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DORSEY & WHITNEY LLP <br /> <br />Mr. Stephen Rohlf <br />Page 5 <br /> <br />August 13, 1997 <br /> <br />the Urban Service EAW ignores these EQB requirements on related projects, <br />connected actions and cumulative impacts. <br /> <br /> Beyond the technical requirements of EQB's rules, it is not idle rhetoric to <br />recognize that construction of the municipal infrastructure envisioned by this <br />project will transform the study district from one that is largely rural in character to <br />a highly-developed urban area. To conclude that there is no potential for <br />significant environmental impact in creating additional urban sprawl upon land <br />devoted principally to open space, wood lands and agricultural activities is, to say <br />the least, to ignore the obvious. Yet, the EAW performs just this feat by failing to <br />analyze most of the real-world consequences that would follow the proposed <br />infrastructure were it to be built. Indeed, Elk River's extended planning process <br />over the last few years has been aimed precisely at shaping (and candidly, <br />encouraging) these development consequences. Cargill respectfully urges the City of <br />Elk River to recognize that MEPA simply does not permit the potential cumulative <br />environmental impacts of such a fundamental transformation to be ignored. <br /> <br />A. Specific Defects <br /> <br /> Elk River's failure to provide timely notice of the Urban Service EAW has <br />prevented Cargill from completing a thorough review of the proposed project. <br />Even a brief review of the document, however, demonstrates its failure to provided <br />the disclosure and analysis required by MEPA of the fundamental issues at stake in <br />connection with the proposed project. The following provides a brief summary of <br />some of the most obvious concerns. <br /> <br />1. Analytical Omissions <br /> <br /> In numerous areas the Urban Service EAW simply ignores potential <br />environmental impacts. The discussion in this section identifies some of the issues <br />that are not addressed in any substantive fashion by MSA. <br /> <br /> Items 9 and 10 of the Urban Service EAW, addressing land use and cover <br />types, indicate that less than 10 percent of this 2400-acre plus area is devoted to <br />urban development. Item 10 claims that the project will result in the loss or less <br />than 20 acres in aggregate of wetland, woodland, open space and farmland. Yet the <br />reality is that if the sewer, water and road facilities included in the project are built, <br />economic and development pressures will result in dense and intense development <br /> <br /> <br />