5.2. SR 09-08-1997 - Laserfiche WebLink

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DORSEY & WHITNEY LLP Mr. Stephen Rohlf Page 6 August 13, 1997 of most of the 2400 acres. Perhaps the only area that would not be developed would be the approximately 300 acres in Cargill's ANC. Nowhere in Items 9, 10 or 11 does the Urban Service EAW discuss potential impacts associated with this fundamental transformation. There are a number of ecologically sensitive and other important environmental resources in the study area, including the Mississippi River, wildlife habitat, plant and animal species, and unique agricultural lands (including the ANC). These areas, to varying degrees, would be substantially altered or impaired by the extension of urban sprawl to the study area. Items 9 through 11 of the EAW form are intended to address such "big-picture" issues, but the document is essentially silent on these questions. Of particular concern to Cargill is the fact that the Urban Service EAW fails to even identify the ANC or its sensitive research functions when mentioning that there is a large Cargill property in the study area. Indeed, the document obscures this fact through its inclusion of an inaccurate zoning map which identifies the Rla district as "Single Family Residential." In fact, the Rla district is a rural residential zoning classification in which significant agricultural activities, including those of Cargill, are conducted. The company repeatedly has made it clear to the City that Cargill is committed to retaining its present site as the permanent home for the ANC operations. The Urban Service EAW makes no attempt to address the environmental implications of large-scale urban development immediately adjacent to the agricultural activities that will continue within the study zone. EAW also fails to consider the implications of the physical extension of certain sewer and water facilities directly onto Cargill's property, which apparently is contemplated under this new project. The Similarly, the discussion in Items 11, 12 and 13 of water resources (wetlands, streams and other surface waters) is cursory at best. In these Items, the Urban Service EAW fails to analyze the extent of anticipated impacts to the environmental resources, and offers unsupported conclusions to the effect that undefined "best management practices" or other control measures will be developed at some later date to mitigate whatever impacts do occur. As discussed in detail below, this approach to environmental review under MEPA has been rejected by the Minnesota courts.