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Minnesota Deportment of Natura{ Resources <br />Division of Ecological and Water Resources <br />1200 Wamer Road <br />St. Paul, MN 55106 <br />651-259-5738 <br />March 7, 2011 <br />Rebecca Haug, Environmental Administrator <br />City of Elk River <br />13065 Orono Parkway <br />Elk River, MN 55330 <br />rhaug@ci.elk-river.mn.us <br />~~~~n~~a}~~I <br />DEPAATliiENTOF <br />NATUAAEAESOUACES <br />Transmitted Via E-mail <br />RE: Plaisted Companies Sand and Gravel Mining Operation Environmental Assessment <br />Worksheet (EAW) <br />Dear Ms. Haug: <br />The Minnesota Department of Natural Resources (DNR) Central Region has reviewed the EAW <br />for the Plaisted Companies Sand and Gravel Mining Operation in the City of Elk River. From a <br />natural resources perspective, the proposed project does not require the preparation of an <br />Environmental Impact Statement (EIS). However, the following comments are for your <br />consideration. <br />Please be advised that the document posted online, along with the agency distributed copies, <br />appeared to be missing some of the attachments referenced in the document. Item 5 and Item 16 <br />made reference to a Figure 5, and item 11 b referenced an Appendix A. At this time it does not <br />appear that these omissions warrant concern for the potential of significant impacts. These errors <br />should, however, be noted for reviewers and these documents should be made available. <br />The EAW does not directly indicate the proposed mining depths, or the potential for the mining <br />operation to impact groundwater. Item 19 indicates that the minimum depth to groundwater is 20 <br />feet. The description of the stockpile locations provided in Item 7 indicates that the pit floor would <br />be approximately 20 feet below grade. While Figure 3, Mining Excavation Plan, indicate that <br />depth would be a minimum of 990 feet mean sea level (with surface elevations varying from <br />1,000 to 1,025 feet mean sea level) and that actual excavation depth may vary depending on the <br />quality of aggregates encountered. Given this information, it maybe possible that the proposed <br />activities could encounter and/or impact groundwater resources. It does not appear from review <br />of other Item information provided that the proposed project includes in-water mining activities. <br />The potential to impact groundwater should be addressed, or the information discussed above <br />should be clarified so that it is clearly understood how this potential impact will be avoided. <br />The DNR Natural Heritage Database letter dated November 15, 2010 identified that Blanding's <br />turtles (Emydoidea blandingi~), a state-listed threatened species, have been documented in the <br />vicinity of the proposed project. The letter also stated that the response to Item 11 b of the project <br />EAW should clearly discuss potential impacts to Blanding's turtles and identify any avoidance or <br />mitigation measures that will be implemented. Possible avoidance or mitigation measures were <br />included in the Blanding's turtle fact sheet that was attached to the letter. While the EAW <br />document acknowledged this comment, the document does not indicate how or to what extent the <br />proposed project will incorporate or consider the recommendations to avoid and minimize impacts <br />as requested. The DNR encourages project proposers to incorporate the recommendations <br />www.mndnr.gov <br />AN EQUAL OPPORTUNITY EMPLOYER <br />i~ PRINTED ON RECYtlEO PAPER CONTAINING A MINIMUM OF 1096 POST-CONSUMER WASTE <br />