste on-site would not be contained or removed; .and • Landowners within the Project .Site would continue to experience uncertainty regarding future use or redevelopment of their properties. Adequacy Determination and 19 December 11, 2000 Record Of Decision Best Buy Campus ,_ 4.24 :FINDINGS RELATIVE TO THE DESIGN ALTERNATIVES Both alternatives have the same locations for access to the facilities and require the same public roadway improvements. Both alternatives include a surface parking lot on the south side that will be relinquished eventually for the expansion of I-494. 4.24.1 Alternative 1 The combination of five buildings and multiple parking ramps in Alternative 1 creates a wail effect between the-sun'oundingnefghborhoods and the Best Buy Campus. The area devoted to parking also maximizes the impervious surface on the Site and reduces the available open space. The green space and any trails in this design are internal to the Best Buy Campus. The common space connects two of the five buildings. 4.24.2 Alternative 2 The combination of four buildings and a single parking ramp in Alternative 2 frees up more open space on the site. The parking ramp wall effect is limited to a portion of 76~' Street and Knox Avenue at the northeast corner of the Site. The building layout provides open areas and green space between the buildings and the surrounding neighborhoods. The trail and several green spaces are open to the community. The commons area connects all four buildings and the parking ramp and may provide opportunities for community uses. 4.24.3 Preferred Alternative Based on the analysis and information presented, the City Council prefers Alternative 2 to Alternative 1 because: • Fewer buildings and a single parking ramp frees up more open space on the Site; • Due to the building layout and site design, more green space and landscaping face the community; • The trail which circumnavigates the property and several green spaces are accessible by the public; • Parking structures dominate fewer views of the Best Buy Campus; , • The view from the Penn Avenue / I-494 Interchange creates a more favorable gateway to the City; • Adequacv Determination and 20 December 11, 2000 . Record Of Decision Best Buy Campus • Access to the buildin s is more visible and visitor friendly; • g • The design has less impervious surface; and • The common space better serves the Best Buy Campus by connecting all buildings and the parking ramp and may provide opportunities for community uses. 4.25 FINDINGS RELATIVE TO THE DENSITY OPTIONS Option B, with 9,500 employees was specifically targeted by MnDOT, Bloomington, and the I-494 Comdor Commission as`having the potential for negative traffic impacts that could not be mitigated. Therefore Option A (1.5 million sq. ft. and 7,500 employees) has been selected as the preferred size of development. This option has the least .amount of impact on traffic level of service, mainline operations, ramp meters, and traffic on residential streets. This option also generates less traffic-related noise and air emissions, has less shadow cast from the buildings onto adjacent properties, has less water demand, and will produce less sanitary and solid waste. 4.26 FINDINGS RELATIVE TO THE 76`h STREET RECONSTRUCTION ALIGNMENTS ~~ Based on comments to the DEIS, the 76`~ Street Alignments have been modified in order to reduce further the impacts to properties near the intersection of Penn Avenue and 76~' Street. First, 76`h Street has been shifted south which minimizes the partial taking of land on the north side of 76`h Street. Second, Penn Avenue has been shifted west which reduces the partial taking of land on the east side of Penn Avenue north of 76`h Street. Third, the westbound right turn lane on Penn Avenue has been shortened by 150 feet to avoid the taking of a four-unit apartment building. With the reduction of the westbound right turn lane from 300 feet to 150 feet, a further queuing analysis showed that the queue lengths would not be expected to exceed the storage . lengths for all scenarios. The south. alignment of the 76a' Street reconstruction was also identified as the alignment most ' compatible with the existing conditions for that portion of the Project. The following Right of Way would be required for the south alignment: ' • The proposed 76~' Street south curb line will be 10-40 feet south of existing curb line except at the intersection with Penn Avenue; ' • The proposed north curb line will be the same as the existing curb line except at the intersection with Penn Avenue; • The proposed ROW will be approximately 15 feet further from the curb line for sidewalk, _. utilities, snow storage, etc; • V Adequacy Determination and 21 December 11, 2000 Record Of Decision Best Buy Campus ,' • .This alignment requires relocation of 20 garages at Fountainhead Apartments. These .garages will be replaced on Site or on adjacent excess MnDOT right of way or will be compensated to the landowner. • The access drive to Fountainhead Apartments, on Knox Avenue just south of 76a' Street, must be modified; • Access to Oliver Avenue and Morgan Avenue will be limited to right-turn only access. 4.27 FINDINGS RELATIVE TO KNOX AVENUE INTERSECTION ALTERNATIVES. In the FEIS, eight options were described to provide improved access to the frontage road and 76`h Street (see Section 6.4 of the FEIS for additional details). They were: 1) Leave the driveways and accesses as they are; 2) Provide east/west access to Logan Avenue; 3) Curve 76~' Street 20 feet further to the south than the proposed 76a' Street South Alignment; 4) Move 76`h Street 80 feet further to the south than the proposed 76`h Street South Alignment; 5) Remove apartment building, north of 76`~ Street at Knox Avenue; 6) Create skewed intersection by curving Knox Avenue to the west; 7) Create offset intersection; and 8) Move intersection west 40 feet. .:~ There have been numerous meetings held between Colony Apartment and Fountainhead Apartment representatives, the City, and the Developer to determine the most satisfactory solution to the .issue of ingress and egress for the apartment complexes. Additional and modified intersection options have been discussed and evaluated. Anew .alternative has been identified which has Knox Avenue as afour-legged intersection that is shifted slightlyto the west. The details of the intersection layout aze.being designed as part of the 76`h Street Reconstruction project. This alternative allows Fountainhead to retain their northerly access, and also provides the Colony Apaztment Complex with access to be connected at the intersection. This alternative would reduce the setback for the Best Buy pazking ramp. The proposed design for this intersection was found to be favorable by both apartment complexes. 4.28 PERMITS AND APPROVALS Based on the DEIS, the FEIS, agency comments and City requirements, the following permits and approvals will likely be required for Project construction.. Adequacy Determination and 22 December 11.2000 Record Of Decision Best Buy Campus Agreement between Best Buy and the City that must be completed prior to commencement of construction. b) The Project proposer has been and will continue to coordinate with the City and the City of Bloomington on the timing of the water main relocations as previously discussed with the Cities and described in the FEIS (Response G4, page 17-15) and DEIS (page 11-3). Comment C8: Penn Avenue and I-494-Interchange reconstruction should be closely coordinated with MnDOT, Bloomington, and area businesses and residents to•minimize negative impacts. Response C8: The City will stipulate in its contract with the bridge contractor incentives for early completion -and penalties for delays. The City intends to limit the bridge closure for the minimal amount of time necessary to complete the work. Several meetings have occurred with the tenants and open houses were conducted to inform businesses and residents of the planned bridge construction schedule Comment C9: The City should continue to work with MnDOT to facilitate an alternative temporary 1-.494 Interchange at Xerxes Avenue. The Penn.Avenue/1-494 Interchange should be completely operational before significant work begins on the Lyndale Avenue/1-494 Interchange. Response C9: The City will continue to work with MnDOT on the temporary Xerxes exit ramp. The City does not intend to close or start significant work on the Lyndale/I-494 Interchange until the Penn Avenue Interchange is completed. D. Malkerson Gilliland Martin LLP on behalf of Walser Automotive Group.. Once again, this commentor offers general criticisms which do not cite specific deficiencies in the FEIS or suggest specific additional analyses which might be helpful. The City again attempted via voice. messages to obtain clarifications of Mr. Malkerson's comments. Mr. Malkerson replied via voice message that he would not be available for at least a week to respond. Therefore, the responses provided are also general. Comment Dl: The pace that the. City has set (and been maintaining) for this environmental review is much too aggressive given the proposed project. Response Dl: The City disagrees that the schedule for this EIS is much too aggressive. The City began work on this environmental review in April and expects to complete the review in December, a period of nine months. From Responses to Comments Letters on FEIS December 11, 2000. Page A-6 - - -~- - • publication of the Scoping EAW on May 15, 2000, to -the date of expected City Council action on adequacy on December 11, 2000, will be eight months. These are reasonable time frames which allow adequate time for analysis and comment. In comparison, the City understands that EIS level environmental reviews for projects of comparable size and complexity have been completed in slightly more than six months. Comment D2: In several sections of the FEIS> the analysis is not at all thoughtful or searching, and at times it is conclusory. Response D2: In stating that that the analysis in several sections is "not at all thoughtful or searching," the commenter does not identify any section of either the DEIS or the FEIS to which the comment applies. Nor does the commenter suggest additional analyses which might improve the information provided. The City disagrees with this comment and believes that all the potentially significant environmental impacts have been analyzed at the level of detail required for an EIS. In stating that the analysis in several sections is "at times conclusory," the commenter does not identify any section of either the DEIS or the FEIS to which the comment applies. An EIS must draw conclusions about impact levels and the applicability of mitigation measures. Without some specific reference to a • conclusion in the EIS as unsupported or wrong, a more specific response is not :possible. Comment D3: Since publication of the DEIS, the City has obtained Metropolitan. Council approval of comprehensive plan amendments that are necessitated by the proposed Best Buy Campus. Similarly> the Richfield Planning Commission has (1) approved rezoning of the project property, (2) approved a conditional use permit for the project, and (3) approved a PUD plan for the project. The granting of these approvals violates EQB rules and increases the likelihood that the project will be developed as currently proposed. Response D3: The MEQB Rules prohibit making a "final governmental decision...to grant a permit, approve a project or begin a project until an EIS is determined adequate." None of the actions cited by the. commenter are final ..governmental decisions. The. Metropolitan Council review and approval of a Comprehensive Plan Amendment has no legal effect on the Project until the City Council adopts the Comprehensive Plan Amendment. The Richfield Planning Commission's actions are advisory to the City Council. The City Council will not make final governmental approvals with respect to the Comprehensive Plan, rezoning, PUD plan or a conditional use permit for the Project until after a determination of EIS adequacy.. • Responses to Comments Letters on FEIS December 11, 2000 ..Page A-7 • Comment D4: The FEIS does not compare the proposal with any alternative site. In other words, a critical component of the EIS was handled privately by Best Buy before the environmental review process began, without governmental or public input, and without a meaningful comparison of environmental effects. Response D4: The Scoping Decision did not require that an alternative site for the Project be addressed in the DEIS. Thee commentor did not raise this issue in the scoping process and has not challenged the Scoping Decision. Comment DS: The FEIS does .consider alternative designs and project scales, but the. consideration is artificial. Response D5: The comment is noted. The City disagrees. Significant differences exist between the designs presented in Alternatives 1 and 2. Both. designs were under serious consideration by Best Buy at the beginning of the EIS process. The City determines as part of this Record Of Decision that Alternative 2 is preferable based on the EIS analysis. The density differences between Option A and Option B under each alternative are not artificial. Best Buy asked to consider a greater density on the Site in case corporate growth exceeded expectations. As shown particularly in the traffic analysis, Option B under either alternative design presents significant problems. The City in this adequacy determination has selected Option A with 7,500 employees as the preferred option. Comment D6: The FEIS also describes only two density alternatives. Response D6: The Scoping Decision did not require analysis of more than the two density options. The commentor did not raise this issue during the scoping process and has not challenged the Scoping Decision. Comment D7: One of the most significant effects of the proposed Best Buy Campus K~urrlrl be the loss of some 170 units of affordable housing. The FEIS does not examine a) titi~hether the loss of this housing will push the displaced residents toward the outer reaches of the metropolitan area; 6) the effect that the loss of this housing will have on remaining sections of this. neighborhood; c) x~hat concrete measures the City of Richfield will take to replace these housing units or otherwise mitigate the effects of the loss. Response D7: There are 169 housing units within the Interchange West area (89 apartments units, 54 single family homes, and 26 duplex units). • Providing an adequate supply of affordable housing is a significant regional issue, and the City has long been a leader in doing so. However, a focus only on Responses to Comments Letters on FEIS December 1 ~, luuu .Page A-8 .7 affordability hinders the City's ability to meet other community needs, which include providing a broader range of housing types and prices. -The City and the Metropolitan Council have established "Livable Communities" goals to provide greater economic integration of the City's housing stock. A 1999 revision of the goals indicates that Richfield's owner-occupied housing is 86 percent affordable (for households earning 80% of the median income), and its renter-occupied housing is 64 percent affordable. The affordability benchmark set by the Metropolitan Council for Richfield is 64 to 77 percent for owner-occupied housing and 32 to 45 percent for renter-occupied housing. Therefore, the City exceeds the Metropolitan Council's benchmark. Using the Metropolitan Council affordability levels for the City and applying it to the Interchange West area result in the following assumptions of affordability: 57 owner occupied units would be considered affordable and 65 renter-occupied housing units would be considered affordable (total of 122). The Metropolitan Council comment on the FEIS recognizes that the Best Buy Campus project does not negatively impact the City's housing goals stating that, "The Final EIS for the Best Buy Campus satisfactorily addresses the impact of the proposal on housing in the area affected." a) The City has experienced a loss of housing from airport and road expansion and redevelopment projects in the past and has always sought to .relocate within Richfield as many of those households as .possible. For. example, in the case of the New Ford Town/Rich Acres buyout by the airport, 25 to 30 percent of the households relocated in Richfield. Assuming a similar percentage in the Interchange West area, 42 to 59 of the households could be expected to relocate in Richfield. b) The housing units within the project area makeup the entire neighborhood. The neighborhood is isolated by 76'h Street on the north, Penn Avenue on the west and commercial uses on the south and east. c) The City has experienced .the loss of housing units and population due to airport expansion, roadway projects, and demographic factors and, on an ongoing basis, seeks to replace these losses through its housing and redevelopment programs. Because the Best Buy Campus does not include a physical housing component, a portion of the Project tax increment ($7 million) is being dedicated to Richfield's housing fund. The funds will be used to construct new and rehabilitate existing housing. With regard to replacing affordable housing units, despite the significant amount of affordable housing existing in the community, it is the HRA's policy to always evaluate an affordable housing component in its housing and redevelopment programs. • Responses to Comments Letters on FEIS December 11, 2000 Page A-9 Comment D8: Tl1e Penn Avenue Bridge reconstruction to a single point diamond • interchange and the widening of Penn Avenue are of such size and regional importance that they should be the subject of an independent environmental review process that is coordinated with the preparation of an-EIS on the proposed Best Buy Campus project. Response D8: While it is true that both the Penn Avenue Interchange project and the 76~' Street Reconstruction project have been programmed to be completed even without the Best Buy Campus, the mandatory requirements for state environmental reviews for roadway projects are not met by either road project. According to Minn. Rules 4410.4300, subp. 22, a road reconstruction project must be at least one mile in length and add new travel lanes to require preparation of an Environmental Assessment Worksheet. The 76~' Street project adds additional travel lanes but does not exceed one mile in length. The Penn Avenue Project also adds additional travel lanes but does not exceed one mile in length. Interchange projects only require state environmental review when they are proposed in a new location. Therefore, the size of these road improvement projects does not warrant independent environmental- review under the MEQB Rules. The federal environmental review process requires a Project Memorandum to be completed for the Penn Avenue Bridge project. This environmental document was prepared by MnDOT and the City and is being reviewed by the Federal Highway Administration. Review of the Project Memorandum is expected to be • complete by the end of December, 2000. A federal environmental review is not required for the 76a' Street Reconstruction Project. Comment D9: There is no analysis of the impact of rerouted traffic (and related noise and carbon monoxide levels) through residential neighborhoods and elsewhere while the Penn Avenue Interchange is under construction. Response D9: The traffic detour plan for the Penn Avenue Bridge project is illustrated in Figure 12.4 of the FEIS. The reference to this figure was omitted in the FEIS. With the closure of the Penn Avenue Bridge, the traffic volumes on 82"d Street between Penn Avenue and I-35W are expected to increase approximately 100 percent. On 80`f' Street, the traffic volumes are expected to decrease by approximately 10% between Penn Avenue-and Xerxes Avenue, but increase by approximately 35% between Xerxes Avenue and France Avenue. Table A-1 lists the 1998 Average Daily Traffic (ADT) volumes from the MnDOT Traffic Flow Maps, the approximate capacities of the roadways, and the estimated ADT volumes during the reconstruction of the Penn Avenue Bridge for these roadways. • Responses to Comments Letters on FEIS December 11, ZUUU Page A-10 • T~tiio s_~ • AvPraaP nails Traffic (ADTI Volumes, 1998 - ^~ o ADT After Best 1998. ADT During Buy ADT Capacity Construction Development Location ( d)' ( d) ( d) d 82 St b/t Penn & I-35W 8,200 23,000 16,400 8,650 80` St b/t Penn & Xerxes 13,700 34,000 12,330 13,850 80` St b/t Xerxes & France 12,500 34,000 16,875 12,650 1 Volumes taken from the Mnuv ~ i rarnc nuw rv~aps wcu~~~c~ yc.~ uny/ As can be seen from this table, the available capacities. of these roadi~ays are expected to accommodate the increase in traffic volumes on 80th Street and 82"a Street during the reconstruction of the Penn Avenue Bridge. The 76th Street reconstruction project-would not require a detour since the roadway is expected to have one lane in each direction remain open during construction, with the exception of temporary shut downs as utilities are worked on. The '76`x' Street construction-related impacts will be temporary and occur only within the 2001 construction season. Alternative routes available for traffic would be I-494, 80`h and 82"a Streets.` After review of the detour ptan for the Penn Avenue Bridge project and the associated traffic analysis, additional noise analysis was conducted for 82"a Street between Penn Avenue and I-35W. The model showed no impact for the , temporary noise increase expected from increased traffic volumes along 82"a due to the Penn Avenue Bridge closure. All other increases in traffic due to the bridge closure were less than the analyzed intersection and, therefore, can be predicted to have no impact. See Comment D 10 for noise model results. Comment 010: The noise analysis in the FEIS does not include impacts on other relevant receptors, which, as you knotir, would include especially all residential and other Noise Area Classification. Uses pursuat:t to Minnesota Rules 7030.0050. Response 010: The noise analysis in the FEIS identified receptors that represented locations that had worst case conditions for potential noise impact. Standard procedures outlined by the MPCA were followed. It is reasonable to assume that, if there were no or little impact for the worst case receptors, other receptors in the vicinity would have the same or less of an impact. • An additional analysis was conducted to include the addition of the church/school located on the corner of 76`h and Penn (Receptor N-4) to,identify the level of impact to this type of sensitive noise. receptor. Additional analysis was also completed for the residential area along 82"a between I-35W and Penn (Receptor N-5) as a sensitive noise receptor during the construction of the Penn Avenue Bridge..To-complete .the documented analysis, the AM peak and year 2022 f 11 f ~d t'f d sensitive noise rece tors were also analyzed' (see Responses to Comments Letters on FElS December 11, 2000 Page A-11 .analysis or a the t en t ~e p Fi re 1) Traffic noise analyses were completed for Options A and B for both the AM and S PM Peak Hours in both 2003 and 2022. In addition, a noise analysis for the temporary construction detour for the Penn Avenue Bridge was performed. In 2003 during the AM Peak Hour, the additional noise from Option A traffic would be just perceptible at Receptors N-1 (77`t' Street and Penn Avenue) and N-2 (Newton Avenue at 76`h Street). The additional noise from Option B traffic would be clearly perceptible at Receptor N-1. In 2003 during the PM Peak Hour, the additional noise from Option A traffic would be just perceptible at Receptor N-2. The additional noise from Option Btraffic-wouldbe just perceptible at Receptor N-2. - In 2022 during the AM Peak Hour, the additional noise from Option A (compared to 2003 No-Build) traffic would be clearly perceptible at Receptors' N-1 and N-4 (Penn Avenue at 76'h Street). The additional noise from Option B traffic would be clearly perceptible at Receptor N -1. In 2022 during the PM Peak Hour, the additional noise from Option A traffic would be just perceptible at Receptor N-2 and clearly perceptible at Receptor N-4. The additional noise-from Option B traffic would be just perceptible at Receptor N-2. The additional noise from temporary detour traffic at Receptor N-5 (Logan Avenue and 82°d Street) would not be perceptible. No mitigation is required. A screen wall could be constructed for a.two block- long segment north of 76'h Street from Logan Avenue to Newton Avenue. However, residents in the neighborhood will need to support the wall and the changes in access that would be needed to build a wall. Several homes that have direct access to 76'h Street would need to relocate their driveways to the north- . south avenues. • Responses to Comments Letters on FEIS December ll, 2000 Page A-12 • • TahlP A_2- Predicted Noise Levels for Option A (AM Peak) Predicted Lto and Lso Noise Level (dBA) Receptor No Build 2003 (with existing geometry) Year 2003 Build Option A: 7,500 Year 2022 Build Option A: 7,500. Lto Lso Lto Lso Lto Lso N-1 67 60 69 63 70 64 N-2 69 62 71 65 - 70 63 N-3 59 52 60 52 59 51 N-4 64 60 65 61 67 64 N-5 67 61 68 61 N/A N/A Daytime. Lto State Standardt 65 60 65 60 65 60 ' Uayt~me Lso antl Lsp State ~tanaara are snown ror reicrcncc vary. u~c aucc.a aua~y~cu o,.. exempt from the State Standards. `Noise barriers are in place between Lyndale Avenue and the closest residence. ~ Temporary increase in traffic generated noise due to construction of the Penn Avenue Bridge.. Table A-3: Predicted Noise Levels for Option A (PM Peak) Predicted Lto and Lso Noise Level (dBA): Receptor No Build 2003 (with existing: geometry) Year 2003 Build Option A: 7,500 Year 2022 Build .Option A; 7,500 Lto Lso Lto Lso Lto Lso N-1 68 62 69 63 70 64 N-2 68 62 71 65 71 65 N-3 58 52 60 53 59 51 N-4 65 61 65 62 68 65 N-5 68 62 68 62 N/A N/A Daytime Lto State Standardt 65 60 65 60 65 60 • ' Daytime Lso and Lso State Standard are snown for reterence only: the sQeets anaryzea are exempt from the State Standards. ' Noise barriers are in place between Lyndale Avenue and the. closest residence. s Temporary increase in traffic generated noise due to construction of the Penn Avenue Bridge. Responses to Comments Letters on FEIS December 11, 2000 Page A-13 [] T~~~o e~• PrPdirtPd NniSe i.evelS for Option B (AM Peak) Predicted Lto and L5o Noise Level (dBA) Receptor No Build 2003 (with existing .geometry) Year 2003 Build Option B: 9,500 Year 2022 Build Option B: 9,500 Lto L5o Lto Lso Lto Lso N-1 6? 60 70 64 70 64 N-2 69 62 70 64 ,..~fl - .- - 64 . N-3 59 52 59 52 59 SI N-4 64 60 65 61 65 61 N-5 67 61 68 - 61 N/A N/A Daytime Lto State Standard' 65 60 65 60 65 60 ' Daytime Lio and L50 state stanaara are snown ror rciacncc v„~y. ~~~c ~.~~~•~ a~~~.~~.,., ~~ exempt from the State Standards. Noise barriers are in place between Lyndale Avenue and the closest residence. ' Temporary increase in traffic generated noise due to construction of the Penn Avenue Bridge. • TahlP A_5. Predicted Noise Levels for Option B (PM Peak) Predicted Lto and L5o Noise. Level (dBA) Receptor No Build 2003 (with existing geometry) Year 2003 Build Option B: 9,500 Year 2022 Build Option B: 9,500 Lto Lso Lto L5o Lto I-so N-1 68 62 70 64 70 64 N-2 68 62 71 65 71 65 N-3 58 52 60 53 59 51 N-4 65 61 65 62 66 62 N-5 68 62 68 62 N/A N/A Daytime Lto State Standard' 65 60 65 60 65 60 L` ' Daytime Lio and Lso State Standard are shown for reverence only: me sweets anaryzeu arc exempt from the State Standards. ` Noise barriers are in place between Lyndale Avenue and the closest residence. `Temporary increase in traffic generated noise due to construction of the Penn Avenue Bridge. Responses to Comments Letters on FEIS December I1, ZUUU Page A-14 • r~ ~~ r~ ~J ~- ww >a w_v w w O z w t= z m b ~_ N Oi i Y . O G E d b'i O 0 C O . N ~U N 0 V] o O U N Q ~ O N L/] w 0 U '~ Q a ~ ~ z ~ ~ ~ m Comment Dll: There is not an adequate analysis of the noise in the FEIS which will • emanate from the Best Buy Campus or an adequate analysis of the impacts of noise from vehicles traveling to and from the Best Buy Campus. Response Dl l: The impact of noise from Site-related traffic was addressed in Section 8.0 of the DEIS and additional analysis provided in the previous response (010). Site-generated noise was brieflyaddressed in response to comment I2 of the FEIS. Based on current site plans, the following information is added to that analysis. Four outdoor cooling towers will be located next to the'southeast :edge of the parking ramp. These towers. will operate in conjunction with chillers located in the basement of one or more of the four buildings. The outdoor cooling towers will include a fan. A 12-foot concrete wall will be built between the cooling towers and Knox Avenue as a preventive noise mitigation measure. The concrete wall will serve as a buffer for the residences east of Knox Avenue. The cooling towers are located in an area insulated by the five story-parking ramps to further suppress any noise emitted. The closest resident is 150 feet from the cooler location. At this distance, the sound pressure level from the cooling towers would be 62 to 64 dB without the concrete walls. These walls will reduce these levels well below the state standards and the below the traffic- related noise. No other outdoor noise generating uses are planned for the Best Buy Site. Therefore, no impact will result to sensitive noise receptors due the . Site-generated noise. Comment 012: The carbon monoxide anahsis in the FEIS does not include a suj~cient number of receptor sites which are affected.bi•-the project and the analysis to date was based on a faulty and incomplete traffic analysis. Response 012: The methodology for identifying potential local air quality impacts follows the EPA-recommended procedure for CO microscale impact analysis. The general evaluation procedure, outlined in the Guideline for Modeling. Carbon Monoxide from Roadway Intersections (EPA, 1992), includes a multiple-intersection screening process, followed by microscale CO analysis with the EPA CAL3QHC line-source dispersion model. Based on common practice for air quality analysis, a sufficient number of receptor .sites were analyzed to provide an accurate CO forecast for this Project. As the levels in the FEIS indicate,.the worst case scenario CO levels are well below state standards. Because the selected intersections represent the worst locations in the study area in terms of traffic volume and vehicular delay, it is reasonable to conclude that other locations in the study area would not experience violations of the ambient CO standards under either of the proposed options. • Responses to Comments Letters on FEIS December 11, 2000 Page A-17 Comment D13: The FEIS does not adequately address the impact of the project on the • public roadways for the years between 2003 and 2022 and does not adequateh~ address the impact of the project if certain assumed improvements to the public roadways set forth in the DEIS and FEIS are not completed by the times assumed in the FEIS. Response D13: This comment is exactly the same as the commenter made in his letter with respect to the DEIS. No acknowledgement is made of the response provided in the FEIS in Section 17, Response I7. The EIS has_presented a detailed traffic analysis in Section 5.0 and Appendix B of the DEIS, Sections 5.0 and 12.5 of the FEIS and in this Record Of Decision. In this comment and his previous comment, the commenter does not identify any specific deficiency in the analysis. With respect to assumed the Project Roadway Improvements not being completed by the times assumed in the EIS, there is no impact because the Best Buy Campus cannot be occupied until the Project Roadway Improvements, are completed. Comment D14: The FEIS does not adequately consider the impacts of the proposed project in conjunction with other projects or potential projects which are planned, approved or under construction impacting the same relevant area of study. • Response D14: This comment is virtually identical to the comment made in the commentor's letter with respect to the DEIS. No acknowledgement is made of the response provided in the FEIS in Section 17 Response I8. The DEIS and the FEIS do consider the Project's impacts in conjunction with other existing, approved or under construction projects impacting the same relevant area of study. Inboth his previous comment and this comment, the commenter does not identify any relevant project which the DEIS or the FEIS ignored. E. Felhaber Larson Fenton & .Vogt on behalf of Highland Management Group, Inc., owners of the Fountainhead Apartments The commenters intend to incorporate the previous objections as stated in the FEIS (Comments and Responses J 1 through J 14). However, no specific deficiencies are cited which would direct the focus of additional analysis. Therefore the previous responses will be applied. Comment El: ACCESS: The FEIS does not address the material impacts. that - elimination of Fountainhead 's northerly access to Knox Avenue will have on the propern~. Responses to Comments Letters on FEIS December Il, 2000 Page A-18 ~_-, The Table states that this location is expected to have a LOS F. The correct level of service for this location should be LOS E. Therefore, with the expected 7,500 employee development for Best Buy, the level of service between Xerxes and Penn decreases from a LOS E (the No-Build condition) to a LOS F. ~q. b) The Benshoof & Associates comments regarding congestion on the I-35W and _ I-494 mainlines, state that two other locations have hourly volumes of 2,300 vehicles per lane for the No-Build condition. The locations are: • I-35W between 76~' Street and 66"' Street during the AM peak hour; and • I-494 between Xerxes Avenue and Penn Avenue during the PM peak hour. - The threshold for a LOS F on a freeway with these types of lane uses is 2,300 vehicles per lane per hour. Therefore, any volume greater than or equal to 2,300 vehicles per lane per hour is LOS F. Because these locations have -- volumes equal to 2,300 vehicles per laneper hour, the level of service at these locations is LOS F. Based on the traffic volumes, geometry and levels of service identified in the table, it is clear that the regional transportation system (I-494 and I-35W) is can ently operating at or near. capacity (LOS E and F) without the Project (No- build). The segment between Xerxes and Penn is already approaching a '. failing condition (LOS E), and the other two segments are failing (LOS F). The Project-generated traffic is only a small contributor to that condition on a regional basis. The mitigation for this level of service impact is programmed by MnDOT to occur within eight years after the Project is constructed. The MnDOT planned improvements include additional lanes on the mainline of I-494, collector/distributors roads, and improved interchanges. With the reconstruction. of I-494 in approximately 2010, the level of service at all three locations described above are expected to improve to a LOS D for both No- Build and the 7,500 employee development. MnDOT is currently in the process of completing the final EIS for the planned I-494 improvement project. Given the current traffic volumes on I-494, with many segments at or near capacity, MnDOT is encouraged to--move this scheduled improvement up as much as possible. The Project's contribution to this planned improvement is to provide the Penn Avenue Bridge and interchange portion of MnDOT's project eight years ahead of schedule. The Project also results in the reconstruction of 76`~ Street, between I-35W and Penn Avenue, which is an identified reliever for I-494. MnDOT has reviewed both the DEIS and FEIS for the Best Buy. Project to examine. the possible impacts of the Project on the xegional transportation Responses to Comments Letters on FEIS December ll, 2000 Page A-25 system. MnDOT stated that Option B with 9,500 employees may be too large • for the supporting roadway network and should not be pursued. MnDOT has expressed no specific traffic-related concerns regarding Option A with 7,500 employees, other than encouraging implementation of a TDM Plan. The Project is consistent with the Metropolitan Council's regional growth policy objective of increasing the density of development within developed areas. Increased development density encourages increased transit use. It is not the intent of their regional growth policy to limit redevelopment projects due to regional transportation deficiencies. Comment G2: Best Buy Project would cause a significant negative traffic impact by creating increased congestion and accidents on 1-494 between Penn Avenue and I-3SW due to greater weaving conflicts. a) The second paragraph under Section 5.3.2,A of the FEIS indicates that the MnDOT weaving study addressed the weave conditions at Penn Avenue and I- 3SW (1--494) with a single point diamond interchange. This statement is false. The referenced MnDOT study addressed other weaving circumstances. b) Page 5-29 in the FEIS references the MnDOT Weaving Study and includes the following statement: "The study concluded the reconstructed Penn Avenue Bridge improved weaving conditions and operations on eastbound 1-494. west of Penn Avenue. " This statement is untrue because the referenced study did • not address in any matter the subjects of weaving conditions and traffic operations on eastbound I-494 west of Penn Avenue. c) Page 5-31 in the FEIS includes the following statement, "The MnDOT Weaving Study also simulated the AM and PMpeak hour No-Build and Build conditions for the Penn Avenue Interchange area, which were simulated using SYNCHRO and TrafNetsim software. " This is a false statement because the referenced MnDOT Weaving Study did not address any such simulation analysis. d) The American Association of State Highway and Transportation Officials (AASHTO) state that the recommended minimum spacing between entrance and exit ramps such as Penn Avenue and I-3SW is 1,575 feet. The existing spacing of 1,280 feet is already 295 feet (19 percent) shorter than the recommended minimum. Contrary to the erroneous statements presented in Section 5.3.2.A of the FEIS, it is obvious that the shortening of the weaving distance to 1,050 feet under the build condition would exacerbate the already deficient condition. The FEIS includes a contradictory statement on page 17-9 in response to comment D8 which referenced weave distance as a reason for rejecting the HOY lane on the eastbound ramp to I-494. Response G2: a-c) The first two comments made above all make reference to the MnDOT Weaving Study and that it did not specifically address the conditions at the I-494 and Penn Avenue Interchange.. The FEIS misstated the reference to • this. study. The intended reference was that the MnDOT Weaving Study Responses to Comments Letters on FEIS December 11, 2000 Page A-26 .:".~ ~j `' results were representative of conditions that would occur at I-494 and Penn Avenue. 'The MnDOT Weaving Study entitled "Estimation of Capacity in t-. ;:: Freeway Weaving Areas for Traffic Management and Operations" examined ~=` other weaving areas at similar interchanges. The Weaving Study did not _ specifically include the I-494 and Penn Avenue Interchange. However, the weaving analysis results in the study can be applied to other ramp entrance ~~- and exit merge/diverge areas, including the I-494 and. Penn Avenue Interchange area for both the existing conditions and the proposed single- point diamond interchange. Additionally, a specific simulation model was run for the~1'-ear 2022 for the Penn Avenue Interchange to test the general conclusions of the Weaving Study on this interchange. The findings of the simulation analysis were consistent with the expectations based on the Weaving Study. Section 5.3 (page 5-29) of the FEIS is the section within the FEIS that misstates the findings from the MnDOT Weaving Study. The original discussion and accurate reference to this study was represented in the clarification letter submitted to MnDOT by the City on October 6, 2000. -The attachment to this letter, as documented in Appendix H of the FEIS, accurately describes the study and how it can be applied to the Penn Avenue/I-494 Interchange. MnDOT reviewed this letter and attachment and agreed through their follow-up correspondence on October 17,.2000 that _ • there were no concerns regarding the proposed weaving distances. Therefore, even though the study was misstated in the FEI5, the conclusions drawn in the FEIS based on the study results and reviewed by MnDOT are valid and relevant. d) Mr. Benshoof correctly states the AASHTO recommended minimum spacing between entrance and exit ramps is 1,575 feet. The current ramp spacing between the Penn Avenue entrance ramp and the I-35W exit ramp is 1,280 feet. Therefore, the current ramp spacing condition of 1,280 feet is less that the AASHTO recommended minimum spacing. However, Mr. Benshoof fails to mention that the MnDOT recommended minimum spacing between entrance and exit ramps is 1,000 feet (MnDOT Road Design Manual, Chapter 6), which is the standard used in Minnesota. Therefore, under both the existing interchange condition/No-Build alternative (1,280 foot spacing) and the proposed single-point diamond. interchange/build alternative (1,050 spacing), the spacing between the entrance and exits ramps of Penn Avenue and I-35W is greater than the MnDOT recommended minimum spacing of 1,000 feet. In reference to Mr. Benshoof s claim that contradicting statements were made in the FEIS regarding weaving distance, the following clarification is provided. Response to comment D8 of the FEIS (page 17-9) stated that Responses to Comments Letters on FEIS December 11, 2000 - Page A-27 • construction of an HOV bypass. lane for the eastbound ramp was rejected due to inadequate weaving distance. This is an accurate statement as the addition of an HOV lane for the 2002 construction would result m a weave condition of less than 1,000 feet (the MnDOT minimum standard).. Without the HOV lane, as proposed, the weave distance is 1,050 feet, which complies with the MnDOT standard. Therefore, the statements presented in the FEIS are not contradictory. Based on the findings in the MnDOT weaving study, as described in the Cityletter to MnDOT (FEIS Appendix H, attachment A), a reduction in the weaving distance between entrance and exit ramps is not a significant factor for creating congestion on the freeway mainline. Traffic speed and ramp geometry were more relevant issues. Based on the principle .findings of the study, it would be expected that the design changes proposed for the Penn Avenue Interchange (increased ramp lengths) will`allow for increased ramp speed, which. will result in less congestion than the current condition even with the reduction in weaving distance. MnDOT reviewed the City's letter and its evaluation of the MnDOT Weaving Study and agreed through their follow-up correspondence on October 17, 2000, that there were no concerns regazding the proposed weaving distances. • Comment G3: Best Buy Project would cause a significant negative traffic impact by creating substantial congestion on Penn Avenue and 76'" street because the p.m. peak hour volumes projected to use entrance ramps from these roadways to 1-494 and I-35W _ greatly exceed their capacity. Response G3: The purpose of this response is to clarify the effects of ramp _. metering, describe MnDOT's ramp metering practices, and respond to issues that were raised in the FEIS. In the comments to the FEIS, Benshoof & Associates determined avera~e metering rates for the Penn Avenue entrance ramps to I-494 and the 76 Street entrance to northbound I-35W through field observations on a single day. Based ___ on this average metering rate, capacities of the entrance ramps listed above were _ determined: MnDOT's standard practices and procedures, however use six different metering rates (R1 through R6), instead,of a single average rate, at each -- entrance ramp to allow vehicles onto the freeway system in a manageable fashion. The R1 rate is the fastest metering rate and the R6 rate is the slowest metering rate `' at a specific entrance ramp. The R1 rate is typically-in operation when the traffic - volumes on both the freeway main line and specific ramp aze low. The R6 rate is typically in operation when there is extreme congestion on the freeway mainline. '.;1 _.~ • Resporues to Comments Letters on FEIS December 11, 2000 Page A-28 ,, Table A-6 shows typical approximate metering rates for several locations in the • Twin Cities Metro area, and it also shows the approximate metering rates for the Penn Avenue entrance ramps to I-494 and for the 76`~ Street entrance ramp to I-35W. As can be seen from the table, the metering rates are different for each ramp entrance location. MnDOT's practice is to calculate the metering rates such that they are able to accommodate the volume of traffic entering onto the freeway without causing significant congestion on the local streets. Tahle A-6. MnDOT Ramo Meter Timings • • Existing Volumes - Approximate Metering Rates -Red Times Only Location Number of Vehicles (v h) c2> Rl ~ R2 R3 t R4 R5 t' R6t Penn Ave to I-494 EB (PM) 1099 0.2 0.5 1.0 1.6 2.7 4.6 Penn Ave to I-494 WB (PM) 304 5.9 7.1 8.8 11.2 14.9 21.7 76th Street to I-35W NB (PM) c4r 294.. 6.2 7.4 9.1 11.6 15.5. 22.5 Broadway Ave to I-94 EB (PM) 1028 0.3 0.7 1.2 1.9 3.0 5.0 Hennpin Ave to I-94 EB (PM) 1184 0.1 0.3 0.8 1.4 2.3 4.1 I-94 EB to I-35W SB (AM) I A84 0.1 0.1 0.1 0.1 0.2 0.5 12th St to I-94 WB (PM) 1071. 0.2 0.6 1.1 1.7 2.8 4.7 I-35W NB to I-94 WB (AM) 1514 0.1 0.1 0.3 0.5 0.8 1.2 10th Srto I-35E NB (PM) 1004. 0.4 0.8 1.3 2.0 3.1 5.2 TH 100 SB to I-394 WB C-D (PM) 1215 0.4 0.6 0.7 1.3 2.2 3.9 RI =Rate 1, R2 =Rate 2. etc, Best Buv Project - 7,500 Employee De~•elopment (Year 2003) Approximate Expected Metering Rates -Red Times Onl tt> Location Number of Vehicles (~'Ph) PT<t Peak R1 ~'t R2 t' R3 t R4 R5 R6 Penn Ave to I-494 EB 1600 0. I O.I 0.1 0.5 1.2 2.5 Penn Ave to 1-4.94 WB 939 0.6 0.9 1.5 2.3 3.5 5.7 76th St to I-35W NB 591 2.1 2.7 3.5 4.8 6.7 10.2 RI =Rate 1, R2 =Rate 2, etc. (I) Add 2.0 seconds for Yellow ana vrecn pnases. (2) Number of vehicles was taken from the MnDOT "All Detector Report," April 13,.2000, (3) Timings were calculated based on the MnDOT Traffic Management Center's current timing practices as of Nov 17, 2000.. (4) Number of vehicles was taken from the M11nDOT "All Detector Report," April 14, 1999 because ramp was under construction in Year 2000. The metering rate used at any specific time and at a particular location is determined by mathematical equation that uses real-time volume information from the freeway mainline and all entrance and exit ramps. This volume information is updated every 30 seconds, which in turn updates the metering rates Responses to Comments Letters on FEIS December II, ZUUU Page A-29 at each specific entrance ramp. Because there are six different metering rates at each ramp entrance and the metering rate in operation may change every 30 seconds, an average metering rate cannot be used to adequately determine the capacity of the entrance ramp. The metering rates determined at a particular ramp are calculated based on the volume of vehicles entering onto the freeway during the peak hour (AM and PM). Because of this, these metering rates are different for each entrance ramp, unless the volumes on the ramps are the same. For example, the metering rates at the Penn:Avenue entrance ramp to. I-494 eastbound would be_different than the - , metering rates at the France Avenue entrance ramp to I-494 eastbound because the volumes on the ramps are different. Because the metering rates are calculated based on the peak hour volume of vehicles using the entrance ramp, large increases or decreases in .the volume of vehicles using the ramp would require the metering rates to be updated periodically. MnDOT updates/adjusts the metering rates for the entire system every six months. Where large scale development occurs in an area that may affect an existing ramp meter by creating substantial traffic volume increases, MnDOT provides. immediate reevaluation of that ramp meter and adjusts the metering rates, as appropriate. Metering rates would also be reevaluated after the reconstruction of an interchange, as would be the case with the. Penn Avenue / I-494 Interchange reconstruction. Therefore, after completion of the Project • Roadway Improvements on Penn Avenue and 76a' Street and completion of the Best Buy Project, the ramp metering on the Penn Avenue entrance ramps to I-494 and the 76`h Street entrance ramps to northbound I-35W would be reevaluated. As stated in Section 12.5 of the FEIS, MnDOT's fastest metering rate is 2.1 seconds per vehicle. If this were the only rate used during the entire hour, a maximum of 1,714 vehicles would be able to travel through the meter and onto the freeway .system. Because MnDOT uses six different metering rates, the lowest rate could be at a minimum of 2.1 seconds per vehicle. The other five metering rates could be equal to or greater than the 2.1 seconds per vehicle minimum based on the volume of vehicles entering onto the freeway. As stated in Section 12.5 of the FEIS, for all development scenarios and time periods included in the analysis, the expected volumes entering onto the regional roadway system (I-494 and I-35W) are less than the maximum threshold of 1,714 vehicles. This reference was made not to imply that a 2.1 second per vehicle metering rate would be used at these entrance ramp locations but to show that. the ramp meters have the capacity to accommodate the increase in traffic volumes from the Project. if MnDOT adjusts the ramp meter rates based on the new traffic volumes from the Best Buy development and there are complaints of the ramp meters creating queues that back up onto local streets, MnDOT's practice is to perform a field . review of the location, verify the problem, and take the appropriate steps to Responses to Comments Letters on FEIS Decernber II, 1000 Page A-30 mitigate the problem. If significant queuing lengths that impact the local street are noticed using the Closed-Captioned Television (CCTV) cameras, MnDOT also has the capability to immediately manually override any ramp meter that is connected to the system. Also, construction of the I-494 / I-35W Interchange area is expected to begin in approximately Year 201 I. When this reconstruction is complete, vehicles will not be able to enter I-494 from Penn Avenue and then travel south onto I-35W. Because of this,. the volume of vehicles on this entrance ramp to eastbound I-494 from Penn Avenue is expected.to_decrease. With this decrease in raffic volumes, MnDOT would be expected to reevaluate the meter rates_at_this.:Iocation again and adjust them accordingly. Comment G4: Best Buy Project would cause a significant through traffic use and associated negative impacts on local residential streets because motorists would seek alternative routes to avoid congestion on the 1.494 and 1--35W entrance ramps Response G4: See Response G3. Based on MnDOT's practice of adjusting the metering rates to accommodate the anticipated volume of traffic entering onto the freeway, and added ramp capacity with the interchange reconstruction, motorists would not be expected to experience unusual congestion on the entrance ramps and would therefore not need to seek alternative routes on the local streets to • avoid this congestion. Additionally, there are a number of arterials that are designated as relievers for I-494 and I-35W .traffic. Some of these routes are located within residential areas. The north/south .arterials closest to the Project include: York Avenue, Penn Avenue, Lyndale Avenue, and Nicollet Avenue. These roadways are generally four-lane undivided roadways with few protected turn lanes, except for York which does have protected turn lanes. Table A-7 below shows the Average Daily Traffic (ADT)volumcs and the design capacities of these roadways. In the DEIS, 15% of the employees entering/exiting the-Best Buy Campus are expected to use I-35W northof 76`'' Street to travel to/from the Site. As a worst. case example, if this percentage were redistributed evenly to the four arterial roadways listed above, each roadway would experience an approximate 4% increase in daily traffic volumes from theProject. The table also shows the ADT volumes. on these roadways with the 4% addition of the Best Buy traffic. Responses to Comments Letters on FEIS December I1, ZUUU Page A-31 Tahle A-7: Avera>?e Daily. Traffic (ADT) Volumes and Design Capacities ^~ ~ r Example Worst-case 1998 ADT Capacity of ADT After Best Buy Arterial (v d ' Roadwa ( d Cam us v d)2 York Avenue 19,000 34,000 20,160 Penn Avenue 17,000 23,000 18,305 Lyndale Avenue 13,500 23,000 14,080 Nicollet Avenue 11,900 23,000 12,480 1 Volumes taken from the MnDOT TraY3ic Flow Maps (vemcies per aay~ 2 Four percent was added in addition to the percentages previously assigned to Penn, York, Lyndale, and Nicollet Assuming the Project traffic was added to these arterials as shown above it is far less than the available capacity of the roadways and is not expected to significantly impact them. Traffic on 76`h Street just west. of Lyndale Avenue has dropped from 12,000 ADT to 5,700 ADT since 77th Street was built as a minor arterial: Only a limited amount of traffic uses 76''' Street to gain access to or from Lyndale or Portland Avenue given the improvements made on 77'h Street. This is a prime example of how minor arterials with adequate capacity minimize the use of residential. streets. Similar benefits are expected to occur with the road improvements on Penn Avenue and 76th Street. • Comment GS: MnDOT has not altered its September 27 statement that the scenario with 9,500 employees would cause five problems regarding access off Penn Avenue. Response G5: Comment noted. The City`s preferred alternative is the 7,500 employee option as described in the Findings Section of this document (Section 4.25). Comment G6: In response to a MnDOT comment that a single point at Penn Avenue will be stressed to its limits and will affect the operation of I-494 and I-3SW, page 17-3 in the FEIS presents the following comment: "Based on a MnDOT study of other weaving areas, and simulation of the existing and proposed conditions, the proposed Penn Avenue improvements are expected to improve operations on 1-494 during peak hour conditions. " As noted in points Gl (a) and GI (b) above, the preceding statement is incorrect and seriously misleading. Response G6: See Responses G 1 and G2. Based on the results of the MnDOT Weaving Study (which did not specifically study the Penn Avenue Interchange), and a simulation study of Year 2022 conditions specifically conducted for the Penn Avenue Interchange Modification Request, the proposed Penn Avenue improvements are expected to improve operations on I-494 during peak hour conditions. Based on these studies, this is not a false or misleading statement. Responses to Comments Letters on FEIS December Il, 2000 Page A-32 '_~ Comment G7: Response to Comment E-2 in the FEIS is incorrect (regarding increased congestion on I: 494 when the freeway is reconstructed) because the traffic capacity on I-4941ikely will be reduced during construction due to factors that will include: a) reduction in lane width b) loss of shoulders c) lane shifts. .Response G7: The FEIS. resp-onse for E2.did_not state that there would.not_be increased congestion. What it did say was that. there. would not be substantial construction- constraints imposed on I-494, especially during peak traffic periods. With any major freeway reconstruction project there is bound. to be increased congestion. However, this congestion would be temporary. and intermittent depending on the construction locations .and progress. The reconstruction of I-494 is not part of this Project or this EIS. The impacts of the I-494 construction project should have been addressed in the 1994 Draft I-494 Environmental Impact Statement, and would be updated in the Final I-494 Environmental Impact Statement being prepared by MnDOT, which is to be published in January 2001. Mitigation for temporary construction impacts for unrelated and unconnected construction projects is not the subject of this. EIS. Comment G8: Regarding the response to FEIS Comment ES: Traffic queuing and congestion will occur at the Penn Avenue/I-4941nterchange because the capacities of the. entratrce ramps are less. than the volumes projected to use the ramps. Response G8: See Response G3 and G4. Again, because MnDOT's practice is to adjust the metering rates to accommodate the anticipated traffic volumes entering onto the freeway after significant roadway improvements-are completed or when .traffic volumes increase, significant queuing is not expected to occur at the Penn Avenue / I-494 Interchange under normal circumstances. Comment G9: Regarding the response to our comment presented in HI of the FEIS: a) The SimTraffic results indicate that the intersection would operate at level of service C. In comparison to normal level of service calculation methodologies, SimTraffic,has underestimated the delay and level of service at this intersection. b) The increase in level of service at the intersection. of 77`h Street and Lyndale Avenue, presented in the FEIS is an illogical outcome when the total volume entering the intersection increases. This situation provides further merit to the argument that the SimTraffic simulation used in the FEIS yields level of service results that are not as valid as results produced through the standard methodologies presented in Syncho or the Highway. Capacity Software. Responses to Comments Letters on FEIS December II 2000 Page A-33 Response G9: a) In an effort to help clarify. for Mr. Benshoof the difference between the two traffic software models (SYNCHRO and SimTraffic), the following is a response from John Albeck, the software designer for both the SYNCHRO and SimTraffic programs: SYNCHRO "Synchro and SimTraffic ARE different models and will give different results. Synchro is a macroscopic traffic software program [examines the intersections and network as a whole..and_cal.culates.the. impacts to the system based on _. empirical equations] that replicates-the signalized intersection-capacityanalysis as specified in the 1997 Highway Capacity Manual (HCM). Macroscopic level models represent traffic in terms of aggregate measures for each movement at the intersections. Equations are used to determine measures of effectiveness such as delay and queue. length.. These models do not account for "bottleneck" situations where upstream traffic deficiencies reduce the amount of traffic reaching downstream intersections. This would be a situation where Synchro may show a delay that is worse than SimTraffic since all of the volume is not reaching the. intersection in SimTraffic." SimTraffic "When it comes to SimTraffic, this is a microscopic simulation model [examines the impacts to each individual vehicle within the model]. SimTraffic has the capability to simulate a wide variety of traffic controls, including a network with traffic signals operating on different cycle lengths or operating under fully-actuated conditions. Most other traffic analysis software packages do not allow for a direct evaluation of traffic conditions operating under varying cycle lengths and traffic control [as exist in the study area]. Each vehicle in the traffic system is individually tracked through the model and comprehensive operational measures of effectiveness are collected on every vehicle during each 0.1-second of the simulation. Driver behavior characteristics ranging from passive to aggressive are assigned to each vehicle by the model, effecting the vehicle's free-flow speed, queue discharge headways, and other behavioral attributes. The variation of each vehicle's behavior is simulated in a manner reflecting real-world operations. Since SimTraffic is a microscopic model, the full impact of queuing and blocking would be measured by the model. This is a situation where SimTraffic could show more delay when compared to Synchro." ~. For the Best Buy Campus analysis both traffic software models were used. The SYNCHRO software was used as a database manager where the lane geometries, volume information, and signal timings were stored for each development scenario. These inputs were then transferred to the SimTraffic model; which was used to fine-tune the signal timings and. geometries and then Responses to Comments Letters on FEIS December I1, 2000 - - Page A-34 • C7 calculate the level of service and queue length impacts to the surrounding roadway network. The SimTraffic model was used to determine the impacts of traffic on the surrounding roadway network because this model examined the impacts of traffic in the system on a vehicle by vehicle basis. As stated above in John Albeck's response, some intersections may have worse level of service results and some intersections may have better level of service results using the SimTraffic model compared the SYNCHRO model.. Also, contrary to Mr. Benshoof s statement that the results from SimTraffic are not compatible with HCS or SYNCRO results, the level of service and queue length results ..produced from SimTraffic.are compatible with each of these programs_and are accepted in the traffic engineering field as reliable and accurate. The analysis that was performed by Benshoof & Associates at the 76th. Street and I-35W Northbound Entrance Ramp and at the 77th Street and Lyndale Avenue intersections using the SYNCHRO software included only those intersections. Because these intersections are part of a larger interconnected signal system, the operations at one intersection influence the operations at an adjacent intersection. If the signal system is optimized, vehicles traveling on the coordinated roadway generally arrive at the intersection when the light is green. Because of this, these vehicles incur little delay thus improving the intersection level of service. If the signal is looked at individually and not in a coordinated system, vehicles travelling on the main roadway arrive at the signal at random times. This may add extra delay to each vehicle because they may arrive at the. intersection when the signal isxed thus decreasing the level of service of the intersection. . A comparison of the AM and .PM peak hour time periods with the 7,500 .employee option for the Year ?003 was conducted to examine the differences in the intersection level of service results produced by SYNCHRO and. SimTraffic: The comparison showed that for a total of 36 intersections (18 for the AM peak hour and 18 for the PM peak hour) the following occurred: • Nine intersections had worse intersection levels of service using SimTraffic vs. SYNCHRO; • Five intersections had better intersection levels of service using. SimTraffic vs. SYNCHRO; and • Twenty-two intersections reported the same levels of service using .SimTraffic vs. SYNCHRO. • As can be seen from this information, SimTraffic showed that there was a difference of four intersections that had worse level of service conditions than intersections that had better level of service conditions. For the majority of the intersections, SimTraffic-and SYNCHRO produced the same level of service results.. As stated above, SimTraffic was used to determine the impacts the surrounding roadway network because this model examined the impacts of Responses to Comments Letters on FEIS December 11, 2000 Page A-35 • traffic in the system on a vehicle by vehicle basis and has the greater capability to model "real-world" conditions. b) The FEIS has a statement in it that reads "The improvement occurred because the volume collected by Benshoof was 100 vehicles less than the predicted average used in the DEIS" for the 77a' Street / Lyndale Avenue intersection. The statement should read, "The improvement occurred because the volume collected. by Benshoof was 100 vehicles less for the northbound to westbound movement than the predicted average used in the DEIS." The .total .volume of vehicles_entering the intersection for all movements during the PM peak hour under the Year 2003 scenario with-7;500 employees would be 124 vehicles higher using the Benshoof data than as presented in the DEIS. Mr. Benshoof is making the. reference that an increase in volumes automatically means a decrease in the level of service of the intersection. This statement is untrue. Because there are fewer vehicles making the northbound to westbound movement using Benshoof's data, the traffic signal can be optimized to remove allotted'"green" time for this left turn movement and to reallocate that "green" time to the eastbound and westbound through movements. By optimizing the signal timing and giving more "green" time to the higher volume movements, the level of service for the intersection is expected to improve from LOS D to a LOS C using the volumes taken from the Benshoof & Associates analysis. Comment GIO: We strongly disagree with the response to FEIS Comment H7 and would state that motorists would have a major incentive to use local streets to avoid the substantial congestion that would occur on Penn Avenue and 76~h Street because the .capacity of the entrance ramps to I-494 and I-35W would be considerably below the projected volumes. Response G10: See Response to Comments G3 and G4. Comment GII: -Aside from the no-build option, the FEIS has not addressed any development alternative that would not cause the above referenced negative traffic impacts. Response G11: All alternatives identified in the Scoping Decision document were analyzed. The MEQB Rules do not require inclusion. of an alternative which has no traffic impacts. Rather the Rules require the development of mitigation measures in response to identified impacts. Responses to Comments Letters on FEIS December 11, 2000 Page A-36 C7 STAFF REPORT 2 108 AGENDA ITEM # REPORT # CITY COUNCIL MEETING MAY 21, 2001 • REPORT PREPARED BY: -BETSY .CHRISTENSEN, ,ADMINISTRATIVE SUPPORT SERVICES MANAGER NAME, TITLE REPORT PRESENTER: DAN SCOTT, DIRECTOR OF PUBLIC SAFETY NAME, TITLE DEPARTMENT DIRECTOR REVIEW: ~ ~~ SIGNATURE REVIEWED BY CITY MANAGER: ITEM FOR COUNCIL CONSIDERATION: Consideration of the request for the outside service of alcohol, to cover the patio service area, for Wiltshire Restaurants, LLC d/b/a Houlihan's Resturant & Bar, 6601 L ndale Avenue South. I. RECOMMENDED ACTION: By Motion: Approve the outside service of alcohol, to cover the patio service area, for Wiltshire Restaurants, LLC d/b/a Houlihan's Restaurant & Bar, 6601. Lyndale Avenue South. II. BACKGROUND On March 28, 2001, Houlihan's Restaurant & Bar submitted a request to open the outside patio area of their establishment. They will be serving both alcoholic and non-alcoholic beverages from their regular menu. Houlihan's has submitted a drawing specifically showing the proposed location, including the square footage and the specific number of tables and chairs for the patio service area. This drawing has been reviewed and approved by the. necessary departments. In addition, the applicant has complied with all of the procedures/criteria required for outside service of alcohol. A copy of the procedures/criteria list is attached. 0521 Patio Houlihan's currently has the necessary on-sale intoxicating and Sunday liquor . licenses for their establishment. However, these licenses are only valid for the serving of alcohol within the establishment and do not cover exterior serving. The applicant has supplied proof of liquor liability insurance to cover the exterior of the premises showing Legion Insurance Company as affording the coverage. The barrier, to restrict access to the patio area by underage youth and other persons walking by, is completed and in place. III. BASIS OF RECOMMENDATION A. POLICY • Houlihan's Restaurant& Bar has complied with all of the required criteria for outside service of alcohol. B. CRITICAL ISSUES • None C. FINANCIAL • None D. LEGAL • This action merely extends service to an outside area. Such service is not prohibited by ordinance or statute: IV. ALTERNATIVE RECOMMENDATION~S~ • The Council could decide to deny the request, which would result in Houlihan's Restaurant & Bar not being able to serve alcohol to patrons outside in the patio service area of their establishment: However, the Public Safety Department has not found any basis for denial. V. ATTACI-IlVIENTS • Procedures/Criteria list. • Four drawings of Houlihan's proposed patio area. VI. PRINCIPAL PARTIES EXPECTED AT MEETING • Houlihan's Restaurant & Bar staff . CITY OF RICHFIELD OUTSIDE SERVICE OF ALCOHOL PROCEDURE/CRITERIA TO: Parties Interested In Outside Seating for AlcohoUFood Service. FROM: Bruce Sylvester -Planning Rick Regnier -Inspections Betsy Christensen - Licensing/Health Barry Fritz -Police Brad Sveum -Fire SUBJECT: Procedure/Criteria for Outside Service of AlcohoUFood PROCEDURE: All requests received by the City for an expanded patio/exterior premises must be reviewed by a staff committee including, but not limited to: Planning, Building Inspection, Police, Fire and Licensing/Health staff. Requests will be evaluated for compliance with building, fire, and health code requirements and with the criteria established herein. The request should be initially submitted to the Planning Division and will be routed to the other divisions noted above for their review and comment Following a favorable review by staff, requests will be reviewed by senior staff and ultimately referred to the City Council for final approval. CRITERIA: The following criteria will be considered by staff as azeas that must be in compliance before an approval will be given: • The initial request for consideration must include a letter outlining the proposed plans for the area which include the dates it will be open as well as a drawing of the azea specifically showing. the proposed location azea. This drawing should include the specific number of tables and chairs. This request should be initially submitted to the Planning Division and will be routed to other divisions for their review and comment. Planning staff will evaluate requests on a case-by-case basis to determine if the additional outdoor seating increases the pazking needs and therefore requires an amendment to the conditional use permit. • The Minnesota State Disability Code requires that there be a clear passageway of at least 4 feet to accommodate physically challenged individuals. In situations where it is not possible to accommodate seating and still maintain this 4foot area, the plans will be denied. • The outside seating area may o~be accessed from within the establishment in those establishments where there is any service of alcohol, wine or malt liquor. • Food must be served in conjunction with the sale .of.any alcohol, wine or malt liquor. C • ~ A plan must be included to address how staff will monitor the scrvice of alcohol, --'' wme or malt liquor so that underage mdividuals are unable to access alcohol from those establishments licensed to sell alcohol, wine or malt liquor. Adequate barriers (fencing, brick walls, etc.) must be present in an outside cafe area to keep the access of alcohol from underage youth and to prevent them from illegally obtaining alcohol. • All required exits from the building must remain clear and unobstructed. • Access for emergency medical response crews including stretchers must be provided and maintained. • Fire protection may be increased, if needed, by additional fire extinguishers, etc. Combustibility of construction and furnishings must comply with Fire and Building codes. • The hours of operation must be identified. • Parking azeas may not be identified as a location for outside seating. • Applicant must possess a valid food establishment license. • A distance of at least 200 feet shall be maintained between the nearest point of the outside cafe to the neazest point of property used for residential purposes. Distance requirements maybe increased or decreased depending on the presence of mitigating factors. • The applicant must famish to the Public Safety Department, evidence that public liability insurance has been procured for any death or personal injury arising from the ownership, maintenance, or operation of the outside cafe in amounts not less that $100,000 for injury to or death of one person, of $300,000 for aay once incident, and not less than $50,000 for damagc to property arising from any one incident. The applicant shall maintain such. insurance in effect at all times during the term of the permit. The City shall be named as an additional named insured in the policy providing such insurance. • The Minnesota State Disability Code regains that there be a clear passageway of ax ,` ~~~ least 4 feet to accommodate physically challenged individuals. In situations where it is not possible to accommodate seating and still maintain this 4foot area, the plans will be denied. • The outside seating area may on be accessed from within the establishment in thoso establishments where there is any service of .alcohol, wine or malt liquor. • Foodmust be served in conjunction with the sale of--.any sicohol, wine or malt liquor. C . ~ A plan must be included to address how staffwill monitor the service of alcohol, _._/ wme or malt liquor so that underage individuals are unable to access alcohol from those establishments licensed to sell alcohol, wine or malt liquor. Adequate barriers (fencing, brick walls, etc.) must be present in as outside cafe area to keep the access of alcohol from underage youth and to prevent them from illegally obtaining alcohol • All required exits from the building must remain clear and unobstructed. • Access for emergency medical response crews including stretchers must ba provided . . and maintained. • Fire protection may be increased, if needed, by additional fire extinguishers,.etc• Combustibility of construction and fiiinishings must comply with Fire and Building ' ~' codes. • The hours of operation must be identified. • Parlang areas may not be identified as a location for outside seating. • Applicant must possess a valid food establishment license. • A distance of at least 200 feet shall be maintained between the nearest point of the outside cafe to the nearest point of property used for residential proposes. Distance requirements maybe increased or decreased depending on the presence of mitigating factors. • The applicant must famish to the Public Safety Department, evidence that public liability insli*ance has been procured for any death or personal injury arising from the ownership, maintenance, or operation of the outside cafe in amounts not less that $100,000 for injury to or death of one person, of $300,000 for any once incident, and not less than $50,000 for damage to property arising fi~om any one incident.. The applicant. shall maintain such insurance in effect at all times during the term of the permit. The City shall be named as as additional named insured in the policy providing such insurance. ,~ ,~ • The applicant must furnish to the Public Safety Department proof of liquor liability inc~ran_ce that covers the exterior of the establishment's premises and must name the City as an additional named insured in the policy providing such inci~rance. • The applicant shall indemnify and hold the City and the City's officials and employees harmless from any loss, cost, damage and expenses arising out of the use, design, operation or maintenance of the outside cafe. • The area occupied by the outside cafe shall abut and shall be operated as part of the food establishment operated by the applicant. No part of the outside cafe shall adjoin any premises other-than the applicant's food establishment. • Live music is prohibited on the exterior of the establishment. • There shall be no wait stations located outside the interior of the establishment for purposes of waiting on or serving customers. • City Staff shall find that a sidewalk cafe will not unduly restrict the safe usage of the sidewalk by the public or fire lanes after taking into consideration the location of obstructions, vehicular traffic and other impediments to the passage of pedestrians. • No expansion of the area occupied by the outside cafe from that shown on the permit application shall be made. shall be laced • No tables, chairs, furnishings, planters, railings or other obstructions p or remain on a sidewalk cafe between November 1st and April 1~` except on a day to day basis when the sidewalk cafe is open for business. • The applicant shall maintain the outside cafe in a clean and sanitary condition. ,~ • f~fi~d?'-G10~71 1~9. 7J c.~a ~ -- - - - ---- - - i~ • . ~ Y • • • •' ~' ~ --~ - o ~~ ~ - ,.. -~ ~ ~ O ~ ~ _~ ~ ~ ~ .. .~- ~ -~ ~~ - _ _ Q '~ y~ .. _ ,~> > ~o _ a I ' ~• s • ~ • i . • I . + f F I • . ~ « L ~~ ~ ~, ~~ -1 K _ ~ ~ ~ . ~ ~ ~. ~ ~ ~ `O - - - Z . -~ . n ~ ~p - _ ~ ~'' c~ .. + Z _ ~ ~~- ~~l o -. ~ ~ ,~ _ ~ N . a o ~ ~~p~ W~ _ ~ A o~ ~~ o ,;~ ~~c ~~ ~ ~ a~~ 1M-~N ,- M •~}, qY •. ~.s: X~+~^w•1t' .r.. f ,r -„b~'. `~.f •M•±: i( :~. ..t~. r , '+~ .. ~"lT'• 'iF r l ~t~A " • .. v _ y • fir,. ~, F .~ 'i w ti ~ ~ hr~~ 7~~• ~~ ~• ` Q<' . ' ' ' ~ ..1 ~"!1. ~Y,. 'N ': ;'t.. ~. •~ :~':.~ 1. . I,' '~ ~ . ~}.~. :.1 1 ~ ~ .I: ... • i ~'. ~~ ~~ ` . 1 '; , .. ~~~' ~ ~ ~• . .~ ' ::~: : ~.1 ~ .r :. s: ~ : .. ,.: ') ~ ,r , i .~ ~ ~ -~~ :~' FIR=73 '- ~ ~ - • r ~.~,~,. , :.. ,~.,Q. 2..g. .. ~, j .: „'~~ Q>: ~ ~ ~ .. ~ ~~CT • ~~ •.~ a n: w- , ~ ap cr ~ _ . . :~Q~~l; ~~ ..~ .~~ "~IC:~1 . . ~ •~au. ~ i .. . .,C..1.`~J.: . '.ti ~ ~ ~ ti r ,, ; 7 ~ J ~ c ~`aNy ~ L c ~~~ ~ N~~~~~ f L ~~~v~ri oN ~~~ ~~n«.~~• t~ 3t(¢tl -----_ ~'-O' OTC. W 1.D t GRINDJPIOOTN ,• • "'• '~""`•`~'~ o~w v a- o~c, WS.D i GRIND JOI~CTS 5t"IOOTN • • K O ~~ n ..~ • • CITY OF RICHFIELD MONDAY, MAY 21, 2001 SPECIAL CITY COUNCIL STUDY SESSION COUNCIL CHAMBERS 6700 PORTLAND AVENUE 5:30 P.M. AGENDA. Call to order Roll call 1. .Discussion of roadway improvements for 7600 block of Lyndale Avenue 2. Discussion of City's bond rating Adjournment Auxiliary aids for individuals with disabilities are available upon request. • Requests must be made at least 96 hours in advance to the Administrative Services Director at 612-861-9702.