12-7-92 agendaCITY OF RICHFIELD
MONDAY, DECEMBER. 7, 1992
**~t***~t**~~**********~********~t********~t*******************~t****
SPECIAL CITY COUNCIL MEETING
6:45 P.M.
COUNCIL CHAMBERS
AGENDA
CALL TO ORDER
1. CONSIDERATION OF APPROVAL OF PETITION TO BOARD OF WATER AND SOIL
RESOURCES FOR REMOVAL OF AREA TRIBUTARY TO WOOD LAKE FROM MINNEHAHA
CREEK WATERSHED DISTRICT AND NINE MILE CREEK WATERSHED DISTRICT AND
ATTACHING AREA TO RICHFIELD BLOOMINGTON WATER MANAGEMENT ORGANIZATION
COUNCIL LETTER N0. 270
ADJOURNMENT
***,~,t,t*******~*~******~t****~*******~***************~~t***********
CITY COUNCIL STUDY SESSION
7:00 P.M.
COUNCIL CHAMBERS
AGENDA
CALL TO ORDER
I. 7:00-8:00 P.M. DISCUSSION WITH JAMES DENN, COMMISSIONER FOR
MINNESOTA DEPARTMENT OF TRANSPORTATION, REGARDING
TRAFFIC CORRIDOR STUDIES CURRENTLY UNDERWAY, WITH
SPECIAL CONSIDERATION GIVEN TO 135W TRAFFIC CORRIDOR
STUDY SESSION LETTER N0. 39
II. 8:00-8:15 P.M. DISCUSSION REGARDING REQUEST TO PARK TRAVEL TRAILER
(RV) ON CITY RIGHT-OF-WAY
STUDY SESSION LETTER N0. 40
III. 8:15-8:45 P.M. POLICY AND STRATEGY RECOMMENDATIONS FOR AIRPORT
RELATED ISSUES
STUDY SESSION LETTER N0. 41
IV. 8:45-9:30 P.M. REVIEW OF 1992 REVISED/1993 PROPOSED BUDGET
STUDY SESSION LETTER N0. 42
9:30 P.M. 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 861-9702.
CITY OF RICHFIELD, MINNESOTA
Study Session Letter No. 42
Agenda December 7, 1992
Issue Statement:
Review of the 1992 Revised/1993 Proposed Budget..
Background:
The Truth-in-Taxation Hearing for the 1992 Revised/1993 Proposed
City Budget is scheduled for December 9, 1992 at 7:00 p.m. In
order to respond to questions Council Members may have prior to
that time, the matter will be presented for discussion and review
at the Study Session. The budget has previously been presented
to the Council at a Study Session on October 5. In addition,
Council Members have provided questions to staff subsequent to
the presentation.
A budget presentation by City staff is not planned. Council
Members will be encouraged to provide questions for discussion.
The Council has directed staff to request comments from the
public regarding the budget. A notice was published in the
October 1992 Your City and Schools (attached). Three comments
were received; a summary of those comments is attached.
Recommended Motion:
Discuss the 1992 Revised/1993 Proposed Budget at the Study
Session.
Basis for Recommendation:
1. It would be helpful to address any issues prior to the public
hearing in order to provide ample opportunity for the public
discussion on the budget.
2. Council Members-Elect may have questions on issues. It would
be helpful to address these issues during budget discussions.
3. Staff has responded to questions and issues raised by Council
Members subsequent to the budget presentations at the
September 14 City Council meeting and the October 5 Study
Session, however there may be additional questions.
Alternative Recommendation:
None.
Discussion/Decision Mode:
This matter will be presented during the Study Session on
December 7, 1992.
Respec ully submitted,
J D. Prosser
C't Manager
JDP:ds
Attachments
City Couna~ S~eelcs
Bud e~t Su estions
~ ~~
nce again, the City approaches its annual budget process with the potential for
Oreduced or uncertain revenues from the State of Minnesota. For 1992, the City has
been warned that some reductions will be likely forthcoming in December when the City
receives its final half installment of Local Government Aids (LGA). The amount of any
reductions would be based upon the State's. revenue collections..
These potential reductions along with an uncertain 1993 revenue picture have prompted
City officials to take another close look at potential service reductions. To that end, the
City Council is seeking input from citizens regarding suggestions for future service reduc-
tions or cost saving measures. If you wish to provide input into this process, please com-
plete the following form and return to:
City of Richfield
Office of the City Manager
6700 Portland avenue
Richfield, MN 55423
i ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ a ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
One service the City could do without is:
My suggestion for saving the City money would be:
RESIDENT BUDGET REDUCTION SUGGESTIONS
There were three Richfield residents who submitted budget
reduction. suggestions to the City after the request form was
published in the October 1992 issue of Your City & Schools.
ONE SERVICE THE CITY COULD DO WITHOUT IS:
• The City should use fewer heavy trucks for garbage and
recycling pick-up. This would reduce the wear and tear on the
alleys and streets.
• A resident. who has lived in the Richfield since 1.955 suggested
that the City does not need a Mayor or City Manager. Also, the
City should reduce the number of street employees by one-third.
• No Cuts.
MY SUGGESTION FOR SAVING THE CITY MONEY WOULD BE:
• Seek additional revenues.
• Reduce the number of elected officials and make the truck
drivers more accountable for their work.
• The City needs to fix the cracks in the alley concrete near
72nd Street and Pleasant Avenue before the entire alley surface
needs to be replaced. Also, the City shouldn't charge residents
for alley sweeping because it is rarely done in the area..
City of Richfield, Minnesota
Study Session Letter No. 41
Agenda, December 7, 1992
Issue Statement:-
Policy and strategy recommendations for airport related issues.
Background•
Recent developments regarding the airport include the following:
• New Ford Town/Rich Acres Acquisition
The MAC is completing the pre-application documentation and.
environmental assessment (EA) that will be submitted to the FAA
for funding the New Ford Town and Rich Acres home buyout.
The MAC is scheduled to complete the EA documentation and publish
it for public review on December 4, 1992. A public hearing date
to review the findings of the EA is scheduled on January 5, 1993
at 7:00 p.m. in the Richfield Senior High School auditorium.
The majority of the residents in the two neighborhoods support
the buyout of the area. A petition was submitted to the MAC on
November 20, 1992, signed by about .200 New Ford Town and Rich
Acres residents and property owners, stating that they support
the buyout of their properties for noise abatement purposes. The
petition was taken by the New Ford Town-Rich Acres Advisory
Committee. There is a another group, Citizens for Preservation
of New Ford Town Residential Area, which opposes the buyout of
the two neighborhoods. The group recently submitted a petition,
signed by 40 New Ford Town residents, to the MAC and FAA, which
stated they oppose the buyout and they want to stay in their
homes..
• FAA Part 150 Program
The MAC is implementing the FAA Part 150 Sound Insulation Program
in cities adjacent to MSP in an effort to reduce the effects of
airport noise on area residents. The program involves modifying
homes to reduce the amount of noise entering from the outside.
Funding for the Part 150 Program is being provided by the FAA (80
percent) and the MAC (20 percent). The program began in 1992 and
is expected to continue for several more years.
There are five communities surrounding MSP that are affected by
noise which are included in the Part 150 Program: Richfield,
Minneapolis, Bloomington, Eagan, and Mendota Heights. Richfield
was designated as having 200 of the eligible homes and thus will
receive 20$ of the funding each year. Listed below is a proposed
schedule indicating the number of Richfield homes that will be
insulated based on this percentage formula:
1992 28 homes (140. total)
__ 1993 33 homes (135 total)
1994 106 homes (540 total)
1995 136 homes (690 total)
The soundproofing projects for the 28 eligible homes in
Richfield, as well as those in the other communities, have been
delayed due to contractors' bids coming in far over budget. In
response, the MAC made some changes in the project including the
bidding process, construction, finishing treatments and home
design modifications. The MAC also changed the contracting
procedures. The process has been personalized allowing the
homeowners to choose the contractors they want to bid on their
homes. This "house by house" method involves the MAC generating
a list of contractors which eligible homeowners will review and
then select three. to bid on their home. The lowest bidder will
be awarded the contract. The "house by house" method will speed
up the process by sending out all the bid packages concurrently,
thus allowing more homes to be insulated in a shorter period of
time.
The revised 1992 construction schedule follows:
November 17, 1992
December 21, 1992
January 11, 1993
July 16, 1993
Open Bids
Award Contract
Start Construction
End Construction
• Draft EIS for Proposed Extension of Runway 4-22
On July 1, 1992, the City submitted comments on the Draft
Environmental Impact Study (EIS) of Runway 4-22 that was prepared
by the Minnesota Department of Transportation (MnDOT). The MAC
proposes to lengthen Runway 4-22 at MSP by more than half a mile
to the southwest toward the intersection of I-494 and Highway 77.
The purpose of the EIS, jointly prepared by the FAA and MnDOT, is
to identify the possible environmental impacts of such a large
construction project. Before the MAC can continue with the
project, the FAA must approve the EIS.
The City's comments stated opposition to virtually every section
of the Draft EIS -- from the statement of purpose and need, to
the project description, to the analysis of impacts and
alternatives. In conclusion, the City believes that the MAC must
revise the Draft EIS to address the deficiencies outlined and
then re-circulate it for public comment.
The FAA and MnDOT are currently reviewing the Draft EIS and
public comments. The following FAA findings have had significant
impact on completing the Draft EIS:
1) The FAA Flight Standards Office has indicated concerns with
the landing threshold location or Runway 4 as identified in the
EIS.
2) The FAA Air Traffic Control Tower said the flight tracks
identified in the EIS are not workable and that an alternative is
required.
MAC officials stated recently that the Draft EIS will need to be
revised to meet FAA flight standards. The MAC will also need to
update many of its original analyses including forecasts, runway
noise abatement, project justification and noise analysis.
Because of these revisions, the EIS process may be delayed six
months or more in order to bring the proposal into compliance
with FAA guidelines.
• MAC 1993-1999 Capital Improvement Plan
The City submitted comments to the MAC on the environmental
effects of projects in MAC's seven-year Capital Improvement Plan
(1993-1999) for MSP. The City's comments focused on two major
issues: the Runway 4-22 extension project and the. small
percentage of projects dedicated to reducing the noise impacts of
the airport on residential areas. Attached is a copy of the
City's letter submitted to the MAC on November 25, 1992.
• MSP Symposia
Don Groen, President and Chief Operating Officer of the
Bloomington Chamber of Commerce, has scheduled meetings in
December with the heads of the. Greater Minneapolis Chamber of
Commerce, Twin West Chamber of Commerce and the St. Paul Chamber
of Commerce. The purpose of these meetings in to discuss the
proposed plans for the MSP Symposia and to obtain financial
support for the concept from the organizations. In January 1993,
Mr. Groen will present the concept to the Board of Directors at
the Bloomington Chamber of Commerce to determine their financial
commitment to the project. Mr. Groen will provide an update in
January to the cities of Richfield and Bloomington regarding the
financial support the Twin Cities chambers of commerce will give
to support the symposia.
• MAC Public Hearing on Various Options at MSP for Noise
Abatement
The MAC held a public hearing on November 30 to receive comments
concerning various options available to the Commission for
assuring additional aircraft noise abatement actions are taken by
.the airlines serving MSP airport through December 1999. The MAC
is considering whether to take additional local actions to reduce
operations of noisier Stage 2 aircraft or allow the Federal law
mandating a phased transition to Stage 3 operations to take
effect over time at MSP. Specifically, these actions include:
- Enact an ordinance to implement the Noise Budget Ordinance that
was not adopted in 1987 in favor of voluntary compliance.
- Negotiate prospective, comprehensive voluntary agreements with
NWA and all passenger airlines serving MSP to increase the
achievable level of noise reduction MAC can obtain by the end of
1999.
- Prepare to enact a new ordinance that would allow MAC~to
enforce each carrier's new negotiated agreements through 1999 and
would mandate involuntary compliance by those airlines choosing
not to negotiate.
The MAC also asked for additional suggestions from the public of
possible noise abatement actions.
The City provided the attached comments at the public hearing on
November 30. Richfield's position strongly supports
implemention of a mandatory noise ordinance at MSP that would
provide more effective noise relief for communities near the
airport. The City recommended a number of factors that should be
considered while preparing the noise ordinance. While the FAA
has previously disapproved mandatory ordinances at airports
.because of their possible infringement on commerce, Richfield
believes that these issues, though complex, can be worked out
through the best efforts of the MAC staff, cities and airline
representatives. Also, Northwest Airlines, as well all other
airlines, must include community impacts in their overall
business plans.
• Noise Mitigation Funding Legislation
During the 1992 Legislative session, a bill was passed requiring
the MAC to dedicate nearly $30 million over the next four years
from Passenger Facility Charges (PFC's) for noise mitigation
projects .around the airport. The MAC's interpretation of the
bill is that MAC must spend an equivalent of the target PFC
revenues from any source. The legislative intent of the bill was
to require the MAC to spend certain increasing percentage
minimums of its annual capital improvement budget for noise
mitigation in communities surrounding the airport in addition to
Part 150 funds.
It was Richfield's understanding that the PFC funds be dedicated
to supplement the FAA Part 150 noise compatibility program which
could be used for acquisition and soundproofing of homes and
schools where there is a demonstrated need. The additional money
now available through this bill wil•1 allow more homes and schools
to be serviced in a shorter period of time.
• FAA Capacity Task Force Study
The FAA is conducting an Airport Capacity Design Team Study for
MSP. The study began in July 1992 and is expected to be
completed sometime before the end of 1993. The MAC requested the
FAA study last February on the advice of the State Advisory
Council on Metropolitan Airport Planning. The State Advisory
Council, created by the Minnesota Legislature to gather
information and make recommendations on the Dual-Track Airport
Planning Process, requested that the MAC seriously cooperate with
the FAA to provide an independent, objective analysis of future
MSP capacity as required by the dual-track airport legislation.
The FAA has conducted, or is in the process of conducting,
similar studies of all the major airports in the United States.
The purpose of the study is to identify potential projects to
increase the airport's capacity while quantifying the possible
benefits of these projects for future operations. It is a
technical analysis examining what the existing airport can handle
and the types of capacity improvements that could be made.
The MSP Capacity Design team is comprised of FAA representatives
from air traffic control, flight standards and the Airport.
Capacity Office, as well as airport tenants (airlines and
military) and representatives from the local and state agencies
(MAC, Met Council, MnDOT). The team is chaired by Benito De
Leon, FAA Airport Capacity Manager.
The study will review the information from the original airport
enhancement concepts proposed in the MAC's Long-Term
Comprehensive Plan (LTCP) for MSP as well as evaluate additional
proposals. The MAC adopted the LTCP in November 1991 to provide
a development plan for the year 2010 and a conceptual plan for
the year 2020. The LTCP incorporates a new 8,000-foot north-
south runway and a new passenger facility terminal on the west
side of the airport.. In 1993, the .MAC is scheduled to analyze
the socio-economic and aviation assumptions utilized in the
original LTCP forecasts and will make necessary revisions. The
data and results from the .FAA capacity study will be included in
the MAC's LTCP update.
Recommended Motion:
With this background information, the following recommendations
are provided to address these issues:
• New Ford Town/Rich Acres Acquisition
Staff will continue to inform the Council on the progress of the
proposed acquisition of the New Ford Town and Rich Acres
neighborhoods.
• FAA Part 150 Program
Staff will continue to update the Council on the status of the
Sound Insulation Program.
• Draft EIS for Proposed Extension of Runway 4-22
Staff will continue to update the Council on future developments
in the environmental review process for the proposed extension of
runway 4-22.
• MAC CIP Capital Improvement Plan
Staff will inform the Council of the MAC's response to the City's
comments.
• MSP Symposia
Staff will continue to keep the Council informed of the proposed
plans for future seminars regarding MSP airport.
• MAC Public Hearing on Various Options at MSP for Noise
Abatement
Staff will inform the Council of the MAC's decision to assure
aircraft noise abatement actions are taken by airlines serving
MSP airport through December 199.9.
• Noise Mitigation Funding Legislation
The MAC's interpretation of the noise mitigation law contradicts
the legislative intent. There needs to be clarification of the
legislative intent of the bill which dictates the MAC's use of
PFC funds for noise mitigation projects near MSP. Staff will
meet with legislators to discuss this issue prior to the 1993
State Legislative session. Staff will inform the Council of
these discussions and will continue to provide updates of the
MAC's use of PFC funds in accordance to the noise mitigation
funding law.
• FAA Capacity Task Force Study
Staff will continue to update the Council of the study being
conducted by the FAA Capacity Task Force team.
Alternative Recommendation:
A variety of alternative recommendations may be discussed at the
December 7, 1992 Study Session.
Discussion/Decision Mode:
These matters will be discussed at the December 7, 1992 Study
Session.
ully submitted,
Jame Prosser
City nager
JDP:ds
Attachments
~ ~ 67Q,0 Portland Avenue • Richfield, Minnesota 55423-2599
~ I~
~~ity Manager Mayor Council
Ja//////mes D. Prosser Martin Kirsch William Bullock Michael Sandahl
Ivan Ludeman Kristal Stokes
November 25, 1992
Mr. Nigel Finney
Deputy Executive. Director
Planning and Environment
Metropolitan Airports Commission
6040 - 28th Avenue South
Minneapolis, MN 55450
RE: Comments on the Environmental Review Process
MAC Seven-Year Capital Improvement Plan, 1993-1999
Dear Nigel:
The City of Richfield reviewed the assessment of the environmental effects of projects in the
Metropolitan Airports Commission's Seven-Year Capital Improvement Plan (1993-1999) for
Minneapolis-St. Paul International Airport. The City is concerned with the following elements
of the plan.
1. Runway 4-22 Extension Project
As stated in the CIP, the MAC's primary purpose for the project is to permit increased use of
Runway 4-22 by providing additional length to Runway 22 and to allow aircraft departing on
Runway 22 to start their takeoff roll southwest of the intersection of Runway 11 U29R. -This
would allow Runway 11 U29R to be operated independently of departures on Runway 22
and would permit these two runways to be operated independently to accomodate up to 90
operations per hour (p. A-12).
The City, has three major concerns with the project's primary purpose.
• Break Release Point
The City is opposed to .the displacement of the aircraft departure threshold further south on
Runway 22. Richfield's concern is that the intensity of noise will be increased for residents
living in southeast Richfield if the departure point is moved towards the south end of the
runway. The break release point should remain unchanged.
• Increased Flight Operations on Runway 22
The MAC states that the extended runway can accomodate up to 90 flight operations per
hour. This will divert some of the airport noise from south. Minneapolis and northeast
Richfield to southeast Richfield and northeast Bloomington. To date, MAC has not
responded to questions raised by Richfield in our Draft EIS responses. These questions
relate to the accuracy of operations projections. These questions should be answered prior
to approval of this project.
The Urban Hometown
Telephone (612) 861-9700
Fax 861-9749
An Equal Opportunity Em•pioyer
Mr. Nigel Finney
November 25, 1992
Page 2
The City is concerned that the increased number of flight operations on Runway 22 will
cause adverse noise impacts on Richfield residential areas. Richfield also questions the
validity of this purpose for the project.
The proposed project does not contain enough detail on the projected flight operations on
Runway 22. Richfield has no protection that the percentage of takeoffs on Runway 22 will
not increase in the future. Also, there are no assurances that there will be an equitable use
of both ends of the runway to balance air traffic and noise for communities located on both
ends.
• Noise Mitigation
The plan does not provide a reasonable mitigation plan for the residential areas in southeast
Richfield that will be negatively impacted by the increased number flight operations. and the
displaced break release threshold on Runway 22.
The City of Richfield reviewed and submitted comments on the Draft Environmental Impact
Study (ElS) of Runway 4-22 on July 1, 1992. In these comments, the City identified :a
number of environmental and flight operational concerns with the proposed runway project.
Attached is the introduction which summarizes our concerns with the proposed project.
In conclusion, the City of Richfield believes that the MAC should not include the Runway 4-
22 extension project in the 1993-1999 CIP unti(the EIS process is satisfactorily completed.
Before the project can .proceed, the MAC and FAA must address and resolve to deficiencies
as outlined in Richfield's response. After the EIS is revised, the document should be
recirculated for public comment. Funding to mitigate Runway 4-22 extension impacts
should also be specifically identified.
2) Environmental
The proposed seven year Capital Improvement Plan (1993-1999) reflects 12% of the capital
improvement projects dedicated for environmental purposes. Except for school insulation,
MAC to date has undertaken virtually no residential noise. mitigation projects. Amore
significant portion of the MAC's Capital Improvement Budget should be dedicated to
....reducing the impact of the airport on residential areas. A review of MAC's Capital
Improvement Plan should also include the legislative mandate contained in Section 473.661,
Subd. 4 of Minnesota State Statutes. This statute requires MAC to dedicate a specific
portion of their budget for off-site noise mitigation projects to supplement Part 150 efforts.
We appreciate the opportunity to review and submit comments on the MAC 1993-1999
Capital Improvement Plan.
i erely,
Ja es D. Prosser
Ci Manager
JDP:ds
Attachment
/~~
REMARKS BEFORE THE
METROPOLITAN AIRPORTS COMMISSION
SPECIAL MEETING
NOVEMBER 30, 1992
Good evening. I am Martin Kirsch, Mayor of the City of Richfield. The City of Richfield
appreciates the opportunity to present its views regarding regulation of airport noise.
Richfield strongly supports an airport noise ordinance. The voluntary noise budget for
MSP has produced positive community benefits. However, overall, the process of
preparing and implementing a mandatory noise ordinance would, in our opinion,
provide more effective noise relief.
Some factors that should be considered in preparing the noise ordinance include the
following:
• Other airports, notably the John Wayne airport in California, have been
experimenting with several different takeoff procedures which produce different
types of noise relief.. The final phase of-this effort is due to be completed at the end
of this year and should be carefully studied for use at MSP.
• B727-100 aircraft with different type engines have been developed to provide a
quiet freight version of aircraft capable of meeting Stage III noise requirements.
Greater use of aircraft with these new engines for freight operations should be
considered at MSP.
• The GAO is completing a survey of 140 jet airports in the United States. This
survey report will provide a number of aviation noise reduction options that should
be considered by MAC for application at MSP.
• An airport noise and operation monitoring system has recently been implemented
at MSP. The MAC should educate communities on what sort of information this
system can provide to them and what types of feedback would be helpful in using
this system prior to the preparation of a noise ordinance.
• The City of Richfield continues to experience significant disruption to our residential
community because of early morning run-ups. We recognize that all airlines are
required to conduct maintenance run-ups in the Northwest Airlines' run-up pad.
We also understand that night time run-ups are prohibited unless preauthorized by
MAC. However, we continue to receive complaints about run-ups in the early
morning hours including prior to 6:00 a.m. MAC should survey the times and
number of aircraft using the run-up pads and determine whether adjustments
could be made to provide early morning relief to our residents.
• Generally, the night time noise restrictions are of great concern to our residents.
Richfield strongly encourages MAC to expand the time for night time noise
restrictions from 10:30 p.m. to 6:00 a.m.
• Communities surrounding. MSP should be directly involved with a process to
establish acceptable noise budget measures. Since it is the residents of these
communities impacted by the airport noise, their involvement is important.
• Several major airports are using AIP funds to pay for noise mitigation projects. As
part of the noise- budget ordinance discussion, MAC should consider funding
projects to redevelop noise sensitive areas to other uses utilizing AIP funds.
We understand that the FAA has previously disapproved noise ordinances because of
their concern on the impact of these ordinances on commerce. These issues are
complex but can be worked out through the best efforts of MAC staff, cities and airline
representatives.
Finally, concern about imposing new restrictions on Northwest Airlines are
understandable. But in many ways, this is the time that it is especially important to
make sure that Northwest as well as all other airlines understand the need to include
community impact as part of their overall business plan.
Thank you for the opportunity to address your commission on this very important
matter.
COMMENTS OF CITY OF RICHFIELD, MINNESOTA
ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR PROPOSED EXTENSION OF RUNWAY 4-22
AT MINNEAPOLIS/ST. PAUL INTER~'~1ATIONAL AIRPORT
James D. Prosser
Richfield City Manager
6700 Portland Avenue
Richfield, MN 55423
(612) 861-9700
Charles L. LeFevere
Holmes & Graven, Chtd.
470 Pillsbury Center
Minneapolis, MN 55402
(612) 337-9300
Steven F. Pflaum
McDermott, Will & Emery
227 West Monroe Street
Chicago, Illinois 60606
(312') 372-2000
July 1, 1992
I. INTRODUCTION
The City of Richfield, Minnesota ("Richfield") submits these
comments on the Draft Environmental Impact Statement and the
Supplement to the Draft Environmental Impact Statement
(collectively, the "Draft EIS") for the proposed extension of
Runway 4-22 at Minneapolis/St. Paul International Airport
{"MSP"). As explained below, the Draft EIS fails to comply with
the requirements of the National Environmental Policy Act of 1969
("NEPA," 42 U.S.C. § 4321 et seq.), Moreover, approval of the
project would violate section 509(b)(5) of the Airport and Airway
Improvement Act of 1982 {"ARIA," 49 U.S.C. App. § 2208(b)(5)),
section 4(f) of the Department of Transportation Act of 1966
("Transportation Act," 49 U.S.C. § 303(c)), Executive Order
11990, and the National Historic Preservation Act of 1966
{"Preservation Act," 16 U.S.C. § 470 et seq.).
The Draft EIS describes the primary goal of the runway
project as being "[t]o increase the use of the crosswind runway
(Runway 4-22) to provide for a shift in some aircraft noise away
from the most heavily impacted residential areas northwest of the
airport." Draft EIS at 12.~~ However, the Draft EIS is
premised upon unrealistic and unsupported assumptions about the
1. Page references to the original Draft EIS are in the
form "Draft EIS at [page number]." Page references to the
Supplement to the Draft EIS are in the form "Supplement at [page
number]."
-1-
extent to which the extended Runway 4-22 could be used in the
contemplated fashion.. In reality, operational and airport design
constraints, many of them associated with the queuing taxiway f•or
Runway 22, would severely impair the capacity of the extended
runway.
The inflated runway capacity assumed in the Draft EIS
undermines both the environmental analysis and the purported
justification for the project. The assertion that the runway
project would shift a certain number of operations from the
parallel runways to Runway 4-22 constitutes the very foundation
of the environmental analysis contained in the Draft EIS. If
Runway 4-22 is used significantly less than the Draft EIS
predicts, then the true environmental consequences of the project
would be vastly different from those projected in the Draft EIS.
Moreover, the entire rationale for spending upwards of
$17 million on this project is undermined if the extended runway
would not permit increased departures on Runway 22 to the extent
claimed in the Draft EIS.
On the other hand, if the extended runway were used to the
extent claimed in the Draft EIS notwithstanding the operational
obstacles, the project would result in significant departure
delays. The existence, and environmental consequences, of such
delays are never addressed in the EIS. Nor could such disruption
in the efficient operation of MSP be accepted for a project that
-2-
is conceded not to reduce airport noise, but simply to shift it
from one primarily residential area to another.
The Draft EIS would be fatally flawed even if the project
would work as represented. The EIS is premised upon an
artificially narrow statement of need that, in turn, produces an
artificially narrow project description, analysis of
environmental impacts, and discussion of alternatives. The
statement of the need for the project--and the manner in which
the project's objectives conveniently changed during the course
of environmental review--suggest that the Draft EIS is simply a
post-hoc rationalization for a project that the sponsor, at
least, has already decided to .approve. That concern is
reinforced by the fact that the FAA has already conditionally
approved the runway project on two occasions, and that the Long-
Term Comprehensive Plan being developed for MSP is predicated
upon the prior extension of Runway 4-22.
The Draft EIS violates NEPA by completely ignoring many
significant environmental impacts, such as safety, land use, and
cumulative impacts. The consideration of other impacts, such as
noise, contains technical information but offers no analysis of
the severity of the impacts associated with the proposed project.
Particularly unfortunate is the almost complete lack of analysis
regarding mitigation measures. Indeed, the Draft EIS completely
fails to address steps that could assist the residents of the
-3-
communities that would bear the brunt of the project's impacts,
i.e., Richfield and Bloomington. The Draft EIS also violates
provisions in NEPA and the implementing regulations promulgated
by the Council on Environmental Quality ("CEQ") regarding the use
of consultants in the preparation of environmental .impact
statements.
Even the inadequate analysis contained in the Draft EIS
makes it clear that the proposed project cannot be approved.
There is simply no basis for a finding, as required by
section 509(b)(5) of the ARIA, that there is no "feasible and
prudent alternative" to the runway extension project and that
"all reasonable steps have been taken to minimize [theJ adverse
effect." 49 U.S.C. App. § 2208(b)(5). Nor could it reasonably
be concluded, under section 4(f) of the Transportation Act, that
the project includes "all possible planning to minimize harm to
the park[s)" that would be affected by significantly increased
noise levels. 49 U.S.C. § 303(c). The existence of feasible
alternatives that would avoid any impacts to wetlands also
prevents a .finding, under Executive Order 11990, that there is no
"practicable alternative" to the proposed project. Finally,
there is no basis for concluding that the proposed project would
not affect any historic properties. protected by the Preservation
Act.
-4-
Under these circumstances, no additional time and money
should be invested in studying this project. However, if the
Metropolitan Airports Commission ("MAC") is not prepared to
abandon the project immediately, MAC and its consultants should
work closely with the FAA to evaluate the efficacy of the
proposed runway. After having done so, if MAC wishes to pursue
this project, the fundamental defects in the Draft EIS require
that a revised Draft EIS be prepared and recirculated for public
comment.
II. THE DRAFT EIS IS PREDICATED UPON UNREALISTIC AND UNSUPPORTED
ASSUMPTIONS REGARDING THE OPERP.TION OF THE RUNWAY PROJECT
A. The Original Draft EIS
The linchpin of the analysis in the Draft EIS is its
assertion that the proposed extension of Runway 4-22 would
increase the capacity. of that runway under the Runway Use System
("RUS") from the current level of 60 operations per hour to a
level of 70 to 95 operations per hour:
"Increasing the length of Runway 4-22 would
increase the hourly capacity of Runway 4-22 under
the RUS to 85 to 95 operations during peak arrival
periods and to 70 to 80 operations during
departure peaks. ." Draft EIS at 25-26.?~
2. The accuracy of this estimate appears questionable in
light of the significantly lower estimate contained in MAC's
"Informational Brochure" for the runway extension. (A copy of
(continued...)
-5-
CITY OF RICHFIELD, MINNESOTA
Study Session Letter No.40
Agenda December 7, 1992
Issue Statement:
Discussion concerning a request to park a travel trailer (RV) on
City right-of-way..
Background•
Randy Bednar, 7344 Chicago Avenue, has been parking an RV on the
74th Street boulevard for a number of years. A recent complaint
made the City aware of the violation, and Public Safety ordered the
RV to be removed. Subsequently, Mr. Bednar has requested
permission to allow continued use of-the right-of-way. The request
is for two dependent actions:
• permission from Council to use right-of-way; and
• variance under RV ordinance.
This would be the first application for a variance under the RV
ordinance and there has been no policy established for the handling
of such petitions.
Recommended Motion:
Discuss the alternatives and direct staff in developing policy.
Alternatives•
1. Refer the case to the hearing examiner for consideration of
variance related to established driveway and distance from
street curb. Council. would consider use of right-of-way of
variance granted or if variance denied and appealed to Council.
2. Consider use of right-of-way and, if permitted, submit to
hearing examiner for variance hearing.
3. The Council has the right to consider both issues in a single
public hearing.
4. The application cost for a residential zoning variance is
$200.00. It is estimated that an RV ordinance variance would
be similar in administrative cost, including the legal
publication, notices, preparation for and public hearing.
Alternative Recommendation:
Defer the discussion to a future study session.
Discussion/Decision Mode:
This is presented for Council discussion on December 7, 1992.
Respect ly submitted,
Jame Prosser
City anager
JDP:ds
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6700 Portland Avenue • Richfield, Minnesota 55423-2599
City Manager Mayor
James D. Prosser Martin Kirsch
Council
William Bullock Michael Sandahl
Ivan Ludeman Kristal Stokes
October 23, 1992
C#922016
Qo
Resident
7344 Chicago Ave. S.
Richfield, MN 55423
It has come to our attention that your
with Richfield ordinances relating to
specific concerns are as follows:
property does not conform
property maintenance. The
1. RV on the side of garage adjacent to the street must be
removed. Please read attached ordinance on area's where RV may
be stored.
If you have any questions, please contact the Environmental
Health Division at 861-9880 at your convenience. Otherwise, we
ask you to alleviate these conditions within 5 days, and help us
to maintain the property maintenance standards that have made
Richfield such a pleasant community in which to live.
Enclosed are the specific ordinances regarding the above items..
An inspector will stop by after the time period noted to re-
inspect the property.
Sincerely,
Jean Sawyer
Environmental Health Specialist
Richfield Public Safety Department
jms
Enclosures
Telephone Number General City Matters: (612) 861-9700
Public Safety Non-emergency (24 hr.) (612) 861-9800 POLICE/FIRE/EMERGENCY: DIAL 91 1
&ichfield City Code
Section 1325. .Parking: recreational vehicles.
1325.01
{Rev. 2-17-89 )
1325.OI. Declaration of purpose. The standards established for recreational
vehicles and equipment in this section are designed to regulate their storage
and commercial use and to protect the health, safety and general welfare of the
community. The standards are established to promote the safe use, storage and
parking of recreational vehicles and equipment and to eliminate those conditions
or misuses which are unsafe and cause deterioration of property and property
values.
1325.03. Definitions. The term "recreational vehicles and equipment" means
travel trailers, including those which telescope or fold down, chassis mounted
campers, house cars, motor .homes, .tent trailers, slip-on campers, converted
buses and converted vans:
(a) Travel trailers, including those which telescope ar fold down,
chassis mounted campers, house cars, motor homes., tent trailers, slip-on
campers, converted buses, converted van and units that .are designed and used
for human living quarters and meeting the following qualifications: {Amended,
Bill No. 1989-2)
(1) are not used as the residence of the owner or occupant;
(2) are used for temporary living quarters by the owner or occupant
while engaged in recreational or vacation activities;
(3) are self-propelled or towed on the public streets or highways
incidental to such recreational or vacation activities.
(b) Slip-on campers are mounted into a pick-up truck in the pick-up box,
either by bolting through the floor of the pick-up box or by firmly clamping to
the side of the pick-up box.
(c) Snowmobiles and snowmobile trailers, boats and boat trailers, all
terrain. vehicles and all terrain vehicle trailers, and utility trailers, which
for the- purpose of this Section shall mean any motorless vehicle having a
carrying capacity of 20,000 pounds or less and used for carrying property on its
own structure while being drawn by a motor vehicle. (Added, Bill No. 1989-2)
The term includes snowmobiles and snowmobile trailers, boats and boat trailers,
and all terrain vehicles and all terrain vehicle trailers; the term does not
include mobile homes or house trailers as defined in Minnesota Statutes, sec-
tion 168.OI1, subdivision 8.
1325.05. Permitted uses. Subdivision 1. General rule. Recreational vehicles
and equipment may be parked or stored in a residential zoning district or in
portions of planned unit development districts designated for residential uses
as follows:
(a) on any rear or side yard of a lot except the side yard of a corner
f lot adjacent to the street.
Richfield City Code 1325.05, Subd. 1
.(Rev. 2-17-89)
(b) case' closer than three feet to any building or structure, including
fences. ~~~
(c) is as established driveway of a lot but not closer than three feet to
-any building or structure not beyond the lot line and not closer than 12 feet to
the curb line of the street abutting an established driveway.
Subd. 2. Loadin A recreational vehicle may be stored on a lot without
regard to the location on the lot for the sole and express purpose of loading
and unloading for a period not in excess of 48 hours.
• Subd. 3. Slide-in pickup campers. Unmounted slide-in pickup campers must
"-' be stored no .higher .than 20 inches above the ground and must be securely sup-
ported at least at four. corners by solid support blocks.
1325.07. Prohibited uses. A recreational vehicle may not be stored, parked or
utilized in residential zoning district or in portions of planned wait develop-
ment districts designated for residential uses as follows:
(a) recreational vehicles and equipment'shall not be used as a permanent
residence;
(b) a recreational vehicle which is in a state of ezteraally visible
disrepair or partial construction must be stored or parked in a rear or side
. yard but not closer than three feet to any building or structure and for not
~` more than one year.
1325.09. .Variances. The council .may grant variances to the literal provisions
of this. section in the same manner .and subject to the same requirements that
apply to variances granted under section S~iS of the zoning code.
1325.11. Inoperable Vehicle. The provisions of Subsection 1320.13 shall be
applicable to the parking and storage of recreational vehicles, ezcept as
provided in Subsection 1325.07, paragraph (b) and notwithstanding any other
provisions of this section to the contrary. (Added, Bill No. 1989-2)
Nov. 2, 1992
To: Richfield City Council Members
From: Randy and Barbara Bednar
7344 Chicago Ave. So.
Phone - 921-2275 (w), 869-5170 (h)
Re: Request to continue .parking RV at current site
Dear City Council Members,
Please accept this letter as our request to continue parking our travel
trailer in the only spot we have available.
Because we have a corner lot our trailer is now supposed to be parked
either on our driveway or towards the rear of our lot. Our predicament
is that neither place will work out. To get it into the corner of our
backyard would require the removal of our yard light, a few trees, .and
some landscaping. Because of the trailer length (33') and a small back
yard~it will not fit in anyplace other than the far corner. Also, because
our driveway is short and makes a 90° turn we need the whole driveway to
make the swing into our garage. The only space left that is workable is
along side our garage on the street side. Attached are some photos of
our lot and trailer so you can get a better understanding our situation.
Both Dennis Nydecker and Betsy Christianson, with the city, have already
visited our lot and can verify what we have described.
We have lived in our home 18 years and have usually owned an RV parking
them on this spot with never a complaint from our neighbors. As evidenced
by the attched list of signatures of neighbors all around us, none of them
has a problem with where its parked. When this trailer was purchased in
January of 1989 we initially considered keeping it at a rental storage
area but had to rule that out because of our concerns for its safety, high
storage costs, and the fact that it wasn't practical from a usage standpoint.
Thank you for your time and consideration of our request.
! Sinc~r(ely, ~~~~,
' Ran~y and Barbara Bednar
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CITY OF RICHFIELD, MINNESOTA
Study Session Letter No. 39
Agenda. December 7, 1992
Issue Statement:
James Denn, Commissioner for the Minnesota Department of
Transportation, has been invited to join the Council and members
of the Richfield community at 7:00 p.m. to discuss the traffic
corridor studies currently underway. Special consideration is to
be given to the I35W traffic corridor.
Background•
Studies of•the I35W and I494 traffic corridors began in earnest
in 1986. Draft Environmental Impact Statements were available
the summer of 1992. The Commissioner for the Minnesota
Department of Transportation is expected to make an announcement
before year end 1992 as to the preferred alternative for each of
the two traffic corridors.
Richfield has carefully followed and participated in the traffic
corridor studies. The 1494 traffic corridor study appears to
have little controversy. The I35W traffic corridor study,
however, has produced several points of controversy.. Richfield
has taken a position in favor of High Occupancy Vehicle lanes on
the basis of safety, local traffic impacts and ridership.- In a
recent press conference, the suburban communities of Richfield,
Bloomington and Eden Prairie presented a unified position
regarding the I35W traffic corridor alternatives.
Members of various Council appointed commissions and committees
as well as some local organizations have been specifically
invited to this Council Study Session. All members of the'
community are invited to participate in the discussions.
Recommended Motion:
No action required. The purpose of the meeting is to discuss the
various traffic corridor studies, I35W in particular, and to make
Richfield's position clear to the Commissioner of Transportation.
Basis of Recommendation:
1. Richfield continues interest in the traffic corridor studies.
2. The I35W traffic corridor study appears to have several
points of controversy.
3. The Commissioner of Transportation is expected to make a
decision before year end 1992 about preferred alternates for
the I35W and I494 traffic corridors.
Alternative Recommendation:
None.
Discussion/Decision Mode:
This discussion item is scheduled for 7:00 p.m. at the City
Council's December 7, 1992 study session.
Respectfu ly submitted,
James Prosser
City anager
JDP:ds