06-363co��aF;ie# ob—s�s
Green 5heet # 40'�049R
RESOLUTION
CITY OF SAINT PAUL, MINNESOTA
Presented By
/y
1 WHEREAS, on or about December 29, 2005, the Metropolitan Airports Commission
2 (hereinafter, the "MAC"), pursuant to Leg. Code § 61.301, submitted two applications for zoning
3 approvals to the Saint Paul Planning Commission (hereinafter, the "Commission") for the
4 purpose of constructing a levee and flood wall system around Holman Field Airport in order to
S protect it from 100-year flood events. The said property is commonly known as 644 Bayfield
6 Street and is legally described in the MAC's application as Lampreys Addition to Saint Paul Ex
7 Leases & Ex Natl Guard Air Base; Part E Of Ry Of Fol; Part Of Govt L.ots 7-11 In Sec 4& Govt
8 Lot 4& 12 & E i/z Of 13 In Sec 5 T28 R22 & S112 Mol Of Blks 10-12 & All Of Blks 1-9 F
9 Ambs Add & S U2 Mol Blk 5& All Of Blks; and
10
11
12
13
14
15
16
17
18
19
30
21
22
23
2A
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
WI3EREAS, under Zoning File No. 06-000752, the MAC applied for variances from the
strict application of the River Comdor Overlay District (Leg. Code § 68.402 and § 68.601)
regulating development on existing slopes steeper than 12%, establishing new slopes steeper
than 18%, and developino structures less than 50 feet from the "Ordinary High Water L,evel," to
undertake "compensatory excavation" and to construct a flood protection system an the Ii zoning
district and RC1 and RC2 Rlver Corridor Overlay Districts; and
WHEREAS, under Zoning File No. 06-000725, the MAC applied for site plan review
under the provisions of Leg. Code §61.40Q in order to construct the flood protection system and
undertake compensatory excavation on the said property; and
WHEREA5, on January 19, 2006, having provided nolice to affected property owners,
the Commission's Zoning Committee duly conducted a public hearing on the said applications
where all persons present were afforded an opportunity to be heard and, at the close of the public
hearing, the Zoning Committee, based upon the files and records, requested additional
information from staff and continued the matter to February 2, 2006; and
WHEREAS, on February 2, 2006, the Zoning Committee received the additional
information requested and thereafter moved to recommend approval, with conditions, of both the
variance application and the site plan application as submitted by the MAC; and
WI�REAS, on February 1Q 2006, the matter was set before the Commission to receive
and discuss the recommendaCions of the Zoning Committee. However upon the statements of
staff infornung the Commission of the significant amount of written information that had been
submitted following the Zoning Committee public hearing, the Commission moved to continue
the matter to its scheduled February 24, 2006 meeting in order ro allow all persons who desired
to respond in writing to the said additional information to submit such additional comments for
the record no later than 4:30 p.m. on February 21, 2006; and
WI�EREA5, on February 24, 2006, the Commission discussed the Zoning Committee's
recommendations and, by sepazate motion, moved to approve, with condiuons, the MAC's
application for variances from the provisions of the City's River Corridor Overlay District under
Commission Resolution No. OS-17 and further moved to approve, with conditions, the MAC's
1 request for site plan approval in order to construct a flood protection system a�d compensatory
2 excavation on the said property under Commission Resolution No. o5-18, based upon the
3 following findings and conclusions as set forth in the res ect ve Commission Resolutions noted
4 above: $ � — � � �
6 T. COMNIISSION RESOLUTION NO. 05-17 APPROVING THE MAC'S
7 VARIANCE REOLTEST �Zoning File No. 06-0007251
o �,
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
33
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
The requested variances meet a11 of the required findings per Section 61.601:
I. The property in question cannot be put to a reasonable use under the strict provisions
of the code.
The airport had to close for a total of 210 days during and after the floods in 1465, 1969, 1493,
1997 and 2001. Costs to tenants at the airport for the 2001 flood (a 75-year flood) were $3.8
million plus additional costs due to delays at the Minneapolis-Saint Paul airport caused by flights
having to be diverted there from Holman Field.
A levee/flood wall system to protect the airport from flooding is a reasonable use that cannot be
constructed under the strict provisions of the code:
The levee cannot be built without first doing the Compensatory Excavation and it is not possible
to do Chis excavation without affecfing slopes on the existing shoteline that are steeper than 12%.
The existing shoreline was created with fill that was used to create the airport and typically has
steep slopes in excess of 50%.
Most of the new, relocated shoreline would have slopes less steep than 18%, bringing the
shoreline more into compliance with current standards. However, steeper slopes are needed in
certain locations where room is limited, such as near the end of the runway. But even in these
areas, the new shoreline will be less steep than the existing.
L.evees are typically built with side slopes of 30%. Requiring side slopes of 18% as required by
the River Corridor Ordinance is impractical and would not provide any benefit.
The location of the sheet pile portion of the levee is determined by the location of existing
Bayfield Street and the existing hanger building. It is not practical to locate this portion of the
levee further from the shoreline.
2. The plight of the land owner is due to circumstances unique to this properly, and these
circumstances were not created by the land owner.
Holman Field was created in the floodplain of the Mississippi River in the late 1420's by the City
of Saint Paul. The MAC took over ownership and operation of the facility in August 1944. The
plight of the landowner is due to the unique circumstance of owning an existing airport in a
location subject to periodic flooding and the location of the streets, hangers and runways. This
situation was not created by the current land owner.
The factors that require variances are existing conditions that were not created by the owner.
These include the location.
Page 2 of 41
,
1 3. The proposed variance is in keeping with the spirit and intent of'the code, and is
2 consistent with the health, safety, comfort, morals and welfare of the inhabitants of the
3 City of St. Paul. O�_ 3��
4
5 The variances for the Compensatory Excavation are consistent with the spirit and intent of the
6 code. The existing shoreline was created with fill that was used to create�the airport. The
7
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
4�
46
47
48
49
50
51
ex3sting shoreline slopes are greater than 50% and aze subject to erosion. The proposed
shoreline, which wouid have a more stable slope and would also be stabilized with native
vegetation, is in keeping with the spirit and intend of the code.
The variances for the levee and flood wall are consistent with the spirit and intent of the code.
The slope restrictions and distance requirements are intended to control erosion and development
impact on the river from individual buildings, not from flood control projects. The side slopes
for the earthen levee will not have an impact on the chazacter of the river. The reduced setback
from the river for the sheet pile portion of the project will not impact the character of the river
because it will be screened by existing vegetation and wiil not be visible from the river.
4. The proposed variance will not impair an adequate supply of dight and air to adjacent
property, nor will it alter the essential character of the surrounding area or
unreasonably diminish established property values within the surrounding area.
The levee will not have changed the visual character of the area. The sheet piling will be hidden
from view from the river by the exisYing trees and other vegetation. The temporary levee will
not be visible except when it is erected during flood conditions. The earthen levee will be set
back from the river and will blend in with the sunounding area.
If the compensatory excavation is done, the levee will not raise the level of the river during flood
conditions.
The compensatory excavation will not change the essential character of the shoreline. There are
currently problems with erosion along the shoreline and the proposed planting with native
grasses and limited use of rip rap will reduce the erosion and stabilize the shoreline.
The Compensatory Excavation and the Flood Protection System and its impact on the river must
also be reviewed and approved by other agencies including the Army Corps of Engineers,
Minnesota Pollution Control Agency and the Minnesota Department of Nataral Resources.
The Flood Protec6on &ystem �vill not cause an increase in air traffic at the airpQrC that would
unreasonably diminish established property values within the sunounding uea.
5. The variance, if granted, would not pernzit any use that is not pernzitted under the
provisions of the code for the property in the district where the affected land is Zocated,
nor would it alter or change the zoning district classification of the property.
The compensatory excavation wiil not change the use of the property. However, the levee is not
pernutted currently since portions of it would be located in the Floodway, and levees are only
permitted in the Floodway "where the intent is to protect individual structures." Once the
compensatory excavation has been completed and approved by FEMA and FEMA has issued its
LOMR, the City will be notified that the floodway boundary has changed. At that time, the City
Council will be asked to rezone the area removed from the floodway from Floodway (RC 1) to
Flood Fringe (RC2) which is necessary for a levee to be permitted. Therefore, the variance for
Page 3 of 41
the levee should be conditioned on rezoning the azea from RCl to RC2. O�— 7 � 7�
6. The request for variance is not based primarily on a desire to increase the value or
income potentiaT of the parcel of land.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
3'7
38
39
40
41
42
43
44
45
46
47
48
49
50
51
The request for variance is based primarily on a desire by MAC to be able to keep Holman Field
open and operating during periods during and after flood conditions as a service to its tenants.
In addition to the findings above, the variances also meet the following findings per Sec. 68.601.
Required for variances in the River Corridor Overlay District:
(a) Applications for varzance to the provisions of this chczpter may be filed as provided in
section 61.600. The burden of proof shall rest with the applicant to demonstrate conclusively
that such variance will not result in a hazard ta life or property and will not adversely affect the
safety, use or srabiliry of a public way, slope or drainage channed, or the natural environment;
such proof may incdude soils, geology and hydrology reports which shall be signed by registered
professional engineers. Variances shall be consisterzt with the general purposes of the standards
contained in this chapter and state law and the intent of applicable state and national laws and
programs. Although variances may be used to modify pernzissible methods of flood protection,
no variance shall have the effect of allowing in any district uses prohibited in that district,
permit a lower degree of flood protection than the flood protection elevation for the particular
area, or pernzit a Zesser degree of flood protection than required by state law.
The variances for slopes and for placement of sheet gile within 50 ft. of the ordinary high water
mark of the river will not resuit in a hazard to life or property once FEMA has approved the
compensatory excavation and issued the L,etter of Map Revision. At that rime, the flood
protection project will be out of the Floodway and will not cause an increase to the regional
flood as determined by FEMA in its Conditional I.etter of map Revision dated 6/14/05. The
compensatory excavation will not adversely affect the safety, use, or stability of a public way,
slope, or drainage channel, or the natural environment. The compensatory excavation will create
a more natural shareline that will be stabilized in part with natural vegetation. This work will
increase the stability of the slopes and enhance the natural environment in the atea of the
excavation. The variances for slopes and location of the sheet pile is consistent with the general
purposes of this chapter, state law, and the intent of state and national laws and programs that
pernut letters of map revision to accoznmodate changing circumstances and the desires of
property owners and to protect developments from flooding. Because the levee/floodwall
project will not be approved until after the affected property has been taken out of the
RCl-Floodway, the variances wiil not allow any uses prohibited in the RC2 Flood Fringe
district, and will result in protecrion of existing development to the 100 year flood event as
required by state law.
Accordingly, the Commission approved the MAC variance requests subject to the following
conditions which were also set forth in Planning Commission Resolution No. OS-17:
1. Work on the Compensatory Excavation cannot begin until MAC obtains
all other required approvals including those from the Army Coips of
Engineers, Minnesota Pollution Control Agency and the Minnesota
Department of Natural Resources.
2. Work on the L.evee / Flood Control System cannot begin until MAC
obtains all required approvals as specified in Section 23 of the Final
Page 4 of 41
2
3
4
6
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
SO
51
Environmental Assessment (December 2005). As part of these approvals,
FEMA must issue a Letter of IvIap Revision for the boundary of the ! ��
floodway and the City Council must approve a revision to the River O s,� —�j i,
Corridor Zoning Map based on FEMA's actions so that a portion of the
airport where the levee would be built is rezoned from RCl (Floodway) to
RC2 (Flood Fringe).
II.
RESOLUTION NO.OS-18 APPROVING THE MAC'S SITE PLAN APPROVAL
REOUEST fZoning File No. 06-0007251
The reguested site plan is consistent with the following:
l. The cily's atlopted comprehensive plan and development or project plans for sub-areas
of the city.
The Land Use Chapter of the Comprehensive Plan, Policy 7.61 states: "MSP and Holman Field
airports are both very important to Saint Paul's economy and quality of life. The City supports
maintaining and improving them in their present locations with full attention to noise
mitigation" The proposed levee/flood wa11 project is consistent with this policy.
The Mississippi River Corridor Chapter of the Comprehensive Plan, Objective 51 states:
"Continue commercial and industrial uses of river conidor ]and and water, consistent with the
Saint Pal Land Use Plan." As stated above, the Land Use Plan supports maintaining and
improving Holman Field in its present location. Objective 6.5 states: "Encourage protection and
restoration of river corridor cultural resources, including historic structures, culturally significant
landscapes, and archaeological and ethnographic resources." As noted previously, the flood
walUlevee project will protect the historic Administration Building from flooding to the 100 year
event. Policy 4.2.2 states, in part: "The City wiil encourage use of native vegetation or other
compatible floodplain vegetafion in redevelopment projects. Where appropriate, when
redeveloping or stabilizing the river's edge, soil bio-engineering techniques and native plantings
will be used in combination with more traditional engineered solutions....° The proposed
compensatory excavation will use native planrings to stabilize the river's edge. The sheet pile
flood wall will be located so as to retain existing vegetation to the greatest extent possible.
2. Applicable ordinances of the City of Saint Paul.
The following ordinance sections apply:
Section 68.402. regulates protection of shorelands, floodplains, wetlands and bluffs in the River
Corridor:
(a). Generullv. Development shall be condzscted so thaz the smallest practical area of land be
developed at any one time and that each area be subjected to as little erosion or flood
damage as posszble during and after development.
(b). Placement ofstructures.
(I). The following minimum set&acks for each class of public waters as described in
Minnesota Regulations NR-82 shall apply to all structures except those specified
as exceptions in subsection (7) below.
Page 5 of 41
a. Far natural environment waters at least two hundred (200} feet from the
normal high water mark for Zots not served by public sewer and �t least one ,
hundred fxfry (1 SO} feet from the ordinary high water mnrk for dats served by ;
public sewers.
This section is not applicable.
(�c-3'.�
b. For general devedopment waters at least seventy-fzve (75) feet from the nornual
hzgh waZer mark for lots not served Try public sewer and at least fifty (SO) feet
from the ordinary high water mark for lots served by public sewer.
The applicant has requested a variance of this standard (see Findings H.1 to H.5).
(2). No commercial or industrial development shall be permitted on slopes greater than
twelve (I2) percent.
The applicant has requested a variance of this standard. (see Findings H.1 to H.5)
(3). No residential development shall be permitted on slopes greater than eighteen (18)
percent.
This section is not applicable.
(4). Bluff development shall take place at least forzy (40) feet landward of all blufflines.
This section is not applicabie.
(S). Transportation, utility and other transmission service faciliaies and corridors shall avoid:
a. Steep slopes;
b. Intrusions into or over streams, valleys and open exposures of water;
c. Intrusions into ridge crests and high points;
d. Creating tunnel vistas; �%
e. Wetlunds;
f. Forests by running along fringe rather than through them. If necessary, to route
through forests, utidize open ttret�s in order to minimize cutting;
g. Soils susceptible to erosion, which would create sedimentation and pollution
problems;
h. Areas of unstuble soils which would be subject to extensive slippages;
I. Areas with high water tables; and
j. Open space recreation areas
This section is not applicable since the aitport is an existing use.
(6). At river crossing points, public facilities, crossing corridors and other rights-of-way
shall be consolidated, so that the smallest area possible is devoted to crossing.
This section is not applicable.
(7). Exceptions.•
Page 6 of 41
2
3
4
5
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
3�
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
a. Locatioa of piers and docks shall be controlled by applicable state and Zocal
regulations.
b. Commercial, industrial or permitted open space uses requiring location on public
waters may be closer to such waters than the setbacks specified in the standard set out in
subsection (3) above.
This section is not applicable.
(c). Grading and fzlling.
o � — l � �
(1). A minimum amount of fzlling shall be allowed when necessary, but in no case
shall the following restrictions on filling be exceeded. Furthermore, fall
opportunzties shall be fairly apportioned to riparian Zandowners. 77xe developer
shall evaluate ownership patterns, configuration and the bottom profcle of each
wetland basin before fzll opportunities are apportioned.
(2). Grading and filling in shoreland areas (when allowable) or any other substantial
adzeration of the natural topography shadl be controCled in accordance with the
following criteria:
a. The smallest amount of bare ground shall be exposed for as short a time as
feasible.
b. Temporary ground cover shall be used.
c. Methods to prevent erosion and trap sediment shall be employed.
d. Fill shall be stabilized.
These standards are met. The size of the compensatory excavation area has been reduced by the
applicant to ensure that the smallest amount of ground shail be exposed. Silt fence and other
measures as needed will be used to prevent erosion and trap sediment. The new shoreline will be
stabilized with rip-rap and native vegetation
(3). Only fill free of chemical pollutants and organic wastes shall be used.
At such time as the levee can be constructed, the applicant will ensure that fill used to construct
the levee will meet this condition.
(4). Total fclling shall not cause the totttl natural flood storage sapaciry of the wezland to fall
below the natural volume of runoff from the wetland and watershed generated by a
100-yeczr storm, as defzned by the National Weather Service. After the affected portion of
the airport property is removed from the Floodway by FEMA, the fzll for the levee as well
as the sheet pile flood walls and temporary flood watls will meet this condition.
(S}. Solid waste dzsposal and landfzll shatd not be pernzitted in the River Corridor District.
The applicant is not requesting these uses.
(6). Development shatl fzt existing topogr and vegetation with a minimum of clearing
and grading.
The applicant is proposing a minimum development that will protect the aiiport to the 100 year
Page 7 of 41
2
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
4Q
41
42
43
44
45
46
47
48
49
50
51
flood event. In times of greater flooding, the airport will be closed. This minimal flood
protection development meets this condition.
(7). No rehabilitation slopes shall be steeper than eighteen (18) percent slope. o � - J ��
The applicant has requested a variance of this standard. (see Findings H.1 to H.5)
(8). Dredging of a shorelartd or wetland shall be allowed only when it will not have adverse
effect upon the wetland. Dredging when allowed shall be limited as follows:
a. It shall be Zocated in the areas of minimum vegetation.
b. It shadl not significantly change the waterflow characteristics.
c. The size of the dredged area shczll be limited to the absolute minimum.
d. Deposit of dredged material shall not result in a change in the current flow, or in
destrttction of vegetation or fish spawning areas, or in water pollution.
These standazds are met by the application. Existing vegetaUon in the area of compensatory
excavation is minimal, and the shoreline has become severely eroded in places. The excavation
is intended to improve water flow characteristics in this part of the channel. The size of the area
affected by the compensatory excavation has been kept to the absolute minimum, and the
applicant has stated that the excavated material will be tested and disposed of properly.
Sec. 68.403. Protection of wildlife and vegetation. Developrnent shall be conducted so as to
avoid intrusion into animal and plant habitats.
(a). No alteration of the natural environment or removal of vegetation shall be permitted
when such alteration or removal would diminish the ability of dependent wildtife to
survive in the Kiver Corridor.
The compensatory excavation and levee construction are not in an area that is cunently habitable
by wildlife. The sheet pile flood wail will be located next to the existing airport road, and the
existing riverward vegetation will be retained far wildlife habitat and screening of the sheet pile
from the river.
(b). No wetland or bduffline vegetation shall be removed or altered except that required for
the placement of structures.
No wetland or bluffline vegetation will be affected by this project. Shoreline vegetation will be
retained,replaced, or added where possible.
(c) Clear cutting shall be prohibiaed except as necessary,�or placing approved publie roads,
utilities, struetures and parking areas.
No clear cutting is associated with this project.
(d) Natural vegetation shall be restored after any construction project.
The applicant will restore native vegetation to the shoreline. No natural vegetation exists in the
area of the airport where the levee will be located. Vegetation riverward of the sheet pile flood
wall will be retained where possible.
Page 8 of 41
_
2
3
4
5
6
7
8
9
10
ll
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
(e) Watering areas necessary for plant survival shall be maintained or provided.
No special requirements are anticipated for plants in the area. ��—
(� Devetopment shall not cause extreme fluctuations of water levels or unnatural changes
in water temperature, water quality, water currents or movements which may have an
adverse impact on endangered or unique species of birds or wildtife.
No fluctuations in waster levels or temperature or water quality wil] result from this project.
Changes to water currents or movements will not have an adverse impact on birds or wildlife.
3. Preservation of unigue geologic, geographic or historically signiftcant characteristics
of the city and environmentally sensitive areas.
The site plan is consistent with the preservation of environmentally sensitive areas. The
Compensatory Excavation will affect 3,000' of shoreline near the south end of the airport.
However, the condition of much of the existing shoreline, which was created with fill, is not
stable: it is steep and being undermined by erosion. There is a row of shrubs approximately 12'
tall at the top of the bank and the area behind it is non-native grass that is mowed. The shoreline
after the Compensatory Excavation would stabilize the shoreline by using a minimal amount of
rip rap and planting native grasses.
The sheet piling that will be built parallel to Bayfield Street about 6' from the edge of the paved
roadway. Because it would be so close to the street, it would have a minimal affect on existing
vegetation and would not be visible from the river because it will be screened by the existing
vegetation.
The site plan is consistent with the preservation of historically sia ificant characteristics of the
city. The ternunal building has been nationally designated as an historic building and the flood
walU levee would help protect it from periodic flooding.
3��
4. Protection of adjacent and neighboring properties through reasonable provision for
such matters as starface water drainage, sound and sight buffers, preservation of views,
light and air, and those aspects of design which may have substantial effects on
neighboring land uses.
The site plan is consistent with this finding. The levee will not increase the level of the rivex
during flood condifions. At one time there were concems that the levee would increase the level
of the river, but this will not happen if the Compensatory Excavation is done to widen the river
channel and increase its capacity.
The levee will not be noticeable from the river. The sheet piling will be well screened by a
existing trees and shrubs along the shQreline.
The Flood Protection System will not cause an increase in air traffic at the airport that would
have substantial effects on neighboring land uses or unreasonably diminish established property
values within the sunounding area.
Page 9 of 41
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39. �
40
41
42
43
44
45
46
47
48
49
50
51
5. The arrangement of buildings, uses and facilities of the praposed devetopment in order
to assure abutting property andfor its occupants will not be unreasanably affected.
� �
The site plan is consistent with this finding. The proposed Compensatory Excavation and levee
will not affect abutting property.
6. Creation of energy-conserving design through landscaping and Zocation, orientation
and etevation of structures.
The site plan is consistent with this finding.
7. Safety and convenience of both vehicular and pedestrian traffic both within the site
and in retation to access streets, including traffic circulation featzcres, the locations
and design of entrances and exits and parking areas within the site.
The site plan will have no impact on vehicular or pedestrian traffic and is consistent with this
finding.
8. The satisfactory availability and capacity of storm and sanitary sewers, including
solutions to any drainage problems in the area of the development.
The site plan is consistent with this finding. MAC is currently making improvements to the
sewer and drainage system for the airport that will accommodate the proposed levee.
9. Suffzcient landscaping, fences, f lood walls and parking necessary to meet the above
objectives.
The site plan as consistent with this finding. Native species would be planted in the area of the
Compensatory Excavation where the shoreline would be widened. The existing shoreline in this
area has shrubs along the shoreline and non-native grass. MAC wants to limit the replacement
planting to native grasses because of concerns that planting new shrubs would provide habitat
for birds that could cause a hazard for aircraft.
Almost all of the exisring landscaping along the shoxeline where the sheet piling is proposed
would be retained would be sufficient to screen the piling from view.
10. Site accessibzlity in accordance with the provisions of the Americans with Disabitities
Act (ADA), including parking spaces, passenger loading zones and accessible routes.
The site plan will have no impact on handicapped accessibility and is consistent with this
finding.
ll. Provision for erosion and sediment control as specified in the '�Ramsey Erosion
Sediment and Control Handbook."
Siit fence will be installed where needed prior to work beginning on the project to ensure that
sediment does not get to the river or a nearby wetland. Staff will require a more detailed plan
for sediment control for the Compensatory Excavation prior to a permit far this work being
issued. The project must also obtain an NPDES pernut from the MPCA that will also address
these issues.
Page 10 of 41
Accordingly, the Comtnission agproved the MAC site plan request subject to the following
conditions which were also set forth in Planning Commission Resolution No. OS-18: p� � o �
� �s J'v's
4 1. Work on the Compensatory Excavation cannot begin until MAC obtains all
5 other required approvais including those from the Army Corps of Engineers, _
6 Minnesota Pollution Control Agency and the Minnesota Department of Natural
7 Resources.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
2. Work on the Levee ( Flood Control System cannot be begin until MAC
obtains all required approvals as specified in Section 2.3 of the �inal
Environmental Assessment (December 2005). As part of these approvals, FEMA
must issue a Letter of Map Revision for the boundary of the floodway and the
City Council must approve a revision to the River Corridor Zoning Map based on
FEMA's actions so that a portion of the aiiport where the levee would be built is
rezoned from RCl (Floodway) to RC2 (Flood Fringe).
WHEREAS, Pursuant to the provisions of Leg. Code § 61.702(a), the Friends of the
Parks and Trails of Saint Paul and Ramsey County, The Friends of the Mississippi River, and the
Audubon Society, on or about March 3, 2006, in Zoning File No. 06-051296, duly filed an
appeal from the said determinations made by the Commission and requested a hearing before the
City Counci] for the purpose of considering the actions taken by the Commission; and
WHEREAS, Acting pursuant to Leg. Code § 61.702(b) and upon notice to affected
partles, a puhlic hearing was duly conducted by the Saint Paul City Council on April 5, 2006,
where all interested parties were given an opportunity to be heard; and
WHEREAS, The Council, having heard the statements made, and having considered the
application, the report of staff, the record, minutes and resolution of the Commission and its
Zoning Committee; does hereby
RESOLVE, That the Council hereby finds the following enors in the facts and findings
of each of the respective decisions of the Planning Commission in this matter, based on the
following findings of the Council:
I. THE COMMIS$ION'S DECISION TO GRANT VARIANCES TO THE MAC AS
SET FORTH IN COMMISSION RESOLITI'ION No. OS-17. IS IN ERROR FOR
THE FOLLOWING REASONS:
(a) The properly in question can be put to tt reasonable use under the strict provisions of
the code.
The airport at Holman Field has been in operation sinoe 1929 without the protection of a flood
wall. It continues to operate today without the protection of a flood wall. The property has been
and continues to be put to a reasonable use under the strict provisions of the code. Excavafion of
steep slopes and the encroachment of a floodwall within the ordinary high water level aze
unnecessary to put the property to a reasonabie use.
According to MAC's own records, floods have closed the airport 210 days during the past 50
years. That is an average of less than 3 days out of every 365 days of operation, ar All% of the
total days of operation.
Page 11 of 41
Construction of the proposed flood wall would have protected the airport during only 148 of
those days, as the other 62 days were closures related to floods with intensity greater that the
100-yeaz flood. Construction of the flood wal] would have provided protection for .0081% of
4 the total days of operation at the airport.
Ob-3�3
6 Airports, by the very nature of their complex operations, are susceptible to closures related to
7 external factors such as inclement weather. It is reasonable to assume a limited amount of
8 closure related to naturai occunences. This does not mean that the property cannot be puf to a
9 reasonable use under the strict provisions of the code.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
(b) The plight of the landowner is not due to circumstances unique to the property, and
these circumstances were not created by the landowner.
Hoiman Field is located immediately adjacent to the Mississippi River in a floodplain. Flooding
in the floodplain is not unique and is to be expected as a natural part of river ecology. Plooding
and high water levels are common circumstances for property along a river, and therefore are not
unique to the Holman Field property.
Holman Field's location on the floodplain is well known as to MAC as the time it assumed
operations at Holman Field in 1943. MAC could have chosen to site a reliever airport outside of
the floodplain and therefore could have a reasonable expectation to be free from flooding.
However, MAC chose the Holman Field site with knowledge that it was in the floodplain and
therefore, it is not reasonable to expect that the site will be free from flooding at all times. In
fact, even with consuuction of the proposed flood wall, MAC cannot expect that this property
will be free from flooding during flood events with greater than the 100-year flood intensity.
Because there is nothing unique about this floodplain property, there is no reason to grant slope
variances or allow construction within the ordinary high water level.
(c) The proposed variance is not in keeping with the spirit and intent of the code, and is
inconsistent with the health, safety, comfort, morals and welfare of the inhabitants of
the city;
The City of Saint Paul adopted the River Corridor Overlay Distz7ct (Leg. Code Chap. 68)and its
subclassifications to provide comprehensive floodplain and river bluff management for the city
in accordance with the pQlices of Minnesota Statutes (Chapters 103 and ll6C's), MinnesoYa
Regulations (NIEQC 54) and Governor's Executive Order No. 79-19. I.eg. Code § 68101(a).
The purpose of the Overlay District is set forth in I,eg. Code § 68101(b)(1-8).
The Council finds that the variances approved by the Commission are inconsistent with L,eg.
Code §§ 68.101(b)(1),( 2), (3),(5),( 6), and (8):
(1) To protect and preserve the Mississippi River Corridor as a unique and
valuable resource for the benefit of the health, safety and welfare of the citizens
of the city and the state;
(2) To prevent and mitigate irreversible damage to the Mississippi River Corridor;
(3) To protect and preserve the Mississippi River Corridor as an essential element
in the federal, state, regional and local recreation, transportation, sewer and water
systems;
(5) TQ protect and preserve the Saint Paul Mississippi River Coiridor's biological and
ecological functions;
(6) To preserve and enhanee tha Saint Paul Mississippi River Corridor s aesthetic,
Page 12 of 41
�
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
cultural, scientific and historic functions;
(8) To guide floodplain development in order to lessen the adverse effects of C
floods, but not to reduce or eliminate flooding. o Cj — 3 U 3
The Council finds that a sheet metal flood wall that will rise 8-14 feet above the terrain for a
distance of 9,635 feet and that will be constructed within 50' of the ardinary high water mark
along the riverbank will not protect and preserve the Mississippi River Corridoi as a unique and
valuable resource for the ciUzens of the city and the state.
The Council finds that the removal of 560 acres from the Mississippi River floodplain and the
excavation of 155,000 cubic yards of riverbank, will allow significant, lasting, and potentially
detrimental changes to the Mississippi River Corridor that may irreversibly damage the river's
natural ecological funcrions.
The river should be viewed as a whole system. Rivers function as complex ecosystems. All
areas of a river including floodway, floodplain and flood fringe form a complex physical and
biological system that supports a variety of natural resources and provides natural flood and
erosion control.
"In a mutually supportive cycle, the living and nonliving parts of natural
floodplains interact with each other to create dynamic systems in which each
component helps to maintain the characteristics of the environment that supports
it These systems of interacring parts of the physical and biological worlds aze
called ecosystems. Together, these parts of the floodplain ecosystem function to
store and convey floodwaters, protect water quality, prevent erosion, and maintain
ricb habitats for fish and wildlife. In recognizing the relationships between the
hydrological, geological, and biological features of these systems, we can begin to
understand how changes to one feature can alter the entire system in significant
ways." (Protecting Floodplain Resources, FederalInteragency Floodplain
Management Task Farce)
Even though Hoiman Field is viewed by some as a non-ecologically functioning floodplain, it
still plays important floodplain functions including providing for flood storage and conveyance;
reducing flood velocities; reducing peak flows; reducing sedimentation; and moderating
temperature functions.
"The loss of natural floodplain functions in heavily developed areas not oniy
impedes flood storage, but also increases erosion and reduces the mitigating
effects that vegetated azeas can have on the pollu5on of waterways.° (Protecting
Floodplain Resources, Federal Interagency Floodplain Management Task Force)
"Vegetation loss and excessive runoff within the floodplain can also cause
increased erosion and sedimentation, which may cover spawning areas and bury
food sources in streams. L,oss of vegetation also removes sources of shelter and
food for wildlife, and human-made structures may present barriers to migration
and reproductive activity." (Protecting Floodplain Resources, Federal Interagency
Floodplain Management Task Force)
The Council finds that a sheet metal flood wall that will rise 8-14 feet above the tenain for a
distance of 9,635 feet and that will be constructed within 50' of the ordinary high water mark
along the riverbank will cut off this portion of the river from the potential to be connected to a
Page 13 of 41
continuous trail system and eliminates an essential element of plans for federal, state� r ion 3
and local recreation.
4 The Council finds that a sheet metal flood wall that will rise 8-14 feet above the terrain for a
5 distance of 9,635 feet and that will be conshucted within 50' of the ordinary high water mark
6 along the riverbank would also be detrimental to the natural aesthetic character of the river and
7 impede views from, on, and along the river and from natural areas, such as the Bruce Vento
8 Nature Sanctuary and Mounds Pazk, which are adjacent to Holman Field.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
The Council finds that variances which will allow for slopes greater that 1$% and constmction
within 50' of the ordinary high water mark will make it difficult, if not impossible to provide
vegetation or other natural elements that could otherwise screen the aesthetic blight of the flood
wall.
The Council finds that even if a sheet metal flood wall that will rise 8-14 feet above the terrain
for a distance of 9,635 feet and that will be constructed within 50' of the ordinary high water
mazk along the riverbank might lessen the adverse effects of floods, the small benefit provided
by the flood wall does not outweigh its negative impacts on the river comdor such that granting
variances would be inconsistent with the overall spirit and intent of I.eg. Code § 68.101(b)(1-8).
The Council also finds that the granted variances aze inconsistent with the spirit and intent of
adopted plans for the River Corridar. The CounciPs rational supporting its findings of error are
more fully set forth in its reasons for denying the site plan which appears in subsequent pages of
this resolution. For the putpose of brevity, the Councii refers to the rational in the subsequent
pages and lines of this resolution as noted for each strategy or objecUve set forth below.
(A) The applicafion is inconsisten2 with the Misssssippi River Corridor Plan Chapter of the Saint
Paul Comprehensive Plan inctuding the plan's following strategies and objectives:
Strategy 1: Protect the River as a Unique Urban Ecosystem
Objective 4.2: Preserve and restore native plant and animal habitats.
See Page 21, Lines 28-43.
Objective 4.3: Protect and preserve floodplain and wetland areas in the City.
See Page 21, Lines 47-51 and Page 22, Lines 1-20.
Strategy 3: Enhance the City's Quality of Life by Reconnecting to the River
Objective 6.1: Enhance opportunities for recreational use of the riverfront by
local visitors and tourists, utilizing parks, open space and physical access to the
river.
See Page 22, Lines 24-31.
Objective 6.2: Preserve and improve existing views to the river and bluffs, and
develop new ones.
See Page 22, Lines 36-43.
Page 14 of 41
Objective 6.3: Provide a continuous, safe pedestrian and bicycle traiZ along both
sides of the river that is connected to the city and regional trail system. O� L a
GJ
See Page 22, Lines 48-50, and Page 23, Lines 1-2.
Strategy 4: Use Urban Design to Enhance the River Corridor's Built Environment
Objective 7.2: Consistent with an urban setting, the design of new buildings
should reflect the river corridor's natural character and respond to topography
by preserving critical public views.
See Page 23, Lines 10-16.
(B) The application is inconsistent with Land Use Chapter of the Saint Paul Comprehensive Plan
including the plan's following objectives:
Objective 4.I: Saint Paul on the Mississippi Development Framework
Irrcplementation.
See Page 23, Lines 37-49 and Page 24, Lines 1-9.
Objective b.2: River Corridor Development.
See Page 24, Lines 13-46.
Objective 7.1: Mississippi National River and Recreation Area (MNRRA) Tier II
Status.
See Page 24, Lines 50-51 and Page 25, Lines 1-27
Objective 7.2: Topographic Features and Sensitive Resources.
See Page 25, Lines 31-50 and Page26, Lines 1-20.
Objective 7.6: Airports andAirportNoise.
See Page 26, Lines 224-51 and Page27 Lines 1-35.
Objective 7.8: Visual Beauty.
See Page 27, Lines 39-48.
(C) The application is inconsistent with the Sztimmary and General Polzcy Chapter of the Saint
Paul Comprehensive Plan fncluding the following General Policies:
GPI: Ten Principles for City Development.
See Page 86, Lines 7-39.
GP2: Topography and Natural Environment.
Page 15 of 41
See Page 28, Lines 43-51, and Page 29, Lines 1-8.
GPIS: RiverCorridor.
See Page 29, Lines 12-25.
GP78: Open Space and River Connections.
See Page 29, Lines 29-38.
06-3�3
(D) The application is inconsistent with the Parks and Recreation Chapter of the Saint Paul
Comprehensive Plan including the following objectives:
Objective 1: Encourage protection, preservation, and regeneration of the ciry's open
space and natural resources.
See Page 29, Lines 46-51 and Pages 30, Linesl-18.
Objective 2: Expand plrysical and visual access to the River.
See Page 3Q Lines 37-51, and Page 31, Lines 1-13.
Objective 3: Develop park and open space connections.
See Page 31, Lines 17-24.
(E) The application is i�consistent with the Saint Paul on the Mississippi Development
Framework including the following goals:
Chapter 1 Environmensad Cantext
Goal 1: Strengthen Saint Paul's identity by reinforcing its topography and natural
environment.
See Page 31, Lines 34-49 and Page 32, Lines 1-7.
Goal 2: Protect, restore and reinforce native vegetation.
See Page 32, Lines 11-26.
Goal 3: Develop creative design altemutives for river edge trearnzents.
See Page 32, Lines 30-46.
Chapter 4 Public Realm.
Goal 1: Provide easily recognizable and accessible connections between downtown Saint
Paul, the riverfront and the city-wide and regional open space trail systems.
See Page 33, Lines 1-3.
Page 16 of Al
Goal 2: Recognize and take fudl advantage of the historic and recreational sagnifacance
of Saint Paul's parkway and trail corrtdor system.
See Page 33, Lines 8-12. ��°,y —�j � 5
Goal 3: Build on existing initiazives to establish an urban greening policy for downtown,
riverfront and river bonom areas.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
S1
See Page 33, Lines 17-22.
Goal 8: Protect and enhance the environmental and aesthetic quality and integrity of
Saint Paul's natural features.
See Page 33, Lines 21-41, and Page 34, Lines 1-9.
F) The application is inconsistent with the National Park Service Mississippi National River and
Recreation Area (MNRXA) Comprehensive Management Plan including the following concepts:
See Page 33, Lines 43-51, and Page 34, Lines 1-9.
G) The MAC's site plan and variance applications are inconsistent with the following additional
City ordinances: Leg. Code §61.301(a) and Leg. Code § 301(b).
Both ordinances pernut, in pertinent part, "A person having an ownership or leasehold interest in
the subject land ...(contingent included)" to apply to the City for a site plan review
(§ 61301(a)) or a variance (§ 613Q1(b)). The appellant's generally have called the MAC's
ownership of the land needed for this project into question. The City has researched the
appellant's claim and has concluded that the MAC lacks an ownership or leasehold interest in at
least some of the land which MAC proposes to develop with the flood wall. Tn particular, the
MAC has not demonstrated an ownership or leasehold interest, contingent or other,vise, i.n the
lands where the MAC has proposed to make compensatory excavations. The ownership records
available to the City show the land under the ownership of the Saint Paul Port Authority.
Therefore, the MAC's application for site plan review as well as its application for variances
fails to meet the general appiication and review procedure required under Leg. Code §§
61.301(a) and .301(b). Because the land in question abuts the Mississippi River and land along
the river as well as the river itself is subject to movement, a report on the title of all the lands
necessary for this project, including but not limited to a survey of all the land on which the flood
wall will be located, is necessary to establish MAC's ownership in order to comply with the
general application and review procedure required under Leg. Code § 61301(a) and 301(b).
(d) The proposed variance will not impair an adequate supply of light and air to adjacent
property, but it may alter the essential character of the surrounding area or
unreasonably diminish established property values within the surrounding area;
There was significant discussion at the Plannang Commission and testimony from surrounding
neighbors regarding the effects of aiiport noise on the essential character of the surrounding area
and property values as they relate to the request for variances for the construction of a perimeter
dike at Holman Field.
According to most established literature on the effects of airport noise on residential property,
increased air traffac will have a detrimental effect on surrounding property values (See materials
Page 17 of 41
1 subznitted to the planning commission including: The Impact of Aiiport Noise on Residential
2 Real Estate, by Randall Bell, MAI; Meta-Analysis of Airport Noise and Hedonic Property ,,�
3 Values: Problems and Prospects, by Jon P. Nelson of the Department of Economics at
4 Pennsylvania State Uni�iersity; and The Effect of Airport Noise on Housing Values: A Summary
5 Report (September 15, 1994) conducted by the Federai Aviation Administration by Booz-Allen
6 & Fiamilton Inc.)
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
While none of these studies are specific to Holman Field, they point to a consistent lowering of
property values in azeas that experience significant airport noise. It is reasonable to conclude
that increased air traffic, and therefore increased noise, at Holman Field related to the granting of
the variances for the construction of the perimeter dike wili have a negative impact on the
property values of sunounding impacted neighborhoods.
MAC has provided no specific information indicating that air traffic will not increase at Holman
Field if the airport is considered secure from flooding. In fact, the cost/benefit analysis (CBA)
dated November 4, 2QQ5 wnducted by HNTB for MAC lists the projected number of operations
at Holman Field increasing in annual aircraft operations from 134,377 in 2008 to 256,280 in
2057. This increase in operations is provided as justification for the cost of the project.
MAC indicates that a benefit of the new dike would be an "Increase in safety at Minneapolis-St.
Paul International Aiiport (MSP) by allowing St. Paul Downtown Airport to fulfill its intended
system role of relieving MSP of significant levels of general aviation traffic." (Perimeter Dike
St. Paul Downtown Airport Briefing Paper, April 11, 2002)
Included in the Planning Commission record is a letter from Dorsey & Whitney LLP, writing on
behalf of Northwest Airlines, November 13, 20�2, who state flafly "If the dike is constructed,
Holman Field will be more attractive to potential customers since it may provide a stronger
measure of flood protection." They also fault the EAW for the perimeter dike for failing to
assume that there will be no increase in airport use following completion of the project. In fact
they state: "This assumption is completely unwarranted, particularly in light of Holman Field's
role as a reliever airport, and pending proposals to limit the use of other reliever airports. The
EAW runs counter to the evidence, and any reliance thereon is arbitrary, capricious or an abuse
of discretion." (Dorsey & Whitney LLP letter to Gary Warren, November 13, 2002)
While airport noise at Holman Field decreased slightly during the 1990's wit}� the phase- in of
stage 3 aircraft and changes to the military fleet, airport noise is on the rise again. Noise zone
maps in the 1992 and 2002 Airport Comprehensive Plans show an increase in the noise zone
from 1998 projected out to 2020 with the proposed construction of the perimeter dike.
The 2000 Airport Comprehensive Plan also predicts an increase in the areas that would be
affected by aiiport noise. The area affected by 60DNL is projected to increase by 248 acres in
2020. The azeas affected by 65DNL are projected to increase by 141 acres. The area affected by
70 DNL is projected to increase by 57 acres and the azea affected by 75DNL is projected to
increase by 65 acres. These projections show an increasing area that will be affected by airport
noise.
MAC's projections also indicate a change in the mix of aircraft that would use the airport if the
perimeter dike were constructed. Exhibit 2C in the MAC 2000 Comprehensive Plan indicates
that jets will go from 27% of traffic operations in 1998 to 33% of operations in 2020.
Multi-engine aircraft are projected to go from 17% of traffic operations in 1998 to 24% in 2020.
Jets and multi-engine aircraft are considered to generate more noise than other aircraft.
`_��3
Page 18 of 41
1 The MAC Dayton's Bluff Noise Monitoring Summary 10l15f2001-10/22(2001 relies on a� U–�'^� �j �
2 "noise averaging" method to make the determination that noise levels from operations associated
3 with the St. Paul Downtown Airport aze not of a significant nature. As Mr. Bell's article points
4 out, certain "noise averaging" methods are considered controversial because they tend to assia
5 noise categories inconsistent with communities' actual noise status. (pg. 319-320) Instead, he
6 concludes that "single event dBL should be considered cazefully" in deternuning appraised
7 value. (pg. 321) The Dayton's Bluff Noise Monitoring Summary regularly recorded operations
8 creating 76.8 dBL to 88.1dBL.
10
11
12
13
14
15
16
1�
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
MAC has not proposed any plans to mitigate increased airport noise in the neighborhoods that
will be affected and airport noise mitigation is incompatible with the Dayton's Bluff Historic
District Guidelines.
It is reasonable to conclude that the granting of variances for the purpose of constructing a
$46,825,000 flood wall has as its ulfirnate goal the increase in air traffic at the airport, rather than
increasing operational days an average of .0081%, and therefore a negative effect on surrounding
property values.
The Council finds that granting the variances will also alter the essential character of the area.
As discussed above, the variances necessary to construct this flood wall will have a detrimental
effect on the ecological functioning of the river; a negative effect on the aesthetic nature and
views from the river and surrounding properties; and limit the recreational opportunities
envisioned by River Corridor
Overlay District.
MAC has provided no plan to address the visual effects of a 9 foot, sheet-metal flood wall that
will rise 9 feet over grade for 5,531 feet along the river bank. The MAC has indicated that the
flood wa11 will be screened by exisdng scrub trees and shrubs along the shoreline. The council is
skeptical that the existing vegetation will survive the construction necessary to install the flood
wall. The council is also skeptical that the existing vegetation is sufficient to buffer the visual
affects of the flood-flood wall on views from the river and the surrounding property, including
the Bruce Vento Nature Sanctuary and Mounds Park.
No plan has been submitted by the MAC to address the visual impact of a rusting sheet metal
flood wall on views from the river and sunounding property.
No plan has been submitted by the MAC to address vandalism to the sheet metal flood wall
which is likely to be an attractive nuisance.
No plan has been submitted by the MAC to discuss the visual impacts of 5,000 square feet of rip
rap from the river and surrounding property.
Objective 6.2 of the Mississippi River Corridor Plan indicates that the City should work to
preserve and improve existing views to the river and bluffs, and develop new ones. This
objective recognizes that various forms of public visual access to the river consist of scenic river
views, extended view corridors, overlook points, observation platforms, bridge crossings,
bridgeheads and bluff stairways. It recognizes that views both from the river and over the river
are important public amenities and should be protected.
Page 19 of 41
�
2
�
0
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
No plan has been submitted to address the visual impact of a rusting sheet metal flood wall o �
views from the river and surrounding property. �(` — �j �j 3
No plan has been submitted to address vandalism to the sheet metal flood wall which is likely to
be an attractive nuisance.
No plan has been submitted to discuss the visual impacts of 5,000 square feet of rip rap from the
river and surrounding property.
(e) The variance, if granted, would pernzit a use that is not permitted under the provisions
of the code for the property in the distrzct where the a,ffected land is located, and it
would alter or change the zoning district classifzcation of the property;
The property for which the variances aze requested is currently zoned RCl. Sec. 68.214 (h) of
the zoning code, which indicates the standards far conditional uses in the RC1 Floodway
District, states:
"Community-wide structural works for flood control intended to remove azeas
from the regulatory floodpiain shall not be allowed in the floodway."
Therefore, the flood wall is not an allowed use in an RCl district.
FEMA has issued a Conditional L.etter of Map Revision (CLOMR), indicaring that it will revise
the flood maps if the compensatory excavation is allowed to proceed forward. This, in essence,
changes the designation of the area to RC2, which would need to be officially re-zoned by the
City Council to be consistent with the flood maps.
Clearly, the granting of the variances for the compensatory excavation is not allowed in the
district where the affected land is located and the granting of the variances would alter and
change the zoning district classification of the property.
(� The request for var is based primarily on a desire to increase the value or income
potential of the parcel of land.
MAC's interest in seeking the variances for the construction of a flood wall is based on a desire
to ensure the airport remains free from floods and therefore is more attractive to additional
tenants and air traffic. MAC's own BenefiUCost Analysis far the project highlights this
relationship to justify the cost of the project.
IL THE COMMI5SION'S DECISION TO APPROVE THE MAC'S PROPOSED
SITE PLAN AS SET FORTH IN COMMI5SION RESOLITI'ION No. OS-18 IS
ERRONEOUS FOR THE FOLLOWING REASONS:
(1) The citp's adopted comprehensive plan and development or project plans for
sub-areas of the city.
The Planning Commission erred in deternuning that the site plan is consistent with the city's
comprehensive plan and development of project plans for sub areas of the city. The city has
done extensive planning over the past decade for the river corridor, which is considered a
valuable, irreplaceable asset. As stated by Steve Johnson of the National Park Service at the
public hearing on April 5, 2006,
Page 20 of 41
r
1 "The Mississippi River is more than 2,300 miles long, but when Congress decided
2 to make a portion of the river part of the national park system, it chose only this
3 glace, a 72-mile segment that includes Saint Paul. Of all of the length of one of
4 the world's greatest rivers, only here is there the convergence of outstanding
5 geology, history and natural resources worthy of national park system
6 designation."
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
C� �- 363
The importance of this resource to the citizens of Saint Paul is reflected in the many strategies
and objectives related to the river corridor outlined in the city's comprehensive planning
documents. The Council finds that the planning commission did not adequately review all
pertinent references to the protection and enhancement of the river corridor and therefore eired
in determining that the site plan is consistent with the comprehensive plan and development of
project plans for sub areas of the city.
A) The City Council finds that the application is inconsistent with the Mississippi River Corridor
Plan Chapter of the Saint Paul Comprehensive Plan including the plan's following strategies
and objectives:
Strategy 1: Protect the River as a Unique Urban Ecosystem
Objectzve 4.2: Preserve and restore native plant and animal habitats
This objective states the importance of preserving and restoring native plant and animal habitats
to create a connected greenway for migrating songbirds and improve the ecology of the
Mississippi valley in Saint Paul. This objective includes a strategy which indicates that the city
will continue to enforce the 50-foot shoreline setback for structures and will support efforts to
restore the shoreline to a more natural character within 100 feet of the river to facilitate wildlife
movement and improve aesthetics.
The construction of a 5,531 foot sheet metal flood wall that will have little setback from the river
bank in some areas will remove native plant and animal habitats and preclude any form of
habitat restoration.
MAC has indicated that they plan to replant the other areas along the flood wall with native
grasses and plants which aze not conducive to attracting birds, as these aze inconsistent with
airport operations. This is inconsistent with the goal of creating a connected greenway for
migrating songbirds and other wildlife.
Questions have been raised about the adequacy of MACs terrestrial survey for endangered
species which was conducted during December. To date, no detailed report on the survey has
been made available to the City Council, the Planning Commission, or other interested agencies.
No aquatic survey has been done to date and questions have been raised about the possibility of
the site of the compensatory excavation including habitat for Higgins Eye Pearly Mussels, a
federal and state identified endangered species.
Objective 4.3.• Protect and preserve floodplain and wetland areas in the City
The area of the proposed flood wall and compensatory excavation is currently zoned R-1
floodway. While Holman Field is viewed by some as a non-ecologically functioning floodplain,
it stiil provides important floodplain functions including providing for flood storage and
conveyance, reducing flood velocities, reducing peak flows, reducing sedimentation and
moderating temperature functions. The MAC has indicated that the compensatory excavation
Page 21 of 41
2
3
4
5
6
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
34
40
41
42
43
44
45
46
47
48
44
50
51
will mitigate some of these concerns. Changes to one feature can alter the entire system in
significant ways. Vegetation loss and excessive runoff within a floodplain can cause ancreased r1
erosion and sedimentation, which may cover spawning azeas and bury food sources_ L.oss of «
vegetation also removes sources of shelter and food for wildlife. New structures may present
barriers to migration and reproductive activity. The Mississippi River Corridor Plan
contemplates these concerns, indicates that our understanding of these natural features continues
to evolve, and therefore calls for careful planning and management.
There have been several wetland areas identified which are in close proximity to the proposed
location of the flood wall. At one time, the plan for the flood wall involved the filling of one
wetland, however, MAC now indicates that the flood wall will not disturb any weflands, but will
run adjacent to identified wetlands. MAC has not provided a survey to the City Council to
identify the exact locarion of the flood wall nor the exact location of wetlands, so it is not
possible to ascertain whether the MAC's assertions are conect.
There have been no reports provided by the MAC to the City Council to indicate the effects of
the flood wal] on adjacent wetlands. For instance, how does the change of river flow impact the
adjacent wetland areas and their ability to support natural flora and fauna. Without more
specific information about steps to protect these valuabie azeas, it is impossible for the Council
to ascertain the impact of the flood wall on adjacent wetlands.
Strategy 3: Enhance the City's Quality of Life by Reconnecting to the River
Objective 6.1: Enhance opportunities for recreational use of the riverfront by local
visitors and tourists, utilizing parks, open space and physical access to the river.
This objective highlights the picturesque, natural environment of Saint Paul's river corridor
which provides desirable open spaces for city residents and tourists to play and relax.
A sheet pile flood wall of 5,531 feet in length rising up to 22 feet above the water would cut off
physical access to the river and mar the aesthetic natural beauty that attracts recreationai use of
the riverfront by visitors and tourists.
Objective 6.2: Preserve and improve existing views to the river and bluffs, and develop
new ones
This objective highlights t}�e importance of visual access to the river and recognizes the
importance of various forms of visual access including extended view corridors, overlook points,
observation platforms, bridge crossings, bridge heads and bluff stairways.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
will profoundly change how people on the water see Saint Paul. It will also detrimentally affect
an important view corridor and significantly affect views from the Samuel Morgan Trail, the
Bruce Vento Nature Sanctuary, Indian Mounds Park and other public lands.
Objective 6.3: Provide a continuous, safe pedestriara and bicycle trail along both sides of
the river that is connected to the city and regional trait system
This objective contemplates a continuous, safe pedestrian and bicycle trail on both sides of the
river to provide the public increased access to the river corridor. Plans for near the airport
include on-street bike lanes.
b-363
Page 22 of 41
2
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
will effectively cut off any access to the river from planned bicycle and pedestrian trails.
0�-363
Strategy 4: Use Urban Design to Enhance the River Corridor's &uilt Environment
Objective 7.2: ConsisTent with an urban setting, the design of new buildings should
reflect the river corridor's natural character and respond to topography by preserving
critical public views
This objective recognizes that in the river corridor, scale becomes important as it relates to
topography, views and the surrounding urban fabric. It calls for the preservation of public views
both of the river from the city and from the river back to the city.
The proposed sheet metal flood wa115,531 feet in length, rising up to 22 feet above the water
will be out of scale with the surrounding topography and will completely block views both of the
river from the city and from the river back to the city.
Objective 7.3: Design Study for River Corridor Redevelopment Sites
While the specific redevelopment sites anticipated by this study do not include Holman Field,
the study's goals were to consider the scale of new development and to create design guidelines
that met the spirit and intent of MNRRA and Critical Area Requirements. The study indicated
that ideally new development should provide greater public access to the river, preserve
significant public views, improve storm water and the urban forest on site, and reinforce and
complement the surrounding urban fabric.
The proposed sheet metal flood wall 5,531 feet in length, rising up to 22 feet above the water
will cut off public access to the river, impede significant public views of the river and from the
river, diminish the possibility of natural urban forest restoration on the site, and be out of sync
and scale with the surrounding urban fabric.
B) The City Council finds that the application is inconsistent with Land Use Chapter of the Saint
Paul Comprehensive Plan including the plan's following objectives:
Objective 4.1: Saint Paul on the Mississippi Development Framework Implementation
This objective calls for, among other things, re-greening of the downtown river valley; bringing
people to the riverbanks and bluff lines; connectivity, or complementarity of each land use with
others nearby; and designing streets to accommodate transit, bikes and pedestrians as well as
cars.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will preclude the re-greening of the downtown river valley and
be in conflict with plans to create a connected greenway for migrating songbirds and improve the
ecology of the Mississippi valley in Saint Paul.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will prevent connection with the riverbanks and provide an
impediment to views of the bluff lines from the river.
Page 23 of 41
1 The proposed sheet metal flood wail of 5,531 feet in length, rising up to 22 feet above the water
2 with as little as 0 feet of setback is designed to cut off connectivity with the river and does not
3 complement the adjacent land uses of the Bruce Vento Nature Sanctuary, the Samuel Morgan
4 Trail, and Indian Mounds Park. O�j — 3� 3
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
3$
39
40
41
42
43
44
45
46
47
48
49
50
51
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will preclude the connection with the river of planned on-street
bike lanes near the airport. Plans call for continuous, safe pedestrian and bicycle traii on both
sides of the river to grovide the public increased access to the river corridor.
Objective 6.2: River Corridor Development
This objective indicates a community intention to °return to the river" in contrast to recent
decades where the river's ecology and dramatic geography were lazgely ignored by industrial
development. This objective calls far a high priority on appropriate management of the river
corridor with changes consistent with enhancement of the corridor's natural ecology; improved
public access and recreational uses throughout the corridor; continuation of industrial uses with
modifications or additions to industrial use when they have no adverse impact on water quality
or air quality far the corridor and adjacent neighborhoods and when they do not substantially
impair the visual character of the corridor from adjacent neighborhoods or from the river itself;
and new development in the floodplain or within 300 feet of the ordinary high water mark should
have a relationship to the river, a need for river location andlor enhance the river environment.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback and the removal of 155,000 cubic feet of river bank is not
consistent with enhancemant of the corridor's natural ecology.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will preclude increased public access to the river and hamper
the ability to enjoy the visuai beauty of the river for recteational purposes. The addition of this
proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water with
as little as 0 feet of setback will substantially affect the visual character of the corridar from
adjacent neighborhoods and from the river itself.
The cost/benefit analysis (CBA) dated November 4, 2005 conducted by HNTB for MAC lists the
projected number of operafions at Holman Field increasing in annual aircraft operations from
134,377 in 2008 to 256,280 in 2057. This increase in operations is provided as justification far
the cost of the project. This increase in air traffic related to the creation of the flood wall will
have an impact on air quality for adjacent neighbors and could potentially have an adverse
impact on water quality far the river.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback and the removal of 155,000 cubic feet of river bank is cieazly
within the floodplain and within 300 feet of the ordinary high water mazk. The proposed flood
wall will sever a relationship with the river and wili not enhance the river environment
ecologically or aesthetically.
Objective 7.1: Mzssissippi National River and Recreation Area (MNRRA) Taer II Status
This objective calls for continued enforcement of bluff, shore land and wetland protection
measures which prohibit development on steep slopes, require setback from bluff lines and
Page 24 of 41
2
3
4
5
6
7
9
10
il
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2b
27
28
39
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
water, and limit aiterafion of the natural environment. The objective also calls for preserving
native plants, wiidlife and archeological sites, careful planning for a 300-foot shore line zo��
increasing natural landscaping along shorelines, bluffs and bluff crests; reducing storm wafer `
runoff and chemical runoff; identifying incentives for industrial land on the river to be used by
businesses that need a river location; increasing tourism and re�reationa] uses of the river and
improving public access to the river.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback is inconsistent with the enforcement of the prohibition of
development of steep slopes and in fact the proposed flood wall is seeking variances for
impacting and creating slopes greater than 18%.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as littie as 0 feet of setback and the removal of 155,000 cubic feet of river bank would
clearly encroach on the 300-foot shoreline zone.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback and the removal of 155,400 cubic feet of river bank will
interfere with increasing the natural landscaping along the shoreline.
Ho1man Field airport is not an industrial use that needs a river location. While the airport has
been located in the river corridor for many yeats, there is nothing specific to its operation that
requires expansion in a river location.
The proposed sheet metal flood wall of 5,531 feet in lengt}�, rising up to 22 feet above the water
with as little as 0 feet of setback wili sever public access to ihe river and reduce the aesthetic
enjoyment of the river for tourists and recreational users of the river.
Objective 7.2: Topographic Features arzd Sensitive Resources
b-3b3
This objective indicates that the City will integrate its land use plans with the work of the DNR's
metro regional Greenways and Natural Areas Collaborative. The collaborative has identified
high quality native habitat remnants and is seeking funding to link the remnants into greenways
which will provide conrinuous habitat comdors to support native plant species and wildlife and
improve park and trail systems. Holman Field is characterized as "Very High" sensitivity.
This objective also calls for the reconnection af neighborhoods to the Mississippi River visually
with natural landscaping along ravine edges and along bluffs facing the river valley; the
restoration of surface water systems including ponds, weUands and streams; completion of the
parkway and trail system to provide access to the river valley; Realtors and neighborhood
marketing groups to highlight beautiful views of the river from adjacent communities.
The construction of a 5,531 foot sheet metal flood wall that will have little setback from the river
bank in some azeas will remove native plant and animal habitats and preclude any form of
habitat restoration.
MAC has indicated that they plan to replant the other areas along the flood wall with native
grasses and plants which are not conducive to attracting birds, as these are inconsistent with
airport operations. This is inconsistent with the goal of creating a connected greenway for
migrafing songbirds and other wildlife in this sensitive azea of the river.
Page 25 of 41
There have been several wetland areas identified which aze in close proximity to the proposed
location of the flood wall. At one rime, the plan for the flood wall involved the fiiling of one
wetland, however, MAC now indicates that the flood wall will not disturb any wetlands;�but will
run adjacent to identified wetlands. MAC has not provided a survey to the City Council Yo 0 6- 3 b 3
identify the exact location of the flood wall nor the exact location of wetiands, so it is noc •�,
possible to ascertain whether the MACs assertions aze correct.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
There have been no reports provided by the MAC to the City Council to indicate the effects of
the flood wall on adjacent wetlands. For instance, how does the change of river flow impact the
adjacent wetland ueas and their ability to support natural flora and fauna. Without more
specific information about steps to protect these valuable areas, it is impossible for the Council
to ascertain the impact of the flood wall on adjacent wetlands.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will preclude completion of the parkway a trail system
anticipated for tlae river and sever access to the river.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will have a negative visual impact on the river and will hamper
efforts to market the beauty of this resource in adjacent communities.
Objective 7.6: Airports and Airport Noise
This objective recognizes the importance of Holman Field to Saint Paul's economy and quality
of life. It indicates that the City supports maintaining and improving them in their present
locations with full attention to noise mitigation.
"Changes in use that might alter the noise zones for Hoiman Field would be of concern to the
City because of the proximity of residential azeas including sites for new development" (7.6.4)
From the documentation provided by MAC, it appears that the creation of a levee at Holman
Field is designed to provide a flood-proof environment so that increased air traffic will make use
of the airport. MAC has provided no information about noise mitigation efforts to protect the
surrounding neighborhoods from this increased traffic as a result of the levee.
MAC has provided no specific information indicating that air traffic will not increase at Holman
Field if the airport is considered secure from flooding, In fact, the cost/benefit analysis (CBA)
dated November 4, 2005 conducted by HNTB for MAC lists the projected number of operations
at Holman Field increasing in annual aircraft operations from 134,377 in 2008 to 256,280 in
2057. This increase in operations is provided as justification for the cost of the project.
MAC indicates that a benefit of the new dike would be an "Increase in safety at Minneapolis-St.
Paul Internarional Airport (MSP) by allowing St. Paul Downtown Aiiport to fulfill its intended
system role of relieving MSP of significant levels of general aviation traffic." (Perimeter Dike
St. Paul Downtown Airport Briefing Paper, April 11, 2002). Included in the Planning
Commission record is a letter from Dorsey & Whitney LLP, writing on behalf of Northwest
Airlines, November 13, 3002, who state flatly "If the dike is constructed, Holman Field will be
more attractive to potential customers since it may provide a stronger measure of flood
protection.° They also fault the EAW for the perimeter dike for failing to assume that there will
be no increase in aizport use folTowing completion of the project. In fact they state: "This
assumprion is completely unwarranted, particularly in light of Holman Field's role as a reliever
Page 26 of 41
'.�
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
4Ll
45
4b
47
48
49
50
51
airport, and pending proposals to limit the use of other reliever airports. The EAW runs counter
to the evidence, and any reliance thereon is arbitrary, capricious or an abuse of discretion."
(Dorsey & Whitney LLP letter to Gary Warren, November 13, 2002) ��`
�
While airport noise at Holman Field decreased slighfly during the 1990's with the phase- in of
stage 3 aircraft and changes to the military fleet, airport noise is on the rise again. Noise zone
maps in the 1992 and 2002 Airport Comprehensive Plans show an increase in the noise zone
from 1998 projected out to 2020 with the proposed construction of the perimeter dike.
The 2000 Aiiport Comprehensive Plan also predicts an increase in the areas that would be
affected by airport noise. The azea affected by 60DNL is projected to increase by 248 acres in
2020. The areas affected by 65DNL aze projected to increase by 141 acres. The area affected by
70 DNL is projected to increase by 57 acres and the azea affected by 75DNL is projected to
increase by 65 acres. These projections show an increasing azea that will be affected by aiiport
noise.
MAC's projections also indicate a change in the mix of aircraft that would use the aiiport if the
perimeter dike were constructed. Exhibit 2C in the MAC 2000 Comprehensive Plan indicates
that jets will go from 27% of traffic operations in 1998 to 33% of operations in 2020.
Multi-engine aircraft aze projected to go from 17% of Craffic operations in 1998 to 24% in 2020.
Jets and multi-engine aircraft are considered to generate more noise than other aircraft.
The MAC Dayton's Bluff Noise Monitoring Summary 10l1512001-10J2212001 relies on a
"noise averaging" method to make the determination that noise levels from operations associated
with the St. Paul Downtown Airport are not of a significant nature. The Planning Commission
record includes a copy of a report The Impact of Airport Noise on Residential Real Estate, by
Randall Bell, MAI. As Mr. Ball points out, certain "noise averaging" methods are considered
controversial because they tend to assign noise categories inconsistent with communities' actual
noise status. (pg. 319-320) Instead, he concludes that "single event dBL should be considered
carefully" in deternuning appraised value. (pg. 321) The Dayton's Bluff Noise Monitoring
Summazy regularly recorded operations creating 76.8 dBL to 88.1dBL.
MAC has not proposed any plans to mitigate increased airport noise in the neighborhoods that
will be affected and airport noise mitigation is incompatible with the Dayton's Bluff Historic
Dastrict Guidelines.
Objective 7.8: Visual Beauty
This objective indicates that many features of the natural environment and the built environment
enhance a sense of place and contribute to well being as long as they remain prominently visible.
It indicates that the City will support the preservation of views and vistas and idenrifies major
view points and corridors including the river corridor at Holman Field.
The proposed sheet metal flood wali of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will completely block eiews both of the river from the city and
from the river back to the city. It will detrimentally affect an important view corridor and
significantly affect views from the Samuel Morgan Trail, tYie Bruce Vento Nature Sanetuary,
Tndian Mounds Park and other public lands.
J � /
Page 27 of 41
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
C) The City Council finds that the application is inconsistent with the Summary and
General Policy Chapter of the Saint Paul Comprehensive Plan including the following
General Policies:
GPl: Ten Principles for City Development
��—�`��
These 10 principles, originally developed as part of the "Saint Paul on the Mississippi
Development Framework" cali for evoking a sense of place; restoring and establishing the
unique urban ecology; improving connectivity; ensuring that buildings support broader city
goals; building on existing strengths; preserving and enhancing herita�e resources; providing a
balanced network for movement; among other goals.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will not evoke a sense of place that reflects ihe city's natural
beauty and exceptional heritage.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will not allow for the reestablishment of a natural system on the
river and provide connected corridors for migrating species.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as litfle as 0 feet of setback will not improve connectivity. In fact, it will preclude any
connection with the river.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback does not support the broader city goals of reconnecting with the
river and enhancing this important resource.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will not allow the city to build on the strength of the river as a
natural recreational and marketing resource.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback does not preserve and enhance the visual and recreation
resources available in the river corridor.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will not provide an opportunity to complete the system of trails
along the river corridor that would provide a balanced network for movement.
GP2: Topography and Natural Environmenf
This policy indicates that Saint Paul will strengthen its identity by reinforcing its topography and
natural environment. It calls on supporting polices from the Land Use and Parks and Recreation
chapters including implementation of the land use themes for "Saint Paul of the Mississippi
Development Framewark"; creation of new access to the riverbanks and bluff lines; promotion
of the Great River Park; conformance of policies and ordinances with the Mississippi National
River and Recreation Area Management Plan; restoration of greenway and natural habitat
linkages; reconnection of neighborhoods to the river with natural landscaping and, where
possible, restoration of surface water in tributary corridors; appropriate development of sites
with river valley views and protections of views where appropriate; conformance of
Page 28 of 41
�I ;* s �
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
?2
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
43
43
44
45
46
47
48
49
50
51
development with Mississippi River Corridor Critical Area Regulations; continued development
restriction, and acquisition where appropriate, for protection of bluffs; and protection of views
and vistas that offer connection with the natural environment, as well as views of appropriate
landmark features of the built environment.
As indicated in the many examples cited above, the proposed sheet metal flood wall of 5,531
feet in lengih, rising up to 22 feet above the water with as little as 0 feet of setback is
inconsistent with these supporting policies.
GPIS: River Corridor
This policy indicates that Saint Paul will continue to give high priority to the transformation of
the River Corridor from a predominantly heavy industrial past to a renewed center for activity
and enjoyment of Saint Paul's natural setting. Supporting policies include continuation of
appropriate improvement and development of the River Corridor as a priority, making sure
changes are consistent with the enhancement of its natural ecology; improvement of public
access and recreational uses throughout the corridor; restriction of new development in the
floodplain (or witlun 300 feet of the water) to those entities which have a relationship to the
river, need a river location, or can enhance the river environment; transportation investment that
emphasize pedestrian opportunities and strengthen neighborhood connections; development
consistent with Critical Area standards and the River Comdor Plan.
As indicated in the many examples cited above, the proposed sheet metal flood wall of 5,531
feet in length, rising up to 22 feet above the water with as little as 0 feet of setback is
inconsistent with these supporting policies.
GP18: Open Space and River Connections
This policy indicates that in corridor planning and development, close attention must be paid to
environmentai quality and Saint Paul must take advantage of opportunities to enhance and
extend the open space network formed by the river corridor, bluffs, puks and parkways.
Neighborhood connections to the Mississippi River Corridor will be enhanced through
appropriate trail and road connections, infrastructure design and land use planning and
regulation.
As indicated in the many examples cited above, the proposed sheet metal flood wall of 5,531
feet in length, rising up to 22 feet above the water with as little as 0 feet of setback is
inconsistent with these supporting policies.
D) The application is inconsistent with the Parks and Recreation Chapter of the Saint Paul
Comprehensive Plan including the follawing objectives:
Objective 1: Encourage protection, preservation, and regeneration of the city's open
space and natural resources
This objective recognizes that Saint Paul's open space, natural, and historic resources provide
many benefits including softening the built environment, providing habitat for plants and
wildlife, and improving overall environmental quality. The objective also recognizes that open
and natural space is vulnerable to unwarranted use and degradation. It calls for a conscious and
concerted effort to protect and preserve open space, natural space, and ecological systems,
recognizing that they have regional impact.
Page 29 of 41
2
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
Included in this objective are policies to develop management and protection strategies for
endangered species and/or sensitive habitats; provide adequate and consistent enforcement of
regulations to protect water quality, wetlands, native habitats and the river corridor; and opening
a cleaner and more friendly river to swimmers and other recreational users.
(� �
The proposed sheet metal flood wall of 5,531 feet in length, zising up to 22 feet above the wat�r �' —�� 3
with as little as 0 feet of setback is inconsistent with softening the built environment; providing
habitat plants and wiidlife; improving overall environmental quality; preserving open space; and
protecting ecological systems.
Questions have been raised about the adequacy of MAC's terrestrial survey for endangered
species which was conducted during December. To date, no detailed report on the survey has
been made available to the City Council, the Planning Commission, or other
interested agencies. No aquatic survey has been done to date and questions have been raised
about the possibility of the site of the compensatory excavation including habitat for Higgins
Eye Peazly Mussels, a federal and state identified endangered species.
There have been several wetland azeas identified which are in close proximity to the proposed
location of the flood wall. At one time, the plan for the flood wall involved the filling of one
wetland, however, MAC now indicates that the flood wall will not disturb any wetlands, but will
run adjacent to identified weflands. MAC has not provided a survey to the City Council to
identify the exact location of the flood wall nor the exact location of wetlands, so it is not
possible to ascertain whether the MACs assertions are coLrect.
There have been no reports provided by the MAC to the City Council to indicate the effects of
the flood wall on adjacent wetlands. For instance, how does the change of river flow impact the
adjacent wetland areas and their ability to support natural flora and fauna. Without more
specific information about steps to protect these valuable areas, it is impossible far the Council
to ascertain the impact of the flood wall on adjacent wetlands.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as litde as 0 feet of setback will cut of access to the river and be a visual impediment to the
enjoyment of natural space for tourists and recreational users of the river.
Objective 2: Expand physical and visual access to the River
This objective recognizes the Mississippi River as Saint Paul's foremost natural, historical, and
recreational resource. It indicates that increasing downtown riverfront access has been
consistently idenrified as a prioriey for riverfront redevelopment and should continue to be
pursued.
Included in this objective are policies which indicate that the city should pursue opportunities to
provide public access to the riverfront in a manner that is aesthetically compatible with the
riverfront and protects environmentally sensitive areas; encourage riverfront development that is
environmentally compatible and fosters a pazk-like riverfront character; preservation and
enhancement of significant river and downtown skyline views; limitations on building heights
and setback encroachment in areas that would obstruct public access and views to the river.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback is not aesthetically compatible with the riverfront and no
evidence has been presented which indicates that it will protect this environmentally sensitive
Page 30 of 41
�
2
3
4
5
area.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback is not environmentally compatible with the river and will not
foster a park-like river-front chazacter.
Q�-�53
7 The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
8 with as little as 0 feet of setback will not preserve or enhance significant river or downtown
9 skyline views.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will encroach on the river bank and will obstruct public access
and views to the river.
Objective 3: Develop park and open space connections
This objective recognizes that park and open space connections provide a means for moving
between pazks, moving within parks, and getting to parks in a safe, convenient and enjoyable
manner.
The proposed sheet metal flood wa11 of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will preclude the planned connection of bike trails through the
Holman Field area and impair visual connection with the river and surrounding park land such as
the Bruce Vento Nature Sanctuary, the Samuel H. Morgan Trail and Indian Mounds Park.
E) The City Council finds that the application is inconsistent with the Saint Paul on the
Mississippi Development Framework including the following goals:
Chapter 1 Environmental Context
Goal l: Strengtlten Saint Paul's identity by reinforcing its topography and natural
environment
This goal recognizes the impor[ance strengthening Saint Paul's identity by reinforcing its
topography and natural environment. Objectives include approaching development decisions
with a view to establishing balance between built and natural areas; developing and undertaking
strategies to.restore the health of local ecosystems; identifying and reinforcing key elements of
the natural setting that contribute to the character of the city including the river and the bluffs;
reinforcing Saint Paul's topography as a natural asset and renewing connections with the
Mississippi River, urban forests, and floodplain reaches.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will appear out of balance with the surrounding topography and
natural environment.
The proposed flood wall will not enhance or restore the local ecosystem and by MACs own
design, will hamper critical magration corridors for birds and other wildlife. Removing over
155,000 cubic feet of river bank will not enhance the local ecosystem and will not allow an
opportunity to restore the local ecosystem.
Page 31 of 41
1 The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
2 with as little as 0 feet of setback will present an imposing stmcture, in conflict with the
3 surrounding topography and hampering public connection with the river, s
4 ��-3�3
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will change the remaining floodplain character of this azea and
will preclude any restoration of the azea to a more natural ecosystem.
Goal 2: Protect, reszore and reinforce native vegetation
This goal recognizes the importance of native vegetation areas to the health of the river and the
variety of animal habitats that are chalienged by urban development. The goal calls for
increased preservation and restoration of native plant and animal habitats to establish a healthy
urban ecology that contributes to a sense of place, improves quality of life, and set a context in
which other strategies of the framework can be implemented.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will present little opportunity for the enhancement of native
vegetation that supports wildlife habitat.
The proposed flood wall will not enhance or restore the local ecosystem and by MAC's own
design, will hamper critical migration corridars for birds and other wildlife.
MAC has failed to provide a detailed plan for restoring native habitat along the riverbank and the
proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water with
as little as 0 feet of setback will not allow for habitat restoration in many areas.
Goal 3: Devedop creative design altematives for river edge treatments
This goal recognizes the importance of the river's edge far accessibility and attractiveness. It
calls for blending hazd and soft edge treatments; using soil bio-engineering techniques and
plantings to increase the strength of the river banks; reestablishing a littoral zone where the
shoreline meets the river s edge; and improving the overall visuaUaesthetic chu of the
shoreline and river edge.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will hamper public accessibility to the river's edge and create a
visual impediment to the view corridor.
With little to no setback for the proposed flood wall, there is no opportunity to blend from hard
surface to soft edge treatments and no opportunity to establish bio-engineering techniques or
plantings to create a natural appearance to the river front.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as litfle as 0 feet of setback will not improve the overall visuaUaesthetic character of the
river edge.
Chapter 4 Public Realm
Goal I: Provide easily recognizable and accessible connections between downtown Saint
Paul, the riverfront and the czEy-wide and regzonal open space trail systems
Page 32 of 41
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will sever connections with the riverfront and preclude efforts to
link the river to a regional trail system. � t,� _���
�
Goal 2: Recognize and take fuZl advantage of the historic and recreational signifzcance
of Saint Paul's parkway and trail corridor system
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
This goal recognizes opportunities to link the existing parkway and trail system with a focus on
linking regional trail systems with the downtown core and the river.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will sever connections with the riverfront and preclude efforts to
link the river to a regional trail system.
Goal 3: Build on existing initiatives to establish an urban greening policy for downtown,
riverfront and river bottom areas
This goal seeks to build on initiatives such as those undertaken by Great River Greening to
develop a greening policy for the riverfront and river bottom areas.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will not allow for adequate opportuniries to landscape and
restare natural habitat along the riverfront. This will reduce unified efforts to create continuous
green corridors for migration and habitat.
Goal 8: Protect and enhance the environ�nental and aesthetic quality and integrity of
Saint Paul's natural features
This goal calls for the reconnecting natural features as part of the city green structure to provide
an opportunity for the public to experience the natural world within downtown Saint Paul. Thi�
goal states "The fractured condition of existing remnant natural azeas makes this a challenging,
but essential goal."
This goal also recognizes that a prominent and thriving system of natural features has
tremendous value, both environmentally and aesthetically. It also recognizes the value of natural
areas for recreational and educational opportunities.
The proposed sheet metal flood wall of 5,531 feet in length, rising up to 22 feet above the water
with as little as 0 feet of setback will sever any opportunity to reconnect this section of this river
with sustainable natural habitats. It will also hamper efforts to create a unified, natural aesthetic
on the riverfront as it blocks views both to and from the river. The removal of more than
155,000 cubic feet of river bank will ineparably change the riverbank and alter the integrity of
this natural area.
F) While the National Park Service Mississippi National River and Recreation Area (MNRRA)
Comprehensive Management Plan is not an adopted city plan, the city references the document
frequently in our planning documents and it serves as the goveming document for management
of the recreation area which includes Holman Field. The City Council believes that it is
important to recognize the Comprehensive Management Plan as a guiding document and finds
that the application is inconsistent with the MNRRA Comprehensive Management Plan
including the following concepts:
Balance and integrate sustainable use and resource preservation needs.
Page 33 of 41
Preserve and restore natural appearance of shorelines and bluffs; protect habitats; protect historic
azeas; preserve economic resources; provide setbacks and screen new uses with vegetarion.
4 Emphasize river-related and river-enhancing uses; minimal change to existing developme4ft �—���
5 Provide a continuous lineaz open space and trail where practical; acquire sensitive areas and
emphasize resource protection.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
SO
51
Balance resource protection and use; increase pollution reduction efforts; preserve biological
diversity; protect cultural and economic resources;facilitate and coordinate research.
(2) Appticable ordznances of the city.
The planning commission's resolution approving the Metropolitan Airports Commission (MAC)
site plan to widen a portion of the river channel and construct a levee is inconsistent with the
following City Ordinances which are noted in the Planning Commission's Resolution.
Leg. Code § 68.402 regulates protection of shorelands, floodplains, wetlands and bluffs in the
River Corridor. The planning commission erred with respect to its findings under Leg. Code §
68.402(b)(1)(b):
(b) Placement of strucfures.
(1) The following minimum setbacks for each class of public waters as described in
Minnesoza Regulations NR-82 shall apply to alt structures except those specified as
exceptions in subsection (7) below.
b. For general developmerzt waters at least seventy-fzve (75) feet from the nornzal high
water mark for Zots not served by public sewer and at Zeast fzfty (SO) feet from the
ordinary high water mark for Zots served by public sewer.
The applicant requested a variance of this standard. The planning commission's findings
approving the variance aze set forth in the staff findings at H.1 to H.5 and are incorporated into
Commission Resolution No. OS-17. The commission's finding is in enor based upon the
CounciPs reasons for denying the said variance as set forth in pages 11-21 of this resolution.
The planning commission erred with respect to its findinas under L.eg. Code § 68.402(b)(2):
(2) No commercial or industrial development shall be pernutted on slopes greater than twelve
(12) percent. The applicant has requested a variance of this standard. The planning
commission's findings approving the variance are set forth in H.l to H.S. The commission's
finding is in error based upon the Council's reasons for denying the said variance as set forth
elsewhere in this resoluhon �`�r���,*�'�"����F`?
The planning commission erred with respect to its findings under the following sections of I,eg.
Code ' 68.402(b)(5)(a)(b)(d). The commission deternuned that the noted sections were not
applicable to the application. The Council finds that the site plan proposes work on slopes in
excess of 18% which is prohibited under the code, that the visual appearance of the ftood wall
will intrude over the river and that the flood wall will create a tunnel vista up and downstream
when viewed from upon the river.
Page 34 of 41
The planning commission erred in its findings under L.eg. Code § 68.402(c)(7). The planning
commission ened in approving the site plan based upon the MAC's request to vary the
provisions underl.eg. Code § 68.402(c)(7). p
cJ�'���
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
(7) No rehabilitation slopes shall be steeper than eighteen (18) percent slope. The applicant
requested a variance of this standard. The planning commission eired when it granted the
variance of this standard in findings H.1 and H.5 of its resolution. The Council's findings of
enor in the planning commission's findings are set forth in the CounciPs reasons to deny the
requested variances as set forth in pages ll- 26 of this resolution.
The planning commission etred in its findings undez I.eg. Code § 68.403(a):
Sec. 68.403. Protection of wildlife and vegetation. Development shall be conducted so
as to avoid intrusion into animal and plant habitats.
(a) No alteration of the natural environment or removal of vegetation shall be permitted
when sueh alteraZion or removal would diminish the abiliry of dependent wzldlife to
survive in the River Corridor.
The planning commission found that the compensatory excavation and levee construction are not
in an azea that is currently habitable by wildlife. The Council finds that the record is lacking to
support such a conclusion on the part of the planning commission. The planning commission
further found that existing vegetation could be retained for wildlife habitats and to screen the
sheet piles from view. The Council finds that retention of existing vegetation is contrary to the
polices found throughout the Comprehensive plan that calls for reestablishing native plants and
vegetation along the river. Retaining vegetation without knowing its type and origin and
whether the vegetaYion is suitable fox wildlife habitat and screening sheet pile is inconsistent
with the City's river policies.
The planning commission erred in its findings under I.eg. Code § 68.403(d)
(d) Naturad vegetation shall be restored after any construction project.
The planning commission found that the MAC must restore native vegetation to the shoreline
and noted that no natural vegetation exists on the actual airport proper w here a portion of the
levee will be located. The planning commission went on to say that vegetation riverward of the
sheet pile flood wall will be retained where possible. This is an error in that it grants too much
discreUon to the MAC to determine whether it is possible to retain native vegetation.
Throughout the comprehensive plan it is a stated goal to retain native vegetation. If the MAC
encounters situations where native vegetation cannot be retained, it is incumbent upon the MAC
to present the situation to the City and allow the City to deternune whether the native vegetauon
can be retained and by what means. Granring approval to the MAC to retain native vegetarion
where possible provides too much discretion to the MAC.
In addition, the MAC's site plan and variance applications aze inconsistent with the following
additional City ordinances: Leg. Code § 61.301(a) and Leg. Code § 301(b). Both ordinances
pernut, in pertinent part, a"person having an ownership or leasehold intexest in the subject land .
..(contingent included)" to apply to the City for a site plan review (§ 61.301(a)) or a variance (§
61.301(b)). The appellant's generally have called the MAC's ownership of the land needed for
this project into question. The City has researched the appellanYs claim and has concluded that
the MAC lacks an ownership or leasehold interest in at least some of the land which MAC
Page 35 of 41
1 proposes to develop with the flood wall. In particular, the MAC has not demonstrated an � 3 b 3
2 ownership or leasehold interest, contingent or otherwise, in the lands where the MAC has
0
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
proposed to make "compensatory" excavations. The ownership records available to the City
show the land under the ownership of the Saint Paui Port Authority. Therefore, the MAC's
application for site pian review as well as its application for variances fails to meet the general
appiication and review procedure required underLeg. Code §§ 61301(a) and .301(b). Because
the land in question abuts the Mississippi River and land along the river as well as the river itself
is subject to movement, a report on the title of all the lands necessary for this project, including
but not limited to a survey of all the land on which the flood wall will be located, is necessary to
establish MAC's ownership in order to comply with the general application and review
procedure required under Leg. Code § 61.301(a) and .301(b).
(3) Preservation of unique geologic, geographic or historically significant characteristics
of the city and environmentalty sensitive areas.
The Metropolitan Airports Commission (MAC) site plan to widen a portion of the river channel
and conshuct a levee is inconsistent with preservation of the unique geologic, geographic or
historically significant chatacteristics of the eity and environmentally sensiuve areas.
The Mississippi River is recognized by the City of Saint Paul as one of our most unique
geologic, geographic and historically significant characteristics. This is bome out in extensive
references to the river in our Comprehensive Plan documents and in other adopted development
frameworks including the 5aint Paul on the Mississippi Design Framework. This is also
recognized in our zoning code with a chapter devoted solely to the River Corridor. As can be
seen from the extensive review of Saint Paul planning documents cited above, all of these
documents call for additional protection of this important natural and social resource and see the
river as integral to the city's future development. Nowhere in this vast array of planning
documents does the city contemplate a 5,531 foot sheet metal flood wall rising 22 feet above the
river that will block access to the river's edge and impair the view corridor from adjacent
property and the river itself.
In addiUon to Saint Paul's recognition of the Mississippi River's significant chazacteristics, both
the State of Minnesota and the National Park Service have designated the river as having
geologic, geographic and historic significance and have enacted legislation (�ederal Public Law
100-696 — November 18, 1998, Titie VII, Mississippi River and Recreation Area, Minnesota
5tatutes Chapters 103 and 116G) and rules (Mississippi River and Recreation Area Final
Comprehensive Management Plan and MEQC54) and completed extensive planning to preserve
the significant chazacteristics of the river.
Clearly, the river is a cherished, one-of-a-kind resource for our City, our State and our Nation,
and as such, projects that will affect the river corridor deserve increased scrutiny by the Planning
Commission and City Council.
Removing 155,000 cubic yazds from the river bank and constructing a flood wa11 that will stretch
for 9,635 feet in length, remove 560 acres from the floodplain, be driven 50 feet deep into the
river bank, and cover the river bank with more than 5,000 yazds of rip rap is not consistent with
preservation efforts and goals outiined in the City's comprehensive plan and zoning code. Nor is
it consistent with the preservation efforts and goals outlined by the State's Department of Natural
Resources or the National Park Service's Goals for the Mississippi River Nafional River and
Recreation Area.
Page 36 of 41
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
(4) Protection of adjacent and neighboring properties through reasonable provisio - 3 6 3
such matters as surface water drainage, sound attd sight buffers, preservation of views,
light and air, and those aspects of design which may have substantuzl effects on
neighboring land uses.
The Metropolitan Aiiports Commission (MAC) site plan to widen a portion of the river channel
and construct a levee is inconsistent with grotection of adjacent and neighboring properties.
MAC has failed to demonstrate that the widening of the river and the construction of a levee will
not have a detrimental effect on sound, sight, preservation of views, and neighboring land uses
for neighboring properties.
(A) Sound Buffers
From the documentation provided by MAC, it appears that the creation of a levee at Holman
Field is designed to provide a flood-proof environment so that increased air traffic will make use
of the airport. MAC has provided no information about noise mitigation efforts to protect the
surrounding neighborhoods from this increased traffic as a result of the levee.
MAC has failed to provide specific information indicating that air traffic will not increase at
Holman Field if the aiiport is considered secure from flooding. In fact, the cost/benefit analysis
(CBA) dated November 4, 2005 conducted by HNTB for MAC lists the projected number of
operations at Holman Field increasing in annual aircraft operations from 134,377 in 2008 to
256,280 in 2057. This increase in operafions is provided as justification for the cost of the
project.
MAC indicates that a benefit of the new dike would be an"Increase in safety at Minneapolis-St.
Paul International Airport (MSP) by allowing St. Paul Downtown Aitport to fulfill its intended
system role of relieving MSP of significant levels of general aviation traffic.° (Perimeter Dike
St. Paul Downtown Airport Briefing Paper, April 11, 2002)
Included in the Planning Commission record is a letter from Dorsey & Whitney LLP, writing on
behalf of Northwest Airlines, November 13, 2002, who state flatly "If the dike is constructed,
Holman Field will be more attracUve to potential customers since it may provide a stronger
measure of flood protecfion." They also fault the EAW for the perimeter dike for failing to
assume that there will be no increase in airport use following compietion of the project. In fact
they state: "This assumption is completely unwarranted, particularly in light of Holman Field's
role as a reliever airport, and pending proposais to limit the use of other reliever aiiports. The
EAW runs counter to the evidence, and any reliance thereon is arbitrary, capricious or an abuse
of discrerion." (Dorsey & Whitney LLP letter to Gary Warren, November 13, 2002)
While aiiport noise at Holman Field decreased slightly during the 1990's with the phase- in of
stage 3 aircraft and changes to the military fleet, airport noise is on the rise again. Noise zone
maps in the 1992 and 2002 Aiiport Comprehensive Plans show an increase in the noise zone
from 1998 projected out to 2020 with the proposed construction of the perimeter dike. No
additional noise studies have been conducted to show that an increase in air traffic will not
impact adjacent properties.
The 2000 AirQort Comprehensive Plan also predicts an increase in the areas that would be
affected by airport noise. The azea affected by 60DNL is projected to increase by 248 acres in
2020. The areas affected by 65DNL are projected to increase by 141 acres. The area affected by
70 DNL is projected to increase by 57 acres and the area affected by 75DNL is projected to
Page 37 of 41
v V J U l
1 increase by 65 acres. These pro}ecYions show an increasing azea that will be affected by airport
2 noise. No additional noise studies have been conducted by MAC to show that the increase in air
3 tra�c will not impact adjacent properties. MAC's projections also indicate a change in the mix
4 of aircraft that would use the airport if the perimeter dike were constructed. Exhibit 2C in the
5 MAC 2000 Comprehensive Plan indicates that jets will go from 27% of traffic operations in
6 1998 to 33% of operations in 2020. Multi�ngine aircraft aze projected to go from 17% of traffic
7 operations in 1998 to 24% in 2020. Jets and multi-engine aircraft aze considered to generate
8 more noise than other aircraft. No additional noise studies have been conducted by MAC to
9 show that this change in aircraft use will not impact surrounding properties.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
S1
The MAC Dayton's Bluff I�TOise Monitoring Summary 10J1512001-10J22l2001 relies on a
"noise averagina' method to make the determination that noise levels from operations associated
with the St. Paul Downtown Airport are not of a significant nature. As The Impact of Airport
Noise on Residential Real Estate, by Randall Bell, MAI points out, certain "noise averaging"
methods are considered controversial because they tend to assign noise categories inconsistent
with communities' actual noise status. (pg. 319-320) Instead, he concludes that ° single event
dBL should be considered cazefully" in deternuning appraised value. (pg. 321) The Dayton's
Bluff Noise Monitoring Summary regularly recorded operations creating 76.8 dBL to 88.1dBL.
MAC has not proposed any plans to mitigate increased airport noise in the neighborhoods that
will be affected and airport noise mitigation is incompatible with the Dayton's Bluff Historic
District Guidelines.
(B) Sight Buffers
MAC has provided no plan to address the visual effects of a 9 foot, sheet-metal flood wall that
will rise 9 feet over grade for 5,531 feet along the river bank. They have indicated that the flood
wall will be screened by existing scrub trees and shrubs along the shoreline.
Without a specific landscape plan, the council is skeptical that the existing vegetation will
survive the construction necessary to install the flood wall. Without a specific landscape plan
the council is also skeptical that the existing vegetation is sufficient to buffer the visual affects of
the flood-flood wall on views from the river and the s�urounding property, including the Bruce
Vento Nature Sanctuary and Mounds Park.
No plan has been submitted to address the visual impact of a rusting sheet metal flood wall on
views from the river and surrounding property.
No plan has been submiited to address vandalism to the sheet metal flood wall which is likely to
be an attractive nuisance.
No pian has been submitted to discuss the visual impacts of 5,000 square feet of rip rap from the
river and sunounding property.
(C) Preservation of Views
Objective 6.2 of the Mississippi River Corridor Pian indicates that the City should work to
preserve and improve existing views to the river and bluffs, and develop new ones. It recognizes
that various forms of public visual access to the river consist of scenic river views, extended
view corridors, overlook points, observation platforms, bridge crossings, bridgeheads and bluff
stairways. It recognizes that views both from the river and over the river aze important public
Page 38 of 41
amenities and should be protected. MAC has failed to provide adequate evidence that the flood
wall will not negatively nnpact visual access to and from the river. o �_�,� �
�
No plan has been submitted to address the visual unpact of a msting sheet metal flood wall on
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
views from the river and surrounding property.
No plan has been submitted to address vandalism to the sheet metal flood wall which is Iikely to `
be an attractive nuisance.
No plan has been submitted to discuss the visual impacts of 5,000 square feet of rip rap from the
river and surrounding property.
(8) The sttfisfactory availability and capacify of storm and sanitary sewers, including
solutions to any drainage problems in the area of the devetopment.
The Council notes that while MAC is creating an extensive sub-drain system to handle excess
water from the high water table, questions remain unanswered about the treatment of runoff and
potential pollution on the site. MAC does not have the requized MPCA permits for the creation
of the sub-drain system or the construction of the flood wall. MAC has not done the necessary
soil and water testing to determine potential pollution hazards to the river.
(9) Suffzcient larcdscaping, fences, flood walls and parking necessary to meet the above
objectives.
MAC has not provided a plan that is sufficient to meet the objectives noted above. As stated
previously, MAC has not submitted a landscaping plan that will address the visual intrusion of
the flood wall. Relying on existing scrub trees and bushes to ameliorate the visual blight of a 9
foot, sheet metal flood wa11 that is more than 5,531 feet in length is inadequate.
(II) Provision for erosion and sediment control as specifzed i� the "Ramsey Erosion and
Sediment Control Handbook. "
MAC has not provided a detailed plan for sediment control for the compensatory excavation.
AND, BE TT FURTHER RESOLVED, That the appeals of the Friends of the Parks and
Trails of Saint Paul and Ramsey County, the Friends of the Mississippi River and the Audubon
Society are hereby granted; and, be it
Page 39 of 41
AND, BE IT FINALLY RESOLVED, That the City Clerk shall mail a copy of �his
resolution to MAC, the Friends of the Parks and Trails of Saint Paul and Ramsey County, the� ;� —� ;: ,�
Friends of the Mississippi River, the Audubon Society, the Zoning Admiuistrator and the
Planniug Commission.
Requested by Depazhnent oL
�
Fonn Approv y CiTy Attorney
BY. . Gr/, L✓cwr,.._ �� • I g- � G
Adoption Certrfied by Council Secretary Foan Approved by Mayor for Submission to Counci]
sy: /�/ln� /r�i�5d�
BY.
Approved by Mayor: Date p finYlJ✓l �..�rr [ iG�i� .fSu ��/�GD2
By:
Page 40 of 41
Adopted by Council: Date �D.?i %/l1i c"����
06-363
This page left intentionally blank.
Page 41 of 41
�
� Green Sheet Green Sheet, Green Sheet Green Sheet Gteen Sfieet Green Sheet �
co , c�
Contact Person 8 Phone:
Counal Pres�dert[ Lartry
266E670
Must Be on Cwncil Agenda by (Date):
79-APR-06
ContraciType:
'� ' • ll.�.�
,�a� -� I Green Sheet NO:
� '
Assign
Number
For
Routing
Order
06-363
3030498
Deoartrnent SentToPerson
0
1 il t '
2 Ie
3
4
5
Total # of Signature Pages _(Clip NI Loca4ons for Signature)
Aclion Requested:
Memorializing City Council acfion taken 4/1272006 granting the appeal of Friends of St. Paul & Ramsey Co. Parks & Traiis, Friends of
the Mississippi River, Audubon Society, & District Councils 1,3, & 4 from a decision of the Planning Commission approving site plan
& variances to allow the Metro¢otitan Airports Comm. tn conshuct a flood protection system at 644 Bayfield St. (Holman Fieid)
itlations: Appm�e (A) or F
Planning Commission
CIB Committee
CiNI Senice Commission
Personal Service Contracfs
'I. Has this persoNfirtn e�er worked unGer a cwdtact for this department?
Yes No
2. Has this person/firtn e�er been a city employee?
Yes No
3. Do� this person/firm possess a skill not norma0y possessed by any
cur2rR city employee?
Yes No
Explain all yes answers on separate sheetand alfach to gree� sheet
Initiating Probism, Issues, OppoRunity (Who, What, When, Where, Why):
Advantages KApproved:
D�advantages If Approved:
DisativaMages M Not Approved:
Transaction:
Funding Source:
Financial Information:
(Explain)
CoSHRevenue Budgeted:
Activity Mumber.
9
Y
�
�
,:
April 22, 2006 3:09 PM page 1
o�-���
CZ� �F" S�r P�l�. 390 C+ry Ha11 7elephone � 651-266-85
MoyorChristophesB. Colem¢n ISWestKeZloggBoulevard Facslmile:651-228-85.
Sair+t Paul, hIN SSIO2
The Honorable Kathy Lantry
St. Paul City Council President
Room 320-C City Hall
Saint Paul, MN 55102
Re: City Council Resolution 06-363
Variance and Site Plan Approval for Ho[man Field
Dear Council President Lanhy:
This letter concerns City Council Resolution 06-363, which relates to the Metropolitan
Airports Commission's ("MAC") application for a variance and site plan approval to
construct a flood wall at Holman Field. I want to advise you that pursuant to Charter §
6.08 I am allowing the resolution to take effect without my signature. I am doing this
because I agree that the proyect, as currently proposed, shouid not be granted the various
land use permissions, but I do not agree with every objection raised by the resolution.
Holman Field is an important asset to St. Paul, the region and our state. I want you to
know that I want this project to move forward in St. Paul, but only when I believe that the
community interest is adequately protected. I have asked the MAC to wark with my
administration to resolve our outstanding issues and then submit a new application to the
St. Paul Pianning Commission as soon as possible. I have enclosed a letter that was sent
to the MAC, which outlines the conditions that the MAC must meet in order for me to
support construction of the flood wa11.
Please trust that I have heard and seriously considered all of the objections to this project
and understand the gravity of concerns raised by many in our community.
I propose that we work diligently together in the next few weeks to move this project
forward.
Sin re ,
�
Christopher B. Coleman
Mayor
cc: St. Paul City Councff
i•
TO:
CI� �F' S�T Pt��. 390 Ciry Ha77
M¢yor Christopher B. Coleman I S West Kellogg Boulevard
Saint Paul, MN 55102
Members of the Metropolitan Airports Commission
Vicki Tigwell, Chair
Kari Berman
Daniel Boivin
Tom Foley
Pat Harris
Mike Landy
John Lanners
Robert Mazs, Jr.
Tammy McGee
Bert McKasy
Paul Rehkamp
Molly Sigel
Sherry Stenerson
Greg Warner
John Williams
FROM: Christopher B. Coleman
Mayor
DATE: Apri124, 2006
RE: Holman Field Flood Wall
3b3
Telephone: 65l-266-8510
Facstm:Ye: 6�7-228-8573
As you know, the Saint Paul City Council voted last week to deny the Metropolitan Airports
Commission's ("MAC") application for a vaziance and site plan approval to build a flood wail at
Holman Field. A resolution metnorializing that decision will reach my desk in the next few
days.
As I have indicated on several occasions, I wiil not veto the City CounciPs resolution. Nor will I
sign it. The City CounciPs resolution will be allowed to take effect without my signature. After
considerable deliberation, I agree that the project, as currently proposed, should not be approved.
I do not concur, however, with each of the fmdings and conclusions detailed in the wide-ranging
resolution and, therefore, will not sign it.
I have been very clear where I stand with respect to the MAC's proposaL I asked that the MAC
withdraw its application prior to the appeal being heard by the City Council. That would have
Metropolitan Airports Commission
Aprii z4, zoo6 ��_ 3� 3
Page two
provided the best opportunity to address my concems with the project while moving the process
along as quickly as possibie. Instead, the MAC chose to pursue approval of the current
application. Project delays, which could have been avoided, aze now an inevitable consequence
ofthe MAC's decision.
I have heazd your frustrarion with respect to the timeline. In the short time that I have been in
office, I have worked deliberately to focus the discussion around key issues and to define a
process through which those issues can be resolved. From an extensive list of commuruty
concerns, the issues that remain have been reduced to three: location, design and aesthetics.
These can and must be addressed by the MAC befare this project proceeds.
For the past hvo decades, Saint Paul has worked tirelessly with our many partners, including the
State of Minnesota, to reclaim the Mississippi River. Millions of dollars have been invested in
efforts to restare and beautify the river valley. There is now a neighborhood on the Upper
Landing where scrap yards once dominated the landscape. The artfiil design of the Wabasha
Street Bridge and the Science Museum reflect commitments made by both the City and its
partners to use every opportuniry to embrace the river with our best efforts. The parks and trails
that line the rivezbanks point toward full implementation of plans for the National Great River
Park. Using the Saint Paul on the Mississippi Development Frametivork as our guide, we haue set
for ourselves a standard of excellence befitting our continenYs greatest river. We owe nothing
less to our children and the city they will inherit.
Enclosed is an outline of the conditions that the MAC must meet in order far me to support
construction of the flood wall. The Saint Paul on the Mississippi Design Center has offered to
lead a process through which the remaining issues can be addressed. They have a strong record
of warking with project architects—including those associated with Lawson Software and
Securian—to enhance great projects by fitting them cazefully into the existing urban fabria I
strongly encourage you to take advantage of their expertise.
Once a new site plan—consistent with our design standuds as articulated by the Design
Center—is submitted to the Planning Commission, T will do all that I can to move the process
forward as quickly as possible.
Enclosure
cc: Governor Tim Pawlenty
Saint Paul City Councilmembers
� ry
�
� , �,
.,_ ;.
CONDITIONS FOR NEW VARIANCE AND SITE PLAN APPROVAL
1. A New AppZication Must Address Aesthetic Issues Regarding the Design, Appearance and
Location of the FZoodwall and the Compensatory Excavation sites.
Before the MAC's formal application is submitted, the Saint Paul on the Mississippi Design
Center will lead a design process for the flood walL The Design Center will seek community
input, obtain professional assistance, and incorporate good design practices.
The design shall be consistent with the Saint Paul on the Mississippi River Development
Framework. The design of the flood wall and excavation sites must respect the adjacent public
realm and be in keeping with the City's stated goals of renewing the river corsidor as a public
amenity.
The flood wall must be located as faz as possible from the riverbank in order to reduce the visual
impact of the flood wall structure and height, and minimize the need to reduce the setback from
the ordinary high water mark.
The floodwall design and the compensatory excavation sites must, to the greatest extent possible,
utilize design elements, design materials, vegetation and landscaping plans and best management
practices that are appropriate to the Mississippi River. The design should incorporate artistic
elements that incorporate the floodwall with ats surrounding environxnent. Sheet metal material
for the flood wa11 is discouraged.
2. Airport Operations and Aircraft Noise MitigaZion.
A. In order to minimize the public's exposure to noise and safety hazards from
airport operations, the MAC will, in consultation and collaboration with the City,
either develop or update a noise compatibility program for Holman Field to the
greatest extent possible under the spirit of, or in compliance with, the Aviation
Safety and Noise Abatement Act of 1979 and its appendices for regulations
implementing the Act. As necessazy, the program must be prepazed and delivered
to the FAA for its evaluation. The MAC shall use its best efforts to secure the
FAA's approval of the program or any portion of the proposed program and wi11
not act in any capacity or communicate with the FAA through any agent or
person, a desire to see the program disapproved. The MAC shall obtain the
FAA's approval of the noise compatibility program and notify the City of the
FAA's acceptance or rejection of the said program.
B. In order to minimize the environmental impact of airport operations, the MAC, in
consultation and collaboration with the City, will study, develop, update and
implemenf policies and regulafions for Holman Field to the greatest e�ent
possible, in the spirit of, or in compliance with, the Airport Noise and Capacity
Act of 1990 which would govern aircraft operation procedures, noise abatement
AA-ADA-EEO Employer
0�-�� �
approach and departure procedures and profiles and flight track and other noise
abatement procedures including tasiing and engine runups, lunits on the total
number of aircraft operations and limitations on the hours of operations. The
policies and regulations shall be prepazed and delivered to the FAA in
consultation and collaboration with the City. The MAC shall obtain the FAA
approval of these policies and regulations.
3. In a New Application MAC Must Agree to Promises Already Made to the Public.
The various statements that the MAC has made to the public or in the form of MAC resolutions
regazding the MAC's commitment to mitigate its Holman Field operations shall be determined
and reduced to conditions and imposed on the site plan and variance approvals.
Runway LenQth. The MAC will not take any action to increase the length of the runways
at the Airport in excess of the current length, unless required to do so by State law,
provided that the MAC will not initiate, promote or otherwise support enactment of such
law.
Pavement Strenath. The MAC will not take any action to increase the Runway Pavement
Weight-Bearing Capacity at the Airport beyond the m�imum presently available, unless
required to do so by State law, provided that the MAC will not initiate, promote or
otherwise support enactment of such law.
Cazgo Operations. The MAC xepresents that, based on operational and space limitations,
major air cargo operations are not able to use the Airport, nor will the MAC take action to
accommodate such activity.
Endangered/Threatened Species. The MAC will coordinate with the City of Saint Paul
and other appropriate agencies to complete an updated survey of threatened(endangered
species within the project area.
Treatment of Contaminated Soils. The NIAC will complete additional soil sampling and
testing in the area proposed for compensatory excavation, including testing for PAH's
and inorganics. The MAC will also monitor excavated material from the compensatory
excavation per a Testing and Disposal Plan. Any contaminated soils will be properly
disposed of in a licensed facility approved for such disposal.
Stormwater Discharee. The MAC will complete a samplingltesting protocol for subdrain
discharge, as may be required by the Minnesota Pollution Control Agency.
�
��-���
CITYQ'r' .S�rpf��.. 390CiryHalf Telephone:651-266-85
MayorChristopherB. Coleman ISWestKelloggBoulevmd Facsimile:6A-228-85.
Saint Paul, MN55102
The Honorable Kathy Lantry
St. Paul City Council President
Room 320-C City Hall
Saint Paul, MN 55102
Re: City Council Resolution 06-363
Yariance and Site Plan Approval for Holman Field
Dear Council President Lantry:
This letter concerns City Council Resolution 06-363, which relates to the Metropolitan
Airports Commission's ("MAC") applicafion for a variance and site plan approval to
construct a flood wall at Holman Field. I want to advise you that pursuant to Charter §
6.08 I am allowing the resolution to take effect without my signature. I am doing this
because I agree that the project, as currently proposed, should not be granted the various
land use permissions, but I do not agree with every objection raised by the resolution.
Holman Field is an important asset to St. Paul, the region and our state. I want you to
know that I want this project to move forward in St. Paul, but only when I believe that the
community interest is adequately protected. I have asked the MAC to work with my
administration to resolve our outstanding issues and then submit a new application to the
St. Paul Planning Commission as soon as possibie. I have enclosed a letter that was sent
to the MAC, which outlines the condifions that the MAC must meet in order far me to
support construction of the flood wa11.
Please trust that I have heard and seriously considered ail of the objections to this project
and understand the gravity of concerns raised by many in our community.
I propose that we wark diligently together in the next few weeks to move this project
forward.
Sin � ,
Christopher B. Coleman
Mayor
cc: St. Paul City Council
0�
TO:
FROM:
���
RE:
CTI'Y OF SAINT PAUL
Mayor Christopher B. Coleman
390 Ciry Hal7
IS WestKe[loggBoulevard
SaintPaul, MNSSl02
Members of the Metropolitan Airports Commission
Vicki Tigweli, Chair
Kari Berman
Daniel Boivin
Tom Foley
Pat Hazris
Mike Landy
John Lanners
Robert Mars, Jr.
Tammy McGee
Bert McKasy
Paul Rehkamp
Molly Sigel
Sherry Stenerson
Greg Warner
John Williams
Christopher B. Coleman
Mayor
April 24, 2006
Hodman Field Flood Wall
Telephone: 65T-266-8510
Facsimile: 651-228-8�73
As you know, the Saint Paul City Council voted last week to deny the Metropolitan Airports
Commission's ("MAC") application for a variance and site plan approval to build a flood wall at
Holman Field. A resolution memorializing that decision will reach my desk in the next few
days.
As I haue indicated on several occasions, I wiil not veto the City Council's resolution. Nor will I
sign it. The City Council's resolution will be allowed to take effect without my signature. After
considerable deliberation, I agree that the project, as currently proposed, should not be approved.
I do not concur, however, with each of the findings and conclusions detailed in the wide-ranging
resolution and, therefore, will not sign it.
I have been very cleaz where I stand with respect to the MAC's proposal. I asked that the MAC
withdraw its application prior to the appeal being heard by the City Council. That would have
Metropolitan Airports Commission 0 6- 3€� 3
Apri124, 2006
Page two
provided the best opportunity to address my concerns with the project while moving the process
along as quickly as possible. Instead,the MAC choseto pursue approval ofthe current
application. Project delays, which could have been avoided, are now an inevitable consequence
of the MAC's decision.
I have heard your fiustration with respect to the timeline. In the short time that I have been in
office, I have worked deliberately to focus the discussion around key issues and to define a
process through which those issues can be resolved. From an extensive list of community
concerns, the issues that remain have been reduced to three: location, design and aesthetics.
These can and must be addressed by the MAC before this project proceeds.
For the past two decades, Saint Paul has worked tirelessly with our many parmers, including the
State of Minnesota, to reclaim the Mississippi River. Millions of dollazs have been invested in
efforts to restore and beautify the river valley. There is now a neighborhood on the Upper
Landing where scrap yazds once dominated the landscape. The artfitl design of the Wabasha
Street Bridge and the Science Museum reflect commitments made by both the City and its
parkners to use every opportunity to embrace the river with our best efforts. The parks and trails
that line the riverbanks point toward full implementation of plans for the National Great River
Park. Using the Saint Paul on the Mississippi Development Framework as our guide, we have set
for ourselves a standard of excellence befitting our continenYs greatest river. We owe nothing
less to our children and the city they will inherit.
Enclosed is an outline of the conditions that the MAC must meet in order for me to support
constnxction of the flood wall. The Saint Paul on the Mississippi Design Center has offered to
lead a process through which the remaining issues can be addressed. They have a sirong record
of working with project architects—including those associated with Lawson Software and
Securian—to enhance great projects by fitting them cazefully into the existing urban fabric. I
strongly encourage you to take advantage of their expertise.
Once a new site plan�onsistent with our design standards as articulated by the Design
Center—is submitted to the Planning Commission, I will do all that I can to move the process
forwazd as quickly as possible.
Enclosure
cc: Governor Tim Pawlenty
Saint Paul City Councilmembers
0�-3!3
CONDITIONS FOR NEW VARIANCE AND SITE PLAN APPROVAL
1. A New Application Must Address Aesthetic Issues Regarding the Design, Appearance and
Location of the Floodwall and the Compensatory Fxcavation sites.
Before the MAC's formal application is submitted, the Saint Paul on the Mississippi Design
Center will lead a design process for the flood wali. The Design Center will seek community
input, obtain professional assistance, and incorporate good design practices.
The design shall be consistent with the Saint Paul on the Mississippi River Development
Framework. The design of the flood wall and excauation sites must respect the adjacent public
realm and be in keeping with the City's stated goals of renewing the river corridar as a public
amenity.
The flood wa11 must be located as far as possible from the riverbank in order to reduce the visual
impact of the flood wall shucture and height, and minimize the need to reduce the setback from
the ordinary high water mark.
The floodwall design and the compensatory excavarion sites must, to the greatest extent possible,
utilize design elements, design materials, vegetation and landscaping plans and best management
practices that are appropriate to the Mississippi River. The design should incorporate artistic
elements that ancorporate the floodwall with its surrounding environment. Sheet metal material
for the flood wall is discouraged.
2. Airport Operations and Aircraft Noise Mitigation.
A. In order to minimize the public's exposure to noise and safety hazards from
airport operations, the MAC wiil, in consultation and collaboration with the City,
either develop or update a noise compatibility program for Holman Field to the
greatest extent possibie under the spirit of, or in compliance with, the Aviation
Safety and Noise Abatement Act of 1979 and its appendices for regulations
implementing the Act. As necessary, the program must be prepared and delivered
to the FAA for its evaluation. The MAC shall use its best efforts to secure the
FAA's approval of the program or any portion of the proposed program and will
not act in any capacity or communicate with the FAA through any agent or
person, a desire to see the program disapproved. The MAC sha11 obtain the
FAA's approval of the noise compatibility program and notify the City of the
FAA's acceptance or rejection of the said program.
B. In order to minimize the environmental impact of airport operations, the MAC, in
consultation and collaboration with the City, will study, develop, update and
implement policies and regulations for Holman Field to the greatest extent
possible, in the spirit of, or in compliance with, the Airport Noise and Capacity
Act of 1990 which would govem aircraft operation procedures, noise abatement
AA-ADA-EEO Employer
Q6-363
approach and departure procedures and profiles and flight track and other noise
abatement procedures including taxiing and engine runups, lunits on the total
number of aircraft operations and limitations on the hours of operations. The
policies and regulations sha11 be prepared and delivered to the FAA in
consultaxion and collaboration with the City. The MAC shall obtain the FAA
approval of these policies and regulations.
3. In a New Application MAC Must Agree to Promises Already Made to the 1'ublic.
The various statements that the MAC has made to the public or in the form of MAC resolutions
regazding the MAC's commitment to mitigate its Holman Field operations shall be detemuned
and reduced to conditions and imposed on the site plan and variance approvals.
Runwav LenQth. The MAC will not take any action to increase the length of the runways
at the Airport in excess of the current length, unless required to do so by State law,
provided that the MAC will not initiate, promote or otherwise support enactment of such
law.
Pavement Stren¢th. The MAC will not take any action to increase the Runway Pavement
Weight-Bearing Capacity at the Airport beyond the maximum presently available, unless
required to do so by State law, provided that the MAC will not initiate, promote or
otherwise support enactment of such law.
Car�o Operations. The MAC represents that, based on operational and space limitations,
major air cargo operations are not able to use the Airport, nor will the MAC take action to
accommodate such activity.
Endangered/Threatened Snecies. The MAC will coordinate with the City of Saint Paul
and other appropriate agencies to complete an updated survey of threatened/endangered
species within the project area.
Treatment of Contaminated Soils. The MAC will complete additional soil sampling and
testing in the area proposed for compensatory excavation, including testing for PAH's
and inorganics. The MAC will also monitar excavated material from the compensatory
excavation per a Testing and Disposal Plan. Any contaminated soils will be properly
disposed of in a licensed facility approved for such disposal.
Stormwater Dischaz�e. The MAC will complete a sampling/testing protocol for subdrain
discharge, as may be required by the Minnesota Pollufion Control Agency.
CITY OF SAINT PAUL
Christopher B. Coleman, Mayor
March 9, 2006
Ms. Mary Erickson
City Council Research Office
Room 310 City Hall
Saint Paut, MN 55102
Dear Ms. Erickson:
OFFICE OF L[CENSE, INSPECT(ONS �D� —�� y ��
EtiVIRONMENTAL PROTECITON `�.m.
Sob Kessler, Director �
COA�II✓�ERCEBUTLDATG Telephome: 651-2669090
BFwnhStreetEast,Suite200 Facs�mrZe: 651-2669124 �
StPaul,Minnesota551 01-1 024 Web: w�vw.Ziep.us
I would like to confirm that a public hearing before the City Council is scheduled for
Wednesday, April 5, 2006 for the folfowing zoning case:
Appeliant: The appeal +aas filed by Friends of Saint Paul and Ramsey Courtty Parks
and Trails with Friends of the Mississippi River, Audubon Society and
District Councils 1. 3 and 4
File Number: 06-051296
Purpose: To consider an appeal of the Planning Commission's decision to approve a
site plan and variances to allow the Mefropolitan Airports Commission to
construct a flood protection system
Location: 644 Bayfield (Holman Field)
I have confirmed this date with the office of Councilmember Thune. My understanding is
that this public hearing request will appear on the agenda of the City Council at your
earliest convenience and that you will publish notice of the hearing in the Saint Paul Legal
Ledger.
Please calf ine at 651-266-9086 if you have any questions.
Sincerely,
Tom Beach
Zoning Section
H:\COMMON\Sde PIaNBig projects\Holman FieldVequest for cc hearing.doc
NOTICE OF P6BLIC HEARIIVG.
'Rie Saint Paul �ty Councii will condtict a
pubfic hear7n��o�'Wednesday; Apii,l 5,
2006, at 5:3G p.m. Cify Cot�ncil
cnambers, Tti;ra Floor ciry xau, 15 west
Kellogg Boulevard, St, Paui, MN, to con-
sider the appeal of.F'riends of St. Paul aud
Ramsey County Pazks and Trails with
NYiends of theMississippi�River, Audubon
Society, and DistrYCt Councils 1�, 3 and 4
to a decision of the Planning Commission
approving a site plan and"variances to al-
low the Metropolitan A,irports Commission
to construct a�flood proEection.system at
644 Bay&eld Street (Holman FYeldj. - _
Dated: March 15. �20Q6 - �
MARY ERICI{SON ` � � �
'Assistant City-Council Secretary ' � � `
� .� _ � jMaict; 201; ' .
_--_== 81: PekDL TEGAL IEDGE'R —�—
$2112061 � '
AA-ADA-EEO Employer
Tom Dimond
2119 Skyway Drive
Saint Paul, MN 55119
651-735-6667
Apri12, 2006
Mayor Chris Coleman
RE: Airport Dike
�
���
�j � �
�
, �
The West Side and East Side aze neighbors joined by the Mississippi River. The neighborhoods
are also united in our interest to protect and enhance the river, and protect and enhance visual
and physical access to the river. We are joined in that effort by the National Park Service,
Audubon, Sierra Club, Friends of the Mississippi River and Friends of the Pazks and Trails.
For years, the more affluent neighborhoods abutting the Mississippi River Parkway have had
their stretch of the river protected, restored and trails and public access provided. The less
affluent East Side and West Side neighborhoods are tired of being treated as second class
citizens in our City. We no longer will accept that our stretch of the Mississippi should be treated
differently for the benefit of those with money and power.
MAC has run rough shod over this process. A public hearing with MAC has been requested on
numerous occasions. MAC's written response is, they are not required to do so. When
challenged on this point at the Planning Commission meetings, Vicki Tigwell and Jeff Hamiel
have both personally promised they will set up that meeting. Both have failed to do so. To this
day, MAC refuses to sit down and work with the neighborhoods on this issue.
The analysis done by Gregory Page was not comprehensive or inclusive. The neighborhoods
were excluded from the process. Only after complaints about a closed process was one
neighborhood individual allowed to attend. Gregory Page established what questions could be
asked of MAC and the public was barred from asking other questions.
The Page report omits that wetlands mapped by the United States Fish and Wildlife Service and
City of Saint Paul Mississippi River Corridor Plan are impacted by the proposed dike. MN DNR
acknowledged that there is probably wetland along the northern section of the proposed dike.
MAC said there was no report done that disproves the USFWS and City maps. MAC said the
basis for determining that there are no wetlands is "that the box is checked". MACs position is
if they "check the box" that should supercede the USFWS and City maps. MAC proposes
building a section of the dike in the wetland and proposes filling in the wetland behind the dike.
The zoning code places the burden of proof on the applicant to demonstrate conclusively their
claims.
The MAC promised to provide 3 views of the dike from Bayfield Street to show impacts on
views and access to the river. MAC also promised to provide views from the water. MAC has
not provided either.
06-3�3
I agree with Gregory Page's conclusion, that if you were to build the dike, the most significant
mitigation would be achieved by locating the wall as faz inland as possible and reducing its
height. The zoning code requires all shuctures be setback at leastSO feet from OHW. MAC is
proposing as little as zero setback. The zoning code places the burden of proof on the applicant.
Gregory Page conectly states that suggestions made to bring the proposed project into greater
compliance aze not under consideration by the MAC.
The Cost Benefit Analysis submitted by MAC does not use actual floods. MAC claims 9(100
year intensity or less) floods in 50 years. The actual number of floods is 3 in 50 yeazs. That
triples the acrixal event benefits. The MAC claims 206 days duration over 50 yeazs the actual is
148. That increases Yhe duration benefits by 1/3 over actual. The actual return on taxpayer
dollars spent is less than 50 cents on the dollaz.
The cost of the dike is $28.5 million or $9.5 million per flood. The EA lists per flood estimated
damages as just over $3 million. MAC letter dated February 8, 2006 states that a single flood
costs MAC and users $7.2 million. That is a$2.3 million shortfall per flood.
The proposed dike and iPs funding are based on the cost benefits which are based on a survey of
tenant costs cited in Table 3. MAC agreed to provide the public with the survey, but MAC
claims they are having a hard time Iocating that information. The public and City have never
been provided copies. We know the nuxnber of floods and duration of floods are not actual. The
other leg of that three-legged stool has no documentation to support it.
FEMA Region V responses dated Februazy 21, 2006 state that any flood plain management
regulations adopted by the city that are more restrictive take precedence. FEMA also stated that
more restrictive city regulations are encouraged.
In the past, we did not always value floodplains and too often allowed their destruction. The
State of Minnesota designated the river conidor a State Critical Area to protect and enhance it.
Saint Paul adopted regulations that prohibit community wide structural works that remove areas
from the flood plain. The City Council and Mayor agreed that you can protect an individual
structure but you can not remove areas from the flood plain. Zoning Code Sec. 68.101(b)(8)
states that the River Corridor regufations are not to reduce or eliminate floodin�.
Communiry wide structural works intended to remove azeas from the regulatory floodpiain are
not permitted uses in either RC-1 or RC-2 Districts. Sec. 68.102 (d) states that a11 uses that are
not permitted uses or permitted uses subject to special conditions are hereby prohibited.
Zoning Code Sec. 68.601(a) states that variances must be consistent with the provision in Sec.
68.101 not to reduce or eliminate flooding. Sec. 68.601(a) states that although variances may be
used to modify permissible methods of flood protection, no variance shall have the effect of
allowing in any district uses prohibited in that district.
Zoning Code prohibits the dike in river corridor zoning districts. Vaziances are not allowed for
prohibited uses. The City Council is required to deny the variances and site plan.
Ob-3�3
I encourage your support of the City Council decision. I hope you will support their decision
based on the merits of supporting the Zoning Code and Mississippi River Corridor Plan.
If for some reason you do not support the efforts of the City Council and neighbof3ioods, I would
hope you would forgo a veto based on a practical co�sideration. If there is a veto of City
Council action the dike still can not be built. A veto would only allow alteration of the river at
a cost to the taa�payers of $6.8 million.
The Planning Commission has placed conditions on the variances and site plan. MAC can not
begin construction of the dike without City Council approval of revisions to the River Corridor
Zoning Map. Zoning Code Sec. 68.601 requires City Council approval of any change,
amendment or supplement of district boundaries or regulations. If the Citv Council does not
support construction of the dike the dike can not proceed veto or not.
Sincerely,
Tom Dimond
��-���
Comments from:
Kathi Donnelly-Cohen
2150 Valley V'sew Place
St. Paul, MN 55119
April 5, 2006
Council President Lantry, council members, my name +s Kathi Donnelly-Cohen
and I live at 2150 Valley View Place in St. Paul. That is located in the Highwood
neighborhood and in the final approach path of traffic to Holman Field.
In the spirit of full disclosure, i am a member of the St. Paul Planning
Commission and a member of the Zoning Committee of that body as well. And I
did vote to approve this in both bodies. However today I am not here today
representing the Planning Commission. I drive down Warner Road to and from
work each day and my office is located the river and I see the airport right out my
window. I am also the wife of former mayor Larry Cohen who was and is a huge
environmentalist. I am here as an interested resident of St. Paul.
This is a very serious issue and f applaud the ardor of those who oppose this
issue. The river is a very valuable and precious part of St. Paul. Over the past
few years we have worked to clean up the river and its bank - removing a scrap
yard and replaced it with the Science Museum and needed housing which will
continue to grow over the next few years. While it would be great to have a
walking path along the river in this area, my understanding is that it is the TSA
(post-9-11 security concerns) that would not allow that, not the construction of
this levee. Visually, I would love to see the use of public art in some way to tone
down the wall in addition to the plantings the MAC proposes.
I believe that the editorial in this morning's Pioneer Press said it best. The
reliability of this airport is critical to the current St. Paul businesses as well as the
ability to attract new headquarter operations. An airport that is available 365
days a year, not "most of the time". You all have the same studies and reports
that I have and the letters pro and con. For the economic future of St. Paul, I
encourage you to deny the appeal and let the project go forward. Thank you.
o�-���
Holman F'ield Dike — We Can Do Better!
By Dan McGuiness and State Rep. Sheldon Johnson
For the last two years community members, elected of�icials, and consultants have been
gathering to talk about the idea of a Great River Park along the Mississippi River in St.
Paal. Excitement has grown as this community-based pianning process has helped create
a vision of a St. Paul river&ont that is more urban, more green and more connected to our
neighborhoods. We have been working together, as a cpmmunity, to define not only
what this riverfront should be but also how we could then all work together to achieve
our goals.
Early on during this process we also agreed that going about riverfront development in
this manner would be far better than fighting land use and development battles one at a
time — pitting "environmental" and "economic" interests against each other time after
time, with t�e City hauing to cons'tantly be in the middle. And we have been working
together and a community-based plan and a vision are emerging — except when it comes
to the future of Holman Field.
Now the City is faced with deciding whether or not to react to a permit request by the
Metropolitan Airports Commission (MAC) to construct a 1 1/3 mile dike and up to 15-
foot high sheet pile wall along the river at Holman Field. Not only would this be visually
inttusive, but, intended or not, it woutd set the stage for yet additionai future devetopment
in the Mississippi River floodplain. Making a decision to approve this dike, fucther
restrict Yhe floodplain, and to enable, if not encourage, more development (especially if
someday someone suggests converting the airport lands to some other uses) is not good
public policy.
If a decision today to approve a dike is not good public policy, then we need to ask,
"What is good public policy?" The best public policy is proactive, not reactive. We can
do better for our community and its world-class river. Instead of simply reacting to
MAC's proposal we should work together to develop a new master plan for Holman Field
and then take steps to achieve that vision. We coWd start with the following elements:
We should protect the investment in buildings that are already there by designing
flood protection for the already-built parts of Holman Fie1d.
We should continue to allow the rest of the airport (grassland and runways) to be
used by people as an airfield the great majority of the time, and for flood storage
during the few days each decade that the river needs this space.
We should remove the temptation to further develop the floodplain at this site by
placing a permanent conservation easement on the runway and open space lands
so that, for as long as we want to use tlus area as an airport we can. Should it
someday no longer be desirable or necessazy to have an airport here, the lands
would continue to be protected as open space for conservation, habitat, river
access and river-related recreational purposes.
We should design a natural buffer and public pathway along the riverbank so that
we can continue to use the area £or an airport but also have better public access
and better habitat next to the river for all to enjoy.
This is a more thoughtful approach and would ailow a11 of us to fill in the details together
as part of a community-based master plan for Holman Field within our Great River Park.
This is a better idea than simply reacting to a request to build a dike and then having to
live with a decision that, in reality, does not need to be made today — and should not. We
think that the City Council and Mayor can do much better for our City. We are capable of
making better pubiic policy and the Great River Park framework provides us with the
tools to be better policy-makers and citlzens.
Dan McGuiness is the Audubon Director, Mississippi Itiver Program. He can be reached
at G51.739.9332. State Rep. Sheldon Johnson represents District 67B, which rncludes
several miles along the Mississippi. He ean be reached at 651, 294.4201.
Dis�iet 6 Planning C�ungit o�-���
...
213 Front Avenue
St Paui, MN 55117
Phone 651 488-4485
Fax S51 488-4343
Date: February 6, 2005
To: Sairrt Paui City Council and Mayor Chris Coleman
ward1-7a�ci.stpaul.mn.us, mavorc(�.ci.stpaul.m_n.us
City Hall Rooms 310A 310B, 310C, 310D, 320A, 3206, 320C, 390
15 West Ketlogg B1vd.
Saint Paul, MN 55102
Re: Hoiman Field Airport Dike Project
Dear Mr. Mayor and City Council:
On March 22" 2006, the District 6 Planning Council Land Use Taskforce met and
voted unanimously to oppose the proposed project due io the likely negative impact on
the environment and quality of life of St. Paul residents in general and District 6
residents in particufar, particularly in regard to increased naise pollution.
If there are any further questions or concerns from any of the parties involved, District 6
Planning Council can be reached at 651-488-4485. Thank you.
�G��
Jeff Martens, Land Use Task Force Chair
District 6 Planning Council
Tom D�ond 0 6— 3 6 3
2ll 9 Skyway Dzive
Saim Paul, MN 55119
651-735-6667
Apri12, 2006
Mayor Chris Coleman
RE: Airport Dike
The West Side and East Side are neighbors joined by the Mississippi River. The neighborhoods
aze also united in our interest to protect and enhance the river, and protect and enhance visual
and physical acces to the river. We are joined in that effort by the National Park Service,
Audubon, Siena Ciub, Friends of the Mississippi River and Friends of the Parks and Trails.
For yeaxs, the more affluent neighborhoods abutting the Mississippi River Pazkway have had
their stretch of the river protected, restared and trails and public access provided. The less
affluent East Side and West Side neighborhoods are tired of being treated as second class
citizens in our City. We no longer will accept that our stretch of the Mississlppi should be treated
differently for the benefit of those with money and power.
MAC has run rough shod over this process. A public hearing with MAC has been requested on
numerous occasions. MAC's written response is, they are not required to do so. When
challenged on this point at the Planning Commission meetings, Vicki Tigwetl and 7eff Hamiel
have both personally promised they will set up that meeting. Both have failed to do so. To this
day, MAC refuses to sit down and work with the neighborhoods on this issue.
Tke analysis done by Gregory Page was not comprehensive or inclusive. The neighborhoods
were excluded from the process. Only after complaints about a closed process was one
neighborhood individual allowed to attend. Gregory Page established what questions could be
asked of MAC and the public was bazred from asking other questions_
The Page report omits that wetlands mapped by the United States Fish and Wildlife Service and
City of Saint Paul Mississippi I2iver Corridor Plan are impacted by the proposed dike. MN DNR
aclmowledged that there is probably wetland atong the northefn seetion of the proposed dike.
MAC said there was no report done that disproves the USFWS and City maps. MAC said the
basis for deternuning that there are no wetiands is "that the box is checked". MAC's position is
ifthey "check the box" that should supercede the USFWS and City maps. MAC proposes
building a section of the dike in the wetiand and proposes filling in the wetland behind the dike.
Tke zoning code places the burden of proof on the applicant to demonstrate conclusively their
claims.
The MAC promised to provide 3 views of the dike from Bayfield Street to show impacts on
views and access to the river. MAC also promised to provide views from the water. MAC has
not provided either.
� Q6-363
I agree with Grregory Page's conclusio� that if you were to build the dike, the most significant
mitigation would be achieved by locating the wall as far inland as possible and reducing its
height. The zoning code requires all structures be setback at teast 50 feet from OHW. MAC is
proposing as little as zero setback. The zoning code places the burden of proaf on the applicant.
Gregory Page correctly states that suggestions made to bring the proposed project into greater
compliance are not under consideration by the MAC.
The Cost Benefit Analysis submitted by MAC does not use actual floods. MAC claims 9(100
yeaz intensity or iess) floods in 50 years. The actual number of floods is 3 in 50 years. That
tripies the actual event benefits. The MAC claims 206 days duration over 50 years the actual is
148. That increases the durarion benefits by 1/3 over actual. The actuat retum on taxpayer
doilars spent is less than 50 cents on the dollar.
The cost of the dike is $28.5 million or $9.5 million per flood. The EA lists per flood estimated
damages as just over $3 mlilion. MAC letter dated February 8, 2006 states that a single flood
costs MAC and users $72 million. That is a$23 million shortfall per flood.
The proposed dike and it's funding are based on the cost benefits which are based on a survey of
tenant costs cited in Table 3. MAC agreed to provide the public with the survey, but MAC
claims they are having a hard time locating that information. The public and City have never
been provided copies. We know the number of floods and duration of floods aze not actual. The
other leg of that three-legged stool has no documentation to support it.
FEMA Region V responses dated February 21, 2006 state that any flood plain management
regulations adopted by the city that are more restrictive take precedence. FEMA also stated that
more restrictive city regularions are encouraged.
In the past, we did no# always value floodplains and too often allowed their destruction. The
State ofMinnesota designated the river corridor a State Critical Area to protect and enhance it.
Saint Paul adopted regutations that prohibit community wide structura't works that remove azeas
from the flood plain. The City Council and Mayor agreed that you can grotect an individual
structure but you can not remove azeas from the flood plain. Zoning Code Sec. 6&101(b}(S)
states that the River Corridor regulations are not to reduce or eliminate floodin�.
Community wide structurai works intended to remove areas from the regulatory floodplain are
not permitted uses in either RC-1 or RC-2 I}istricts. Sec. b8.162 (d) states that all uses that aze
not pemutted uses or permitted uses subject to speciai conditions are hereby prohibited_
Zoning Code Sec. 68.6�1(a) states that variances must be consistent with the provision in Sec.
68.101 not to reduce or eliminate flooding. Sec. 68.601(a) states t12at although variances may be
used to modify permissibte methods of flood protection, no variance sha11 have the effect of
allowing in any district uses prohibited in thaY district.
Zoning Code prohibits the dike in riwer corridor zoning districts. Variances aze not ailowed for
prohibited uses. The City Council is required to deny the variances and site plan.
;
06-3�3
I encourage your support of the City Councii decision. I hope you will support their decision
based on the merits of supporting the Zoning Code and Mississippi River Corridor Plan. '
ff for some reason you do not support the efforts of the City Councii and neighborhoods, I would
hope you woutd forgo a veto based on a practical consideration. If there is a veto of City
Council action the dike still can not be bui1L A veto would only allow alteration ofthe river at
a cost to the ta�cpayers of $6.8 million_
The Plauning Commission has placed conditions on the variances and site plan. MAC can not
begin construcrion of the dike without City Council approvai of revisions to the River Comdor
Zoning Map. Zoning Code Sec. 68.601requires City Council apgroval of any change,
amendment or supplement of district boundaries or regulations. Tf the Citv Council does not
sunport construction of the ditie the dike can not proceed veto or not
Sincerely,
'' •�J�l/ ��
Tom Dimond
.,
t .
Airport Dike Facts - April 2006 _
0 � � . .�
Cost $28.6 million
Compensatory excavation cost $6.8 million
The dike would have protected the airport from 3 floods in 63
years
From 1943 to 2006 there ha�e been 3 floods within the design
limits of the dike (100 year intensity).
The dike would have prevented an average closure of 2.3 da,ys a
year over the last 63 years. 148 days closure divided by 63 years.
The cost of the dike is $9.5 million per flood. $28.5 million
divided 3
MAC claims the dike will save MAC and it's tenants $72 million
per flood.
The dike adds $23 million to the losses incurred by each flood.
The dike shifts the cost from those who built at their own risk in
the flood plain to the taxpaYers.
The dike can not be constructed unless the majority of the City
Council approves a zoning change.
! °
f
U
L
7
O
�
�
c
�
G
3
�
..
Q
N
U
C
d
�
L
U
R
Q
�
F
O
F
° o ° o 0 0
o O a
t��t o o c�V
N Ki ^ G?
.cimm m
cr — v
Efl Eif 4H �A
���R �
� m
. �oor- o
ooe+ o
ivooN a
� O �
t�[a O � m m
Q m CV V. CI
. � N
F� fA fi� fA �1 fN
p O
p O
m p o
0 0 0
a m m ,
tr pp m
� �
o n
0 0
0 4
r' o 0
o.
� � v C
N N ' n
(ry E9
O �
� O O
O Q m
N ` �
Vi �
p D
O o
P
� O �
� . o �
ry ' '
N C`i
� R�r
0 0 '
o r,5
0 0
b O O
o m m
N � �
� �
^ Q---o"""" —"_�
M1
o n �"
� . W
O CV C! �?
p �j u7 ' Q
G3
O
O
r
m
69
0
0
0
N
N
�
O
O
O
O
r
VA
O
0
O
O
0
�
4�
0
0
0
O
O
a
m
�
� � � � N o
m w � o
0 o m o 0 0
cv o 0 0 0 0
� p m O
.- O N 0 O N
Q� Q O C m
� � = � Q
EN ifl � � �
O �
� O
O � -
o �
Q � 4!
G
� � �
o a d
fl Q o
, �Ij p O
N Q
C
� � �
O �
o O p
O
p � �
y� (q 4A
p o p o o O O
P Q p p q O O
a o 0 0 0 0 0
p p O O O O
° Q cv m c o o f�
� C ' '� � cv
+Yf fN iA iN d� �N �
d � � � a
0 0 0 �
° o_ o a q
p O o O �
O
Q [V Cfl � m.
,_. m
cn E» v� v9 `�
_.. �. o -- m - --- — - o
n o 0
m O
^ N �
v O N
C" V U]
� (� fA (9
FA V1
0
Q
3
0
C
3
0
3
m
0.
y
�
� �
� £
m
T X y
N � �
C � t
m o 4
� U
a m o
� � �
m a w
� a,
_°_
a��
UJ
Q •�e m `� r-
� h � � � � �
� �- � � �
m `
m y m E '° �
3 m p u� 8 N� �m �
C C t� Q 0 6
�U L� � Q 'O }` � � � C� G
�J '.� V m q � m �+�` m
y q= m o lL � �£� fi .r 7
b c � A � 'M � � �
. U q� Q. - R � m � T/1 � CI 0
3 � m o w� ? � c � � W U
0
"' aaw�� Q W �, m
a� a � U�c � U � >
� � � q 4
" a Vj $� 4
t
3
- LL
�
a
�
� �
m �
W �
e _
0 '
„ m
O V
v �
d m
� �
��
m
? o
m �
� �
w
� O
o �
� �
�
��
m
• <
0. �
SaiEe'd £iS8 99z TS9 ��I��O S�?J0,1CW �fltld '1S 9S:ZT S06Z-60-H3�
.�
,
;
��-���
St. Paul Downtown Airport Improvement Project
Questions and Answers ' �
Question 8: Will the benefits for the floodwall justify the cost?
Answer:
The benefits of the floodwall far outweigh the cost.
• St. Paul Downtown Airport has flooded seven tnnes in as many decades. Floods closed the
airport in 1941, 1942,1965,1969, 1993,1997 and Z001.
• A single flood event typically costs the MAC and airport usexs $7.2 million
• The floodwall and airfield safety enhancement project wiil bring $20.1 million in addirional
federal dollazs into Minnesota. These dollazs come from fees paid by aviation users, not
from the general tas base.
• The Metropolitan Airports Commission developed a cost-benefit analysis that was reviewed
and accepted by the Federal Aviarion Administration when approving funding far the
project.
1i � r E !� ' �
1 v .�'
0
beiag issued. The project must atso obtain an NPDES permit from the MPCA that will also
address these issues.
NOW, ��rORE, BE TT RESOLVED, by the 5aint Pau1 Planning Commission, under the
authoriry of the Cit�s Izgislattve Code, that the applicatian the Metropolitan A:rports Co:nmission
for site plan review for tfie establishment of a flood protectian system aad compensatory excavation
at 644 Bayfteld Street is hereby approved, subject to tfie foIlowing eoaditions:
1. Work on the Compensatory Excavation cannot begin until MAC obtains all other required
appravaIs including tfiase from the Army Corps af Eagineers, Minnesota Patlution Com*ol
Agency and tfle Minnesota Departme�rt ofNaxural Resources.
2. Work on the Levee / Flood Cantrol 5ystem cannot be begin vntil MAC obtains all required
agprovals as specified in Section 23 ofthe Fi�ta1 EnviraunmenYal Assesssnent (Ilece�ber 20Q5}.
As part af these approvats, FEMA must issue a Letter of Map Revision for the boundary of the
flaodway and the City Council must approve a revision to the River Carridor Zoning Map
based an FEMA's ac#ions so tttat a poriion of the ai�ort where the tevee woufd be built is
rezoned from RC I(Floodway) to RC2 (Flood Fringe).
inoved by Morton
secondetd �y
in favor 15
agai�st 4(McCail, LU, G6rdc�n. Kramerl
Mailed: February 27, 2006
I:1.9MAN4AMERG�ZONING\SAVEV5592282094.DOC
approve site pI�
o�-���
The FAA forecast of based aircraft and operations is based on local and natio�al growth trends, 7
which are not affected by the proposed perimeter dike project. Implementation of the proposed "
perimeter dike project would not change the forecast. The same number of operarions is forecast
with and without the proposed project. Therefore, project improvements would not result in an
increase in airport operations.
PERIME'I'ER DIKE PROJECT
STP has experienced a long history of flooding from the adjoining Mississippi River. Flood
events in 1965, 1969, 1993, 1997 and 2001 rendered the airfield inoperable for 210 days
collectively, causing significant financial impacts to auport tenants, airport users, local
businesses, and the Twin Cities in general. The durations of runway closures from past major
flood events are shown in Table 1.
Table 1. Runway Closures from Major Flood Events
Year of Flood Flood Iutensity Duration of Airf'ield
Closure (davs)
1997
2001
31
31
35
35
78
MAC currently has a plan in place for how to proceed when a flood event is forecasted. Normal
river elevation is approximately 690 feet. When the flood stage reaches elevation 695 feet
during a flood event, impacts to the airport's infield and outlying perimeter areas occur at STP.
At this point, MAC closes two runways and aircraft operations are restricted to the primary
Runway 14J32 and major transition taxiways. At elevation 695, the southern stretch of Taxiway
E along with portions of Ta�iways P and A are flooded. The e�usting �eld is shown in FYgure
3.
At flood elevation 699 feet, the midpoint of primary Runway 14/32 is flooded and the airfield is
completely closed. By this time, MAC will have taken measures to close the airport terminal
building and protect it by flooding the basement. Both MAC and the FAA remove aufield lights,
navigational equipment and other electrical related fixtures from the �eld.
Airport tenants are faced with certain decisions when a flood is forecast. If fihey are located in
the south building azea where the floor elevations of the structures are above the,100-yeaz flood
elevation, they have the option to close down operaflons entirely for the durarion of the flood
(since they cannot fly in and out of the airport) or relocate operations to another airport (normally
one of the other five relievers or to MSP). Those in other building azeas with floor elevations at
700 feet must provide temporary flood protection measures (such as sand bags), or more likely,
they are required to open up their hangar doors and allow the structures to flood internaliy. They
must also decide whether to close operations entirely for the flood duration or to temporarily
relocate operations to another airport.
F'inal Environmental Assessment - St. Paul Downtown Airport PerirreeEer Dike & RSA lmprmements Project
S
0�'
�
- �
a
Following is the text I will be presenting
to you today.
The right margin contains references to
transcripts and other documentation,
copies of which are attached for your
convenience and reference.
Thank you for your time in this matter.
OPPENHEIMER
OPPENHEIMER WOLFF & DONNELLY uP
• Plaza VII, Swte 3300
45 South Seventh S[reet
Minneapolis,MN 55402-1G09
612.607 7000
Fax 612.607 7100
DirectDia] 612.607.7334
E _Mail: ceiden@oppenheimer.com
Apri15, 2006
VIA PERSONAL DELIVERY
Ms. Debbie Montgomery (Ward 1)
Mr. Dave Thune (Ward 2)
Mr. Pat Harris (Ward 3)
Mr. 7ay Benanav (Ward 4)
Mr. Lee Helgen (Ward 5)
Mr. Dan Bostrom (Ward 6)
Ms. Kathy Lantry (Ward 7)
St. Paul City Council
15 West Kellogg Boulevard
St Paul, MN 55102
• Re: Appeal of Planning Commission Resolutions -- File Nos. OS-17 and 05-18
Dear Councilmembers:
0�-3b3
We were asked to analyze ownership issues related to certain levee land located at the St. Paul
Airport, also known as Holman Field, when this issue was raised by the City Attorney of St. Paul
7ohn Choi in an e-mail sent to Tom Anderson, Generai Counsel for the Metropolitan Airports
Commission ("MAC") at 5:27 p.m. on Tuesday March 28, 2006 (see Tab 1). We warked with
MAC's counsel John Kedrowski to draft the letter sent on March 31, 2006 in response to Mr.
Choi's letter (see Tab 2). We have been asked to provide you with the underlying docuinents we
examined related to this recently raised ownership issue.
As you are aware, St. Paul City Code section 61.301 permits an entity "having an ownership or
leasehold interest in the subject land andfar building (contingent included)" to ap�ly for site plan
review, variances, and other zoning decisions made by the planning commission. As an owner
within the meaning of the aforementioned code section, MAC applied for site plan review and
variances under File Nos. OS-17 and OS-18, and the planning commission approved MAC's
applications.
First, the Compensatory Excavation is located on airport property and therefore, MAC has
statutory ownership interest in the land at issue. Pursuant to Minnesota Statutes section 473.621,
the Metropolitan Airports Commission was given authority to use and control all airports owned
• by St. Paul whether "Yitle thereto is held in the name of the city, the council, a board of park
commissioners, or any other body". The levee land where the Compensatory Excavation will
OPPENHEIMER
OPPENHEIMER WOLFF & DONNELLV LLV '
. St. Paul City Council
Page 2
0�-3; �
take place ("Levee Land") was (i) ori�inally dedicated for levee purposes in favor of the City of
St. Paul ("City") in the 1800s in plats of CampbelPs Addition (see Tab 3, Mariarity's Addition
(see Tab 4, West St. Paul Real Estate and Improvement Syndicate Addition No. 3(see Tab 5,
and West St. Paul Rea1 Estate and Improvement Syndicate Addition No. 4(see Tab 6), (ii)
conveyed on March 23, 1892 to the City "for the sole use and purpose of a public street and
levee" (see Tab 7, and (iii) taken by the City by condemnation for levee purposes to the extent
said land was not already dedicated for levee purposes by any plat or conveyed to the City for
levee purposes (see Tab 8 .
In 1929, the State of Minnesota first enacted the stat�zte (presently codified at Minnesota Statutes
section 469.054) enabling cities to transfer to their port authority any waterfront or riparian
property owned by those cities. In 1934, the City transfened its waterfront property that had
been dedicated, conveyed and taken by the City for levee purposes, including the Levee Land, to
its port authority ("Port Authority") (see Tab 8 pursuant to a deed that also expressly prohibits
the Port Authority from selling ar exchanging the Levee Land without the approval of the St.
Paul City Council. Said conveyance may have tra��sferred less than fee title absolute in the
Levee Land to the Port Authority, with the City retaining a reversion-like interest because of its
right to approve any sale or exchange of the Levee Land. The Ramsey County Half-Section
� Parcel Maps show the City as the holder of the fee title to a11 portions of the Levee Lazzd not
covered by an existing 1985 easement granted by the Port Authority to MAC (see Tab 9).
Therefare, MAC has an ownership interest in the Levee Land under Minnesota Statutes section
473.621 because (i) the Port Authority, as an "other body", has been transferred an interest in the
Levee Land and (ii) the City retained the ability to have its City Council approve any sale or
exchange of the Levee Land.
MAC has additional direct ownership interests m the Levee Land. MAC has always operated
and controlled the St. Paul Airport without regard to fact that St. Paul holds fee tifle to the north
half, MAC holds fee title to the south half, and the Port Authority holds an interest in the Levee
Land. MAC has exhibited such control with the City and Port Authority's knowledge and
consent In 1985, the Port Authority granted MAC a permanent easement to a significant portion
of the Levee Land (see Tab 10). As part of this project, the Port Authority has confirmed in
writing it will formally grant MAC whatever property rights are necessary for the Compensatory
Excavation work (see Tab 11 . Accordingly, MAC holds the same equitable interest as any
purchaser under a purchase agreement, and the planning commission has granted approvals in
the past to parties that do not hold fee title. In one example tl�e pianning commission granted a
zoning approval to the Port Authority before the Port Authority held fee title to the iand; the
Resolution expressly states that the applicant merely had entered into a purchase agreement for
•
OPPENHEIMER
OPPENHEIMER WOLFF & DONNELLY LLV
� St. Paul City Council
Pa�e 3
�s-���
the land (see Tab 12 . In another example the planning commission granted a zoning approval to
a contractor that was not the fee owner of the land (see Tab 13 .
Sincerely,
OPPENHEIMER WOLFF & DONNELLY LLP
�� �
Carol Ann Eiden
CAE:cb
Enclosures
�
�
� -._
a
Page 1 of 2
06-363
Eiden, Carol Ann
• From:
Sent:
To:
Anderson, Tom [TWAnders@mspmac.org] �
Tuesday, March 28, 2006 9:40 PM
Rasmussen, Pamela; Kedrowski, John; Boyd, Cameron; Eiden, Carol Ann; Rief, Bridget
Subject: FW: MAC Holman Field Application
Attachmenfs: John Choi.vcf
-----Original Message-----
From: John Choi [mailto:John.Choi@ci.stpaul.mn.us]
Sent: Tuesday, March 28, 2006 5:27 PM
To: twanders@mspmac.org
Cc: Jerry Hendrickson; Peter Warner
Subject: MAC Hofman Feld Application
Tom,
•
As we discussed today, my office has had the opportunity to further investigate the MAC's
ownership of land around the perimeter of Holman Field and, in particular, land that was
outside the City's original transfer of land to MAC pursuant to the 1943 legislation that
created the MAC. Our investigation leads us to believe that the MAC neither owns nor has a
leasehold interest in a�l or parts of the land on which the MAC proposes to undertake
"compensatory excavations" as part of the proposed floodwali. In fact, the MAC agrees with
this conclusion.
Saint Paul Leg. Code § 61301(a) requires all zoning app(icants to demonstrate that they have
an "ownership or leasehold interesY' in the subject land for which a zoning appiication has
been made. Without such an interest, the MAC is not eligible to receive Ciry approval of the
zoning applications it has submitted. Although a"contingenY' ownership interest is
contemplated by the City's ordinance, the MAC has not demonstrated such an interest as a
part of its appiication.
Accordingly, I am prepared to advise the necessary City o�ciais that the MAC's zoning
appiications are incomplete at this time and cannot be approved because of the ownership
problem. In addition, Minn. Stat: § 15.99, also compels me to advise tliat the MAC's
applications shouid also be rejected because of the time provisions of that statute. If the
MAC would like to withdraw its applications before the public hearing ort Aprii 5, 2006, please
tet me know, in writing, as soon as possibie.
Please feel free to cail me at 651.266.8717 to discuss this further.
Sincerely,
)ohn J. Choi
City Attorney
•
3/29l2006
�
O6-3b3
METROPOLITAN AIRPORTS COMMISSION
• eP��tS 59iy1
E T
2 y 9
F
; o
:t t w
0
O �
♦ f G
', M1 '��RGOF T%
March 31, 2006
Minneapolis-Saint Paui International Airport
6040 - 2Rth Avenua Sou[h • Minneapolis, MN 55450-2799
Phone(612)726-R100
VIA FACS7MILE AND EMAIL
Mr. John Choi
City Attomey
Office of the City Attorney
400 City Hall
IS West Kellogg Boulevard
Saint Paul, MN 55102
RE: Appeal of the MetropoIitan Airports Commission Application for a
Variance-644 Bayfield Street (Holman Field)
City File No. 06-000.752
Deaz Mr. Choi:
• This letter is in regud to Uie Metropolitan Airports Commission's ("MAC"} application
for a variance from the City of St. Pau1's ("City") zoning code for construction work at
Holman Field. A public hearing on an appeai is scheduled in front of the City Council on
Apri15, 2006.
On Mazch 28, 2006, you wrote to MAC's General Counsel, Thomas Anderson, regarding
MAC's ownership or legal interest in the property involved in the variance. Since then,
similar remarks have become the subject of newspaper stories. In those remarks, you
indicated that MAC does not own or have a]egal interest in the property, and that the
code requires MAC to demonstrate its interest.
In previous conversations with your office, MAC asked about the interpretation of
ownership and the "contingent inclu@ed" language in the City's code. The response from
an assistant city attorney was that MAC's interest in the property was no different than
other requests whereby applicants without an ownership interest were allowed to file a
variance request. MAC relied upon this response. MAC's application conrinued through
the variance process and was ultimately approved by the Planning Commission.
In addition, your recent remarks appear to be inconsistent with the St. Paul City Code.
Pursuant to seciion 61202(b}, the Planning Commission acted as the final decision-
makex with regazd to granting MAC's variance appiication. Assuming for purposes of
argument only that MAC did not demonstrate an ownership interest in its application, the
Planning Commission has waived the strict reGuirement interpretation. Under Section
61.6Qt, the Planning Commission, acting as the board of zoning appeals, by accepting
• The Metropolitan Airpnrl Commivu>n is art affirmative achon employcr.
www.mspaup��Lmm
Neiicvn A'uporls AIRI.AKE • ANOKACOUNIYJBLAINE . CRYSTAi. • FLYMG C}AUU • LAKE ELEAO • SAINT FAOL DOWNTOWN
Mr. John Choi, City Attomey
Mazch 31, 2006
• Page 2
06-���
and approving the variance has waived the requirement for strict enforcement of the code,
speci£lcally the application requirements contained in section 6130t. Or, in the
aliemative, the Planning Commission discussed the ownership issue at its hearing. The
Planning Commission weighed the ownership interest, waived the issue ia regards to che
variance and decided in MAC's favor.
For your office to change its opinion at this late stage of the process (after MAC's
reliance and the Planning Commission's decision) is inconsistent and appears arbitrary.
It appears that yon have reached a conclusion regazding ownership without providing
MAC any due process to demonstrate its ownership. The City Attomey's Office cannot
simply come to a conclusion and recommend that MAC withdraw its application. The
variance application has been approved.
If the City Attorney's Office is going to interpret the code strictly despite the Planning
Commission's approval, then MAC believes that the City Council does not have the
power to hear the appeal. Section 61.702 of the code states that the city council has the
power to heaz and decide appeals where it is alleged that "there is an enor in any facf,
procedure or finding" made by the Planning Commission. Said section requires that an
appeal must be filed by "any person, firm or corporation or by any office, department,
board or bureau affected by" the Planning Commission decision. Cer[ain citizen goups
• filed this appeal of the Planning Commzssion's ruling under section 61.�02 of the City
Code. In Stanseil v. Citv of Northfield., 618 N.W.2d 814 (Minn. Ct. App. 2000) a
citizen goup filed an appeal of a zoning decision allowing large-scale retail
establishments. The citizens azgued that they had standing to chatlenge the decision as
members of the community Ihat were allegedly "injured" as a resul[ thereof. The
Minnesota Court of Appeals held that "[pJersons who wish to bring suit on a matter of
public interest must demonstrate `either (1) damages disrinct from the public's injury, or
(2) express statutory authority."' Minn. Stat. section 462361 pem�its "aggrieved"
persons to appeal zoning decisions, and the Minnesota Court of Appeals defined a
"person aggrieved" as a person who suffered particularized injuries on property rights or
personal interest. Id. At 819. The code's use of the word "affected" means that the
citizen group(s) fi]ing the appeal must also have a particularized adversely affected
property right or personal interesi and cannot simply file the appeal as a member of the
general pubiic alleging geneial adverse affects. In the cunent appeal, the citizen groups
have failed to demonstrate standing as an affected party under the code.
Also, your office's opinion is inconsistent with the City's past practice. Previous
variance and zoning applications have been filed where the applicant did not have an
ownership or lease interest. For example, in 200Q the City accepted and began
processing MAC's application for a dike on Eaton Street, even though NfAC was still in
discussions with the St. Paut Port Authority (`Tort Authority"} about a potentiai easement
for the property.
•
06-363
Mr. 7ohn Choi, City Attomey
• March 31, 2006
Page 3
Notwithstanding the potenfial problems with your office's new intecpretation of the code,
the timeliness of the notification, and the appellants lack of stantling, MAC easily meets
the "ownership or leasehold interest in the subject Iand andlor building (contingent
incladed)" requirement of the code. First, MAC's clear ownership interest sfems from an
easement ganted by the Port Autharity to the MAC in 1985. While not recorded in the
county recorder's index, the express written easement demonstrates that MAC has an
ownership interest. A copy of the easement is attached.
Another way that MAC is able to demonstrate an interest in the property is throngh a
"contingent interesY'. MAC's contingent interest appears in Iwo unique ways that have
already been presented via the March 27, 2006 fetter fram the Saint Paul Port Authority
to you. As acknowledged to you in that letter, MAC has the power of eminent domain to
take the property from the Port Authority. In addition, the letter indicates the Pod
Authority's "willingness to grant to the MAC the property rights necessary for the
project, should the City approve the project" MAC's ability to use eminent domain and
the possibility of acquiring praperty through negotiation would be contingent on MAC
receiving a variance. To require MAC to take such steps prior to submitting an
application for a variance would be contrary to common practice. Regardless, the
express language from the Port Authority letter demonstrates that MAC has a"contingent
interest" in the property.
• Third, MAC can demonstrate an equitabie interest in the property, or at a minimum, a
quasi-lease interest. Under Minn. Stat. §473.621, subd. 2, MAC statutorily owns the
right to use, manage, operate, regulate, police and control "any and all airports owned by
either the city of Minneapolis, or St. Paul, whether the airport or title thereto is held in the
name of the city, the council, a boazd of park commissioners, or any other body."
Through this statute and many years of common practice, MAC has been exeroising
exclusive use, control and maintenance of the subject property. MAC maintains tt�e
grounds, cleans the debris and controls access to the property. The Port Authority has not
actively exercised any degree of controt or use over the property in many years.
Lastly, the unique characteristics of this property, the relationship between the Port
Authority and MAC, and the proposed praject must be taken into account when
determining any interest. This property is zoned for airport use. MAC, as the political
subdivision created by the State of Minnesota to further various aviation purposes,
operates and controls the property as an airport. T1ie Port Authority has tong recognized
MAC's ability to regulate Port Authority-owned ptoperty at the airport. The
compensatory excavation will further MAC's interest, and the airport tenants' abitities to
continue working, during river flooding. In addiUon, MAC's proposed work will assist in
protecting others from fhe significant financial and ocher inherent costs associated with
flooding problems.
u
06-363
Mr. John Choi, City Attomey
March 31, 2006
• Page 4
MAC can cleazly show an ownership interest, contingent interest and a quasi-lease
interest in the subject property to sarisfy the requirements of section 61301.vaziance
process. Even though the Planning Commission has already granted MAC the variance,
your summary conclusion stating that MAC's zoning application is incomplete, could
deprive MAC of the variance. The only recourse appears to place MAC in an unenviable
position of challenging the City's authority and interpretation of the code, due process
violations and the azbitrariness in regards to enforcemen[ of the code.
Before making any new intecpretation of the City's code and adversely advising City
officials about the ownership issue, MAC urges you to reconsider your position in light
of the material contained in this letter.
5incerely,
\) �. KP�'�
John R. Kedrowski
Attomey
Ntetropolitan Aitports Commission
u
C\SlweNko4wslS� Aul Flwl AyMLLaV IoblinOiu Ol-)1-0blJ)4[
.
n
� �
•
•
@
l'I
_ '' �E`;=:�':�i��'�3�'� � 9 .�'
� - ��bz�'xoz•('
- TO ST PAVL �JIINN_ "
�. L�i� � 1 _��5�.�...._- {
,
�h
\ •�K.:...��-
�
\'.
\
,�' `l.
,�\ , N
!�
� i. .
1 " ' m.
Fi:' �
1 � R 1 -
.i• .
\i
������::�.L��.u.:u,.��:�� �.- : y . ����_....:�;.: -- �.\
� �a.,.c�. �f;;.o u< :»enk:_i... T "w.R �. ..,i4 v�.�..sc�G ` °..;-(— � .l:_la,�. c �.`:,�.. _._ , -\
�ca.. .�� , iti. � E U:o..v_.h.�+.__lw....=G:.�c" • " =` _ - :.
5 t ..,...� .t.' ' ..`�.., (,.. .
��1�.1� � VM1T.W_' E `�W- 1.�'i_t i [� I�I� . '�'?'� .
lY'.uk` eii:,��iaFSzzi-:;•ti-W.x.}:F-+.v.j"'^^`u�}alk:u.�.i....rC:u`�.-_G:�:�:�:..c ��.a
.�. .,:a.?.u.a..�oisa.r.�..t�.c��-...,a_:...c.. �^.�4...�.
' . ° : � •. �
�/
; ' • ����,l. Tf,'.
) 3 _ _ ' >i..�
9 Y'+i•itlex.Pw L4+k:ttDL-.� i . ^ ' : . � ,/� ../ (/...._G
w 7, _��� y . s ac 1�4w.�,( oi a.�iS:. . m.� a::cm:x-. � _:_ka: � �:. :i.c. c: i/'c.:..._
Qru�.,.,�..TSw..,f+�' 4.w.':ti...���i:'s+..C:.d?� _CA�zQ-R.2�3•.w.-r.+.i�u:t�:.,_ .a. ti¢s.^«",...�.:..�u....,;'t.,F,i.:.w
4(��:.�'Mtc � w..�ul(' Y' . �.
t�
sa,:.:c_...c..•..�.u'�._.i.. . :. �3�. . •.r1}.i�:.pL....,....:z_.._._. _._ ..- _
�,,;,� lkiti..�.«.�..� ..i..x.. a...�,F.:c,� . . i - ----'
� � ��.�-�- � �� � � 'hE�,� ,�.c,,..��,,�. �;
i - : i .�.� x �:.,,.°� .'
_. . f./.,. �F::
. � _-�S4d�1i[ucau�¢.{srPi,.:a.it� Qs..�:��.14i1 �.,t_ .c-rc.�...t.�; , i _-`:.
..-" 1}�: aa. ��mu�i�r�Kayi.�.) n..a_Sa.c'u�.,��.�c.�..{.wl'.CG:.-�s='.°..e'..�`a�+�`-as�.."�"�'x..i���is...<'�.,:�.t�i,,��
Y 5` �� , an �'" ' ,
\ �
�,l � � . . oF � ��/vr�%ti
t' : (�....f
.�li�;...,
E \ � G'ce�a o;;d�,p,�,�dab� /a��v.t^F =P^t ¢e�8B7 {ct�?� � ��;?:,Sa,
3 �j4 �
: — Cciapf+aE� a l �E �ss�
: (� : � „� 3°�fx' �
i _ • � , ;� . «G�...+Lg �
� �r
t ,'` - �. , � ' - f . ' ��1�,� �:i,,}�.
a i1' _ _' . � 6 . .
T/ 1 �o„4 -_
. f/ • 188'� .
( � ` - -
'�' ` �r. " - �
�/,' � - - �..o;..,,,,,
l�f — � �
;� /:� �, .� � -_ ---.
I' _ .. _ •+y_ .. ,_.:.,..
�:;! � � , - -• •
� ��: ' � ��� .>: �
`�' 6 . . �R;�:.� _ 1
�/� ___ - _ . . �- i ,
r /// - _ _ . � �!. �%� - � .
/.r� .. . - .� . " .
� � - �
,
� �
--- — - �
�
�
3
6
0�-36�
,
a6-�b3
�
u
.
��.J������ ���Li ����
. �
� .��. ���� �A,1�1,�.
1
�
� �� � h ,o
� �
� � s z 6 o s
H �
a � —
`� / d 3 g �
� % i' �
y � i
� � . ,y � Ss� " 7
f � �
e
y� � 6 S y � 6
a , .
,�_'_'__'_— A _____'c_'__�_ t
"�___—"_'__"__ _ -- '_�_ _—_�_' "'__ _
—' _ _ _ — _ � — — — — — _ _'S&'�alCli� �i _�4�.4CiS.eife �_ 1�]C C4�`� _ _
= e�:__.,_
l{ayrG�ta���r �9�`1"9�f�*��Ply f �����T�° 1` ��
�. L A T
r�,iysim.us.
� �..,.c�srj f+t,� fi„q'�,.u..
. � � �,.,�xr��wrs�
6F�a.� ,��y. m "�e"r' � - esiA�c� ,Pry
Qi�its.r�u�fi ' � Jc�ar�a���
�
w�ataw..rl�.a �yJx.uu�u> CJs�d.��.,,
�w �� �f`f&..L. . ' � �y Co.
' jp +0 p M, �$K ^� � � �sv, �l(�iiru..
�.' :v �%�it`s�p'�°.n . .
��%
i�
Cl �!'.
X t�
m � 4
� ' ''
t•�
m. '
u
.?�� �
1
s.,..a�< y.u.�:..ryrne.�.�..E.f�a
�
d-.m�-�g.�..-g ,y..�.�e.�^tC
�^✓drs .�
✓ � d �°6..'/e°!L6! /8dJ'
� _:. .__..• .. �t�'�iso�.��� 6 �f.l
--- �- `��° - �9cf,p°.zrsry �„�t�.�.�...��:.cy.�sa�
' ���Cotiu�zc�l�ini��ciLfi�'� fJ'tP�z��'c AR° � iP?J ,�u.wpu,.�:
- '_ C � /� c4ffi8TY .
_ _`__7�sM(�' 'mPd%VS984L
truano mswrmnrwr
•.. ����h, tl+-���.'�mo+
--- -- ---------- --- — - ---- N ,./
------ ---- ---...--.. ._--------- -- - .._.._..- '��---_--
,
1
3
�
— �___
< '✓lin_
/ a
, �.s.�.a��„�,Sca'�iny.
�:.,.�
�'
�,�, .
�
a�-363
�
•
u
� ��� ��'� �'�`��
�e:ea\ '�.s�a�e o- \m�ro�em�.�: Sy��.�Q,o.�� .
A C� �!. T 1 O N N O. 3
/�
/ J�
/
v o 6
/ ` �
i' yP 9
s D tp .
� �` �
6
1
8
9, .
�.
-- — — — — -111Ft�0�i�n.t$— — — — — —
��3 � � S�
Z � / Y�
�� �"`�' -- __ �.._� ,. ..,,,,.�, w ------� ��: �
./aG:cal... re.. _i � y _ _ �wib.Sc.. w. C- N � �ict'L�a �c �.•.
— .�M��OrckS ��t�nr.aV'�. —La .
sf/hii2�uv1.Y����1.�6 Tl4:i�Ln�bl.'1fXn✓.XRid.A4uL.E�Nca�/n�rerc.�ci./J9mNii./.aee.��nfie..n...a�'.+..rvjb
��TCIi�fl���O% �'i�Y�Yiycdo+�elJ/l.n�f(/�Cj?a�c9'etJdv�si�dOp�aii�uT/e fn �wi✓WiEefpavpdY,/"liri/ c^S�r.�I:R��n.d'J..-
�rrSr�xi.T�sc.�w��aM/.- �...w+S..e.e.rriAK.r�/Y•3wd.4�et'Zoae6.:�...xw...�w.�+L.v� +r.Ed4�neAa...�ffy/'l.AY,"v�.'v.e�7.:R:..��lY.+em../.rZj.v:.ea.dG�y!F.�t:e_�9.i.6.«4..�.4......d6 �J
.e€�..�.ry�.,..L.,.-.+..�ye�A.. r.4.....�..o-. � I.:��'.L.rylr./19/�.+r.:..�,4a�....r...d.�.a�..�e.:�J:r�..�
�y.-{�6.i'.fa.� �S8].6T/eKfa�l/...+¢r+�L..t..1.✓�:.N+:yL.%l..rl+.+�LG.�.3PL.Sf..f.F�.T{e�neuA�v.r.
.z...�„� .e�..dz.o.f'�.tn...F..;.e �G:..,z'.F...�,>.�-zdd,es �.-��...._a.,z>z
. • . ..n.fe.�F.r....:s.:n,.zw4�..,:,s.i'd. �z.t�,:..r.'�,.e.x�
<�,.�.r..ir��.sn..w .o...�rwn.e.........n......�...� .�.ws...L....HLJ e�...<..:./.
1
r �
i
�
T H E
.�ihtc ol�//iiii/�JO�m d:: /y � eJJ$laJr !10 /lt6dcr>. �..-.al...,.r.> 9,...c�.,�..,«....t� �.'
C ori,n.7yf/�n�.ireq.i p�,Y.eo.LC..r/.b�i,w�...<zz.h...,.......� �.,.r.y�..e.rLl.�a�t.r
y � F�-,e:' n: a/.��Rl eu 6v' o..s fe�. u�.�+.t eG.d.
/. J<.;� , ����
l / l J « � <xT,; ,�„�GG.�.,,....4�._��-� Jp�sa,� sY�r,r�t
y G�/_l��PIGGCl �/�LCI�� �JIG /(lGii���se�.Ifi�
C � sr.��,...., � _
�iF..�
� ( .r. i.',F r,..._,
llc�y.lc�!,�.rnj�,b.r.c.wt-�� f!L°Y nn�.�rc (O�53er/ }Co.`.ri,�,.�ueN
t 1
�f�..zm�;,.,
ed
�xn. nvw.
���
� Tsw...�s.
dfJa..L-
Av.'...._
.x�n�..�....���, � `�_ r,>,...y.,r
u ,,,.,..... c:.....,: z,
/Jo! d.T1/ixs.� �� _ � � /✓���
' - _ C.jf�....,.
rSTp�.
� a-,'..-..' x
�:,,. "'„`:' z�w,
,.,,��.
� _°�d..W �;�.: fM� o
gr
�� �
<
�
��
� L �,
'
4
2
— �SY. � — Tea—
� � �
/ i
/2 // /O $ � q 6
� t �
U F
� b:.4 M =t� a
� s'
R
J� /.i.//�i�. , w�� �
. � _v . .�:..,�
�1fi.(u`/ao!'1�s.mre�e•�u. s::Fr;v,,.
����� ����:
�;,A€„�;.
F
2
�
;
`
t
�
�
n
�
`
a
$
E
`
�
'c
v
. �
�
�
:c 2d/PP6. . _�
�r.<s't.,..., /.�P <
y�...✓.'ge.:�..(-�:sc�3 -
� , , ��.,. �- ; �'-.�� .
, , �..
vi2.irts..i.� �..".C'Tn���G.. J.
:.,� _, �.., w.� ,,�,... ,� ��,
L.�1 N �
z.c.a.�sA
-rin.a.'rc:.. � �r ° n;.t
Tn.c. +.C..�
_ c� «,a�.'6G,..:z�
� .r .e
-.,y ..a.r,... �...
eL..,ia!!'�L:�el.,v. n,.<�m:e/Yn!L:...n.......ne..:...✓--.� n...a.r
s`� "'�m.....�.a�.c.4.aF� p .��.,...,a.�...:r.�.�.-._ .:_.
� �j.�lf f e�4�n...«
sr.w.rti /(�l �.Fl.�.
p �.M (br�w. �o �1�.._.
l r!/t T ��ll!!b_�✓ / _ � -
�
° �iCCXC �1,X6. .
Q6-36�
�
•
.
�
�
��
��
a
A' i
v�
7k
�
�i ti
i
�•�'
z � � ��
��y,�—
�., �._ , �e,
: f� � � �
'� � �
�
X �-� �
�s�
` y � A�
��.
.�\r ���
��. ���
\'. ���
�:? � �
r
.�,� �� a
r A ��
IA��
nf� �1fCli�
i ��,..« �' I
j ( d'T;y .a. �p��
Q�i�lid.u.¢Qpp,-er�so�sr �ej'Jiq/Gbile6 JxYa=Cl...F: .. ����,��
l
�. ,e�,,,� . �.
�- 9' r �� s, � f. J'_ ,�
�/rvea ce..,. �.�o � :sa.d6 .ew�a " e '� .,` " d4✓k� ,.�.,...L:.,:m.eal.4.m.e.
Os��afffb..a7//.:.� :" --"C''•.• r+�.L�
_.. - �j'�'1'::..�.. a"9a9 :1'^�L^.�°�.. .
� H. E
� rz �� F._.F � � �� 1v �f`� �� � 1 .
�a.i �s , �/'_ ".
`�.� �.�, �'a� �. �a�. � v �.��'`§\ a � 1r.� \\� � ��\� o�aa' a'a�et� �
fa. � 0 0� 4' C� k�s Cv �. 4
SCALE x INCH=100FEET.
__' _ "_-�C�dcib�e'(¢__ _' _ _ _'
'_'__"'___—__.__ _____"'___"'
M 1 � �
\ N M 9 J) 5 ! d'/S �I ro 9 d p 5 '
6a. 6n '��T �
� _ T ' �_� s � �i �.. � _ .
. � //
t�
d
m
b
4
!D
� �.-!' ,;7.
� a
;�
� `'�'.
N°' 1 �
--�- ----- i�. .
�',a,, y/�i .�1�,,.��Y�
�u� /� }`
tlCT1SP�iT �� �HQ}e' �/Kllc . �
�
F> � n
,�
� ",
i ,� ,; i
4 �,». .
� �� i
',
� y /
� ;,:
' ' f
»���
�
�
,- G
�,
�
,
;
� � .
� .
� �� �� � ���
, �
� l .
... ,
s
, � � �� � �;��',,�
° ; ;r . . - 'a �.f� ��, , ��� i�r��Gi � � �� . �. . ; '��r'1.���—
' � f'`�e r���`, ' �� t�
� ; "- ' �- �.r���.e� , ���� �'� ����� �`i' . �` j� � ,
.n. � � , ,� �, �.��1� /����� �� /�'���� �. ��r� ���i�'� � �...
� �� ,�c�aF� �. �`� .�-;�r�<� , , ,� .
� � ' :�� ,s '� ��;� �/� � �' � � ���,-� �,w��'1�'�'aG�;��,
� f �'����Gk!�� /r/d-, ll�l, U�� r��?����,.�l� �-1 . ��.s� , >
l' ,l �� . : �/� ��G%�'/ " , �
, � � � � ' �.�1�;���J yG;J', �z��' ��l ; .
, � �.� ,dG�'����'2�, � , , ""�f
� I � "' `� /' �� ,Dyt,�G ,O�'i,��c��'���'�C/ : �f/�a��� 3 ��� "a
� ;': ,�1��:`� i��/�� �L��� ,�Z,`'cu' C�,r` �,�G.. 7� : .�
° ��� i�ti� ��-�� , �
� iJ��� ;� �,.
° "�d'� �,d l,e�'� �, '
l
, ,��'� ���`� � N�4�/Y//�/, :����r�` � � .
, . � � �. �� r �, q r N � ,i � / � , � � f �
, ' ` ���%4�VLL�e��'tE�"""� """— //(r
.' ' �� �' � , .
' ,� s � �'+� � r-1 /f .���" �� , �� ! �Jj f � � �,
� � N e�,ji"�; ,�i a;y, ".� r i/ �
, , 4 � � y•i' ,
, .: v �.
3
,-.
` i �
,��
W
� ,� � ��s; '
�� i � �
� � i
� �, , � �
�,� f�.''�. �� �����.�� .�� ' -�. .:. .
.� ; ������� ��G� �.
. . - r � � (%�/ . .�G(/ n �0 `ct!✓ '....
,Q,Q�'��l/ , � ` � A r� ,�� ' �° .
� � ..
'. � .
r
�,.�� .�w .,, ,. , . , ,�5� A'r
. ' , , ' , _ . • � , . , . ' { f ,�d . �
'. - � .r • �K+�✓ ��%s!/✓v �/�/�y •' � i r
• � r / �'/ f A ( � E� 4p
, �/�� � Y'/V �„��j���rt!;� N ... � � �� r � � ��
��: ��'� �� �� y�,�,��.� ;� � , , . � �� �:
�°�� �._,'�.
� ����. � • � / ��` ` �, x'�'"" tr;���
�'
� ��ur�/. afc� ,ze�L , ��,r ,: `� �D . �lI/!�' .� . � .
� 'm,'� .�KE� � .. " . / j t F
� ��r��, ..� ����.
' I
; ��;;� ,�����`.....�:� �;;
G�„�.,�`��`� � . .,!� ,, �{
� � �.. � - .���. . : �`�� � � ; . � � � � � � � � � . � . ��' � .�.� :,a.:,. ��`�
� ��� ,�y` 1"/'���r�d�'� s�, ; �, _ .. � ��:;
° � � �f il.,� G �� ��'�,� 'I'G'�.��, ' ,
f ,�`..,�l,/�`� �`, .�G��l�l��� , �i�� �� / G�� ;:�
� �� ,� ,.,
� � �L�'�.����ff�IL � �o '��:�r'l/7il/ . ���%' � ,:..�... . -'. �
f � / ' �' ,y�/ , � t , ���// �J�,��� �//�/v � : ' '�"' z'"` ':
, � � J p � . .. , ! .I/ ,C4 i'vuv G�GC/ ti'GG��.���E� . �
'J^'�
' ��1�'�' ��.�" ,��'-���'�a �,�'��,� �'� ,_�'���- ,� - �
y�'�",�� ,� ��',�',r��-- -- - , ���;��o �-.�/�� ; . . . ��
� : , � u �� k � ^ ������ ����j .��� .
� - �� � G,�,��� ��.-��� �� ,�1� ,��y���,������;�
: �:>'..��, ���r� ��'o�' �% L r ,]! , .
� _
; ����� � ' � ; � . �,
''�' %/�GJ �;;��i�Z!-��G; �/,'��i��G,.�i .��1.1�'f��'1�,G�• �
M � i� �/ �;��. �� � / / i��/ , /�r/S�!�����V'W�l][�L'
/�v(�� ,Ozl�/ i2¢tGee��,!` ��!G� �/1!�G�'���l�l-�GG,����� `
„ � � s � �p /[ � / O ����
y ' 4 � �.Cn�r,�� ; '�'� ��<��CG ��2�� ��✓� � /"�A/�C ,�� ,� �; , �
� �,/ A / /�� /� ' �%� C �//,j ,.� ��f i/!/� � .P
�'�,LJ� G�/ /.�I�f�G�� � �CCG� . �� /�/l�'1%/�� � � icCGU r� � � �.:. � s
�! �e .��.�`'� �;% ����1/��l `.� . �r�����lv�� ��� r��r�f,�r���� �%�z�a-�� ,
' ' �
i
Y �
ti � �
I �
> .�
f �
,,; t L �,i
b ''�
1 i �
� �
�� : � � .�� � �
r , �r � �
�'w: / /� '" r ,.+� ,>..;', :
� ,
o �'��.F�., ,�, � -�, :
/ rb� �' , � , . ,
w �' ( �
M � 1 `
i .� �:ri`. � .... ,� ..l./.L.t.'�l�.a.� '� � � ✓v �dtiw m� ro' ��
� �� �� � �
� �.. r
�
� . � 4 � +.,A� � •�
? � F� 4
� ` L � I
Zl4.�' � : r �`m�- .fi . ,� I . � y L ,, , ;
���� s �d i �" `3I yv s i:. $�a'� a-- �
�H . tF .
/�/` � � '�• �
�,.r,�+f . �'1
i�wx,F . , ♦ � `x .�a'� ' e :
` ' 7 ��- .r.
� � . �.i. � �" S � ���� . . :nl.i//
! '
r ,,. ,. � �
� � �� � �f
�. . ., / wJ� n � k .':'
r �
/� i�/ �. / >!6'r�
� � i
J�p�. i '�
:� VM��'��'��i
. . .u...�., i t�� v..'.
r
rY . . . ,
��
F•
� � �
. �x r=.a',�, Cg�a• f �pn'.� :.. ,.,,,.. _ .,. .. . � , F - . . . . . , ,._. � �� �..;. „, � . . i a x : �r u au � �.c�4';`w' , �,
', . . "'. , � q , ' .� � � . .
,� `' � 9 i.. �
9' � / ,l ,,� • o
. y� N a .i>' ,�e!.d" Gf�!�f '�.(.�� ��,1l .c,�//. �'! , l,F'r "�''A. ��," .11 � =��' lG�.l � �rl '��1�/`�.�1:1 %�,��," d'lf��
A. - . e ' / � �' // � . ' � '
'' �"i!a'$��x� �+d�d�' C�l..�'� �%��''� .'l LC<' ��d: t' ! :'/ C'/� . � .' llt`�!� �Gl � L/� ,l.li � �/��. i �6�/�i� Cg"o
A � . `.��'� x:r �. ���!��^.� � �,. �,. ,��,,;� ; J "�;,:4'��::�G �r�� ���z�����r..� Y .�e ��, �
� �' � ,,� ' �� � ' . � � F , , t �-
, ` ''�;�`' ��'�!� ��� �,,✓c" ,c��;�.:� �Y��,, .�'J .�.��CG.�s��l'��'���C�.CD,,.'�,. 1a �
. S!�"� �Jte''�'.�'�'� :r''��'�!!t , ��c-��1� � � �fi✓��/`/l.�l , IJL'L 1 '%��"' � :`�-clv��C L� .L-�' ,m.. �1t�C', � ',u...
� . , , / / /. '
��; � �r�a'w!'".r� �'�6' �.illC��' .s`r� :��Y� �,1�."l�� ; ��a'�� /�i�t 1��-�-�,,� ���°����� � - .. � � � �
�:�' - `AC+�e,<i� � : iv<( :: t / . `�. �� � / ,i; ; , f �.:�-r
is ' �'ttt"`LG 1 � J/fl��'(�'�� �f!��z'��LC -���% .. ,
�� . tl �, �i�. /�l �"LG � C � , / 1 , � ' y , � p . .� � � l � „^�-..-.,, .
, � �� � � � ^ _'`�r✓'/.�,� �, <. -� '(�_ �C � "��
"' %. � a d �% � �.� C/,(��i . !' � 6, � ' ' . . � • _
V
' 4, . . � , . . . .
. ✓.lfLt C� ,4 , r , �, , . �� i � G �G"�� � ' ' ' ' . .
`.,, .�6':'.t'�`�" '/1�'/•.'b�/% ss. ,_� ��� ��1�'��; �' G/f '%(! /���; l�•ar:�` '�z
; G/ ,
/ i �/ � V ' i. . ,/ ' � � /
,,,; �. „��J,c.il:,.',�/'1 j' ��`i�I�l .Jlf�: �l"l.� � (�,�;,'%1���;' � Cl''��ri/ � ; 1 �.�'/ :'C�!/i rl!�
�, � •• �� ` y�!' i ZG //:'li�:,:!]G� !(' ,I/�/� /'�L! �f'wCC.l (f4� : i��' .�: �C{ .{{ � . .�, !/ i �: ���c
r�� ` ' ' -
t . ' / -,
fi��o%l l fi P i! // ` //, t/� /i 1��i/' � � i�i �i '!/,!
� „ � �ri�_. it-.:� ;Q, �2'C'��l�G'�ll��i</l/i � Giti . i'� i,,., aC,�i. ¢✓
� .- ./ . � /
�;�,; ; ��2 fLC%' llt'G .�;"C� .11.�:xl� . � . •.
� �
, � �4 � r- .
� - . � 'R<,WU,;�i��',z,.Yx, , J, %t /, ll� ' .: ' ��� ' . . .
� !� � . . ' .I i /" _
� � � � i�� y� i: ;,�:, -; J�-��u� ' �,: : ��.�. � ��. �., '.< < �'�
,. .�:/�,:7. �j%l�lr-G .lii�.� P/�Y��i.G!.G�� ( �ui- /7. ��/.�'���/. /l�l',��� li'.�:> �����;�fl�.; � � .ln;��
� ,�'l�Nb' l?
� � � I':�,
� � ..
;. :��� �ECQ.riGG�l.(%u� � r j;'.�Cl�/� % �11f>'� G.�...'q'.
<F L
{: �� _ �iu!✓ ,��c"o?�wi;f.�.r�ri �iau�u�aA W,�cE� �os�uwJ n�i�t �.�P±.,�� �� 1�.�,►� �
`
4 Y �"�'____�3¢r n o-co,��' ��G� e I�� Q.� a.�J �i i1�6�9 , i a 4 z a.�' rf �so-��.2e^� � i,�, °~,.`�`/
�O /.T� „' . , f'` , ' .
,. ���;[ � , ��/ �; i
%i!/�L� G�, /%/,'✓'✓.!r`�,"r%G �t . ^,� �� ' '� ' ! 'r� r . � �
f ='t , ,� .,ti.`� ,r,�"�✓!� �6r� %��`f . �i � ; , . i µ
� t � � .ilC�`'��ll�' ^� � o , � ...
„ �/ _ %
�,. . . • , � . � , C , . � ..J . �,�
�' ,� �� ;i��sz . � ��Z� � - ✓l�- ��: �
� ry ' �.. �
`s9� ,.,c � � i J , . . � .f.l.��.c <c ' < <%
. %� vLFV (/vl�'L9':�� VCLA' ✓ �'G�' e c
��/' ., �/,�,� ' V /� , / � � • ' .
• K .;� /! KG�✓�� , �/Y'2�'vl(.�-/f,fiG i � \ � � r . i
, '. - , . � ,. �� . � , ..
. , � . . � ( • � � , I
' '"1 .. r/' `` � � �' , � ' . . . .
� , , � �/�/'l�/Ul�r'/ :A/ !l�l�l:'.`i'�, � �' ,'�i `� �
74�, / + e , � � - . G " lY " �i.j 'f�.': . �.i . F < < ,Fa.', • ,. ' �� ,
� e. . � i �•
X�' ,,���' � s� ��� ����z,f �ii,_�. ��'l� i t'. . r.: !: rr' �. -. r � � .� ` �. �' ° \.,�`: �
� � �:, �� � ,
��� � R;���, ,��°����;t .����� ��«:��;.�-�� �'�����,�� �( .�.. � �. � ��, �:
' � d'I"4 " / //..//,, �� I" '.� � � f • ., r r , � � ' C ' �" , (+ l ( � " .t 4` ' • r ..
�(lU¢'�✓ ,,�CiiL �Q..� � t:r 4'(r ♦ t��� ��
'�,,,:�, I�� �� �, � . ', . � -'c � ,., l"' f�c r ,� � � ,:
� � � J ' '. � c :< <, r 7tC`< c.«�.�.�
, ,1F �y ' ! � l��t il �.
�// y / � f ) �
u'k1 <6s::�f"�"�.l�,l..,� a �r«V/:r��l.„(�L � ��� ���'//' " 1 . `�;' � , / ' y/ � �f � '/ ." .�
�< � / y , � "i /���.� i ���� .r�i. ( :4�� .� SwI,',I,'/ � , 1:��� .
�!�///�/ � /
/ f �J.{}' /
�" � � b�V � � 1 . + �� % L / / �����.V � � � � ✓. , � f� �� � � � � . ,
. p i � � . , t . � . f: �', . . L t!/C� �, ' ii ,� /� {� '�'
�' � / / � / � f � � / ..� �_J . f i't., tl�, �: (��C�.Ji'�!_
.v' .-������'"' � .�.l�C' ��.�J�r.:l� � 1/i " �� � ,y 9
�� ,� G � / /!� : 1:z�4. °. ; tf.C• , .f'!(�.,��� �'i,l'�1�./2!'%'�lf' , �'
»�%. � �f/Y ` / / ��� � r C'(CIV�
:, l</�, �:L' �t. fi t G�, } �� • ,pK '' � ` , ` r���i / / . ,..t
�, � �F`���� IG 4U C� iCL�C'C.0 � / J �� � _ C !�L t � !�C ' i i
x� . `p(. /t /!' �'!"'�/�' (', .
{ ,�I /. � C l / / ' / � � �
`° ',! � ! '.'.!'Y � ' r ' f a , ; < . �, �<�!%l'f'! �' 4 , �� � 1"� : „•�!' �1:� ,
�� 'i � �"K� �� /.y '�' � ; /` � •� � j � / .
, �� - � y � rrZ(�.. , , , tt'!'r ° � �.
�`' � ./"2%"C"Il� � f � � ;/ .���.� ��' �1'. �1�,C. !!li< (.�./�'
� - r C!r''�,',��� �i'/Ql � / �� � �t _ � `'' . � � y
'�;'' _ r , � � ,1 , �!, , � r , �' � �( . � �� �, �e ! �l��f ( �/' i �( ll" � �C<e i^
� � r�'Cd� i�:" �r`�! � ,� ��� � � / �%l .
�� , !a' �<� cf <�;��r'r'�,'/,' �
j � �. ; ,��/ �,: r�,�r,'�� ,ll.;lfl' ,�j /°%'l'l'C ��, li „ , , , � � ;�; � � � 'l . i%',' l < l%i� ,
f //, � ., /' // „ ' �'�< l'l.t�" f ` ;,'"`l / /// ' � � `� / �r-
K •�.�✓rL�C...�! („'4'G � / ` , / / �`R .�I!/��/i'J �(/////� r
,�d�? P�al���' �( ;G� . .� /� / i �}
�. � ll( c I GlG C.����1 � . ,�i� [�(�^// . '. , ��
�r�l�;ti f/�f` �d /�tCG ,�rlCl ✓r�" ; : � ; ' `f�j�;'r•;,, � " ��' � ,. / .
t/,r . ✓Cl.i(l
� ,�� _ '' 1,
s
d 1:'.uJ
�
•
06-���
--# �,.� -
,. .n � � �— 1 s , ,xi,s '�� .�1 _ �_
4 r� � R , _ � 4 ` ( _.'.- -t _ ar - '.''
§ _ ' � - '' ; '�i646� ( '(� �J � � ._ -: �`�'�
T%1S I1IDEBNRB @W�`ibys {tL'.�b2 �,pi;1f�C.St Nk�t�a Sh� i�`kI Y
. :• � \ i z . . . -. �1-�-��� - "
;._ diiz ql sn{mr;r�ut. _ m�'eiioi�i-oE�ra aci?y, oL sn. sa ot�ks�nvea4ss; ^'�._ �
�: �l . _. .T_.-.-�
ParyZj�of t�s'3Het Fnrti sn4 Pb82 6517$Y�IPT p➢ T8E JIlY�"� Y[yI';�'�� ;.
t_L �'
�.�y - aa6epdrattoA ¢hlet s.�a i..� ox ttr�"s ofX3�e�otV y r a . x ) 3?3�'sa._�-=:'�. -
' iaeonC PeSt. ' " - � �C 7 . • _ -�
y'. ' ' " c'.� . . ,. =.;_:;, :�: .� �
� { . ` WIr1l83sBTH, tl�pt {he e�1a ya[fT;qZ�'�•Q}sit pnrO;a � "-�'"�
_ gV? -._.
o: the �o�p of ow ➢r ;lsx �(�;,061 )��' btLry g �Ioa� .sa .siP�'i;�� asfd�rit3qa - ; - `
�io 1t tn hdfid � • +.. . � 1 ' -
paSd�lY tha�ea3G ya�;�j� of th� �fo0bd 9nrb, Lp. • t th�1�-�'?
• ot 1s' lierob ' � � ` "
y Qaknor�Imged, doeo namny gYaati, dat8a�fn, qn1E-p�aim� and �
, ! i ' , � ' � ' , __ = . % P �:
ponvay unio�[he eald ;ntt� oS LLe 6eoonp yqpt, SL� bveosaeor! �A �eil$y� r'
/nrevsr till, sLe or,yaroe � and lyleg er,A��,LYtog�la tbi�Ylro� f
y :._�.nny �n0. State o2 M� a dee tE1d ae�loFlorr,� �so�-+ { '�
� �'` , � � � �
E00 ft. i1F.P1.�andoOqdPIDye oi ]�v�d'S"�yvepo�M D���L ` ��
�° ` order b2 Cb:nu.on Jqma12,' qyril 8¢, �1BB6, �r�d rwo .!d�
�%- vyl. 16 ngs 1GH eoard o1 YdDllo tlorke M�eaemi2t 9io iQ��
, o ea�2limed Dy.t6e Board of,Yapllo Yorka, $�yt. �,E �3�886,'Qq�- `"_�� �
aribad a'B SOl1oMN:" . • /'- . � �I��' "'-' "- ' � . . '
bmmenoing'he 6.8. oorngr o1 L'$t 3Y Hloa�i�$foi-trIz�jnq �'
didltion thenvs 3.H.ly elong th� 5.$. I�Qq� o��eLLd aQ1tltFoq ': �
, so the 1%s-1/�•eevtiondine itlah 2ormeitLe 533 oi uid �.
' k3ae k 2rvinee adJltton, [Aen 9.W 3�'ia � �;r�l}bi� to iIl� '- '
" . , 'J.P? tlornei'of�H3 ��� k �E RfaleCi.�d6l51Pn.r °�. � �i
. 5.u.lp Id e gtr82 `t 11na to e rnsr. ot plouY 7 dinwy,- oy �
� s TredB3e eM1diSi hoe N.17 A� e.rt�Alg§t 11w�td• S.$.
„rH"� :oroet qt Yastition Pla 14 gO1m4�;beiog dl�t�nt 9. Seom�th� ����
:t. Line�o2 Sea. }? q^.p. RB •,E3, 1,4b�1R SL. m�e�m�sd oa i� 1 �
m
line ba,tween 6Snn�j� BoaQ 'pta g 9dQStion�� YaYtSSioq �18�, ' �
,� , chaneo 4. 50 degiaeB 8 mindtea 06 ee'b4qda H, a}o� LJ1v B. liq� o[
Pn(Cltinh'P�1�ot, 434 St. ge�d�pokat 9olffg'tqs d1�iQ=4g 11n� Ost+aen
� \ Lote �4 �Q°IB nt Paitition Plat Lh�nps $ W:1x l�y ��DTO1gED
g
_ 1+,ysrfy or lenG i.:�she--deadoatluq��tn• go�afli�_iatod'
o , .Z$ and'Y9 9tiqeroi, Brown b Bam��ya oQdTtTop, t�oord�
:� _ ;86'1., 1�� �')" Tort Plet�,gpg� 16,'��buttt�.iqta,C,'Se '
eiva'. SuOd�vie3cp. ai�Bjpol89: IS%tPUindl� s18=3DSi!
. -1,' 2, 3, { and F�.ylb�'S 1�ei 4 21ap dr�n St?m th�
ot Lot 6;,Bvp3dr;rioy; iy� ;A '$.yK upiy;
... aun6laletoq�of,.rlro<`Y8,-a13 03 �p 6a1�{C'ead.�Gtl
oP. Lota a8. aa. 6 i� t4�` H: 60. 4]. 6�: b7� , 68 1j1TK
o la�j4:diw/w.Yrcm tli� 6.}l� oozws o1 yot iSe`' BR,bdiYSi
_ 86� tb [ �4�0 S•$• unanoz oi bnD �0. 9o�d11f�lp�-'�#� Blp��
' - 'E x2,( � , � r 3 `,
j � ?�._' f 6JY -'Yga ' �' 1 .
� i �,c� � , ., ���_ ' �l"
� .a, � v �.t t<„-.�wA���N� �' .',�
_..�. .4 . -'.J'�r.- � - , ��' � : '_ �-k�..
l,
0
� t� � i F` y� a,µ � , '
„ —{'r T r
A ,. �1 _ ^ _, tII e..' . , � l ., � ' `. l.-' G [ .E � � - .l l :.�
a ausa�r� aaaac_o�._ `: �. - . - `' ' . .
. . _ - :�
- . � ltna.�ry6 � tt, to �.-$: aora6c oL Lot 40 alaec 2fl st£' oa, FtiO�n a
, q�xym�e,Ye`�ub.:oz Stjnenn, grorn � RomeAe sdaittoo,_t • in a
_, uttaSgA2 2{ae to the S.W. aorPei'"aY LOt 68 Blopk•E9'311II_
�- tivaHn a Ram9eye 9rsD. o; 9ilnaon, �BFbvn b 8aqee)p. dd¢flen,� Leu�
�� "y.X.ly ia - a efiei3.S�t I�ne Le th� S daaa�i oL.1dS�6-�1 oqY-E9
„�r+�=..n A�ovn L-:3@maaP� 3rtb. at St�iyyqn 8rorn i 9�m��;i Y1�
_ "therma s.W.1y a?ot� tRe '9.%. eia� aY Hlook Ey,to.3. �
� Lot 18 .11loa{ E� Sitaeya; Bzo.n k'.8em�Yy["Snb. ot StluaOq;' ln
• ii�
� �'.
.
�
C�
•
Q b-3b3
� ,., _ �, �, : _ _ -
: NV, � �. � �, . "• �� =
3_7.._:/� P4�F�'V� . _! X [�� �� �.�`�../ SS_ '
/ '�' . !,
� .. � i � f.{�`,__� i.
` .
'_ _ _'_ .- �_. , . _.�.`� " _J._`-,I. .._ .2>.
i `' :F
. l _ . � , -_ =1 =, _ .
. _ _ '_ . ' _ _ _ - , -;� \ �y _ \ .
_ _ - " t . , ' -� ��
� sb. sanai.iaio. nr arow�e ee .aa'tn. �x�nc ,. -srera s�i�, <
add3419D. ..1 � . _ . _ . , A'w ! r. t' '
. � � � _ � : 1' .. ;�.. , � r:i'C.::, .'r.�_
.e .tiiy oz iso- 3aY s}s P,Y�t.-iYaDrdt .OntA U
"YJ' Som Plnte ?>8f,�. �4�'Ikt� H, ?O a lt:� �02Ritit�'S7Tn6 -�'`"
,. �.' . 8.T3.o1 a linr <rAm feom4Dh� B.L. oo:n�r f Lnt_ i bnDdSF �loh - '
'� oi IilooY 28; 3=.aaov( BLOyiA �.$emae)a sd'G, Son Lh� 6:E.-o iasZ� .�
.� of Lot ll, t`ar tioa�plrL•, . . i�.
-� aLYi➢ 01 l�v- tc tSS Q�4Saatluu ni a ls a 1Y.P�tjytou Ylit �A 4
�� 1 aD4tcing Lote 1 pnd � t4i �9.E. �o:nsx �at 16,. wqr D�CP$,., j'+
�y u}�3.8.-ooen�-"oZ 3LT'� Wdltlon, a +bdi�Seloo�o3:lportlRa
'-"' '+� ��di Lo'te 16 svd _6 p�Y}� Plqt, rn1pL a� '�L�SHAbD p1G0!�Q�6{oat�� av
. , .�tSa id�attaml iTnt. hreqOSdR�APt11 P6. �:R in lE• P1,F!� .
PfHe' 16. � J � � r. � 1; �
`„ s
�� q� ntriy aS laL la tXe=4ed�'o64ton 1n Spuc , Poad%k 1Yadi� � y., (
" /�!� Addlilqn, rcob l�d7{aioh�21.`LflW, in C' uvnYLL p�g��'�11,ng '�,
� 5.1�--of > 1)ne �c�d°1+u¢ the�9.E. aor¢et 1;20�'l6.'P@;.G12;b.y _ .
' . Ylat„+Dlu➢ 1¢ �ov tpe, S S. �AS� o= � xm' ��ltlou� DO;tha ���� y
' �3�8: eoines oE Bloak�3 �mey�. �tlud k.?r'n +ia 1Llol!'e�'YFam� •
� - �'tp� $,E.,00Cno oi 81'001� 1 e�� ed01<SOIl, .o fh��H:$•'q sT+�af'. �=�
- � Hloek f, ecme iditko0._fneln ing nll"o8 �4 �}Z o.al�•Y oa1 _
. Pddltioa..lil ot.cLS0.a��aiLPtleu'i�d[f: ;Y.- ��.�' ',_..
� addition h�u e nn� ONn daEloa��1 D� 4DR %KtL�ra-$4'at�� ??��s' .
� ' Comp�n)�-Ylas, eoor6�4�Ddo.�p0�; Vth, FCP.b tn "7' 20rj1M'2o+(m '
j_' - ' P1nti P�Be� 1" ..8: a�# 2114Q1Sion t6alat iLe�lr.n6'in ¢I�J. Boad��
,k Rradsn �dQ1.YOL 6�d3a6ted fOS �tl�e [c �+2S.A9ipoee�. �,
�
�� � ' 1 mleoell�nooc ct�l➢ a1.Y1wd l�ing 9.1� t� lln� daa�n 2YOm LG� '
-- - ➢.S. oosner oi gyayk s, rinn�y� Bond 6,:� !exa aaditlop"tq�•L6e. 9. ,�ti
� uorner� of Bko�s� 7P. 810� i Irv3naa addU.` i, al� 01 wL1oD oLtlp�� �� � �
oS lsad bea Dc,_a,�l�dioqteb in the UDPS+-� +o�. �d6ltinn� :eooz'�o6� .
� gsgue7T8eh, 1f�>b �"22" To�A Plata Pa3: 1. ��. . ".�!
- e Nl that pait .t Lot lU, Bloak �9 81os•A f41u!'o {daILIEA�to '( ; '�,p
3L. Psvl� 17}r:y eovtn of � line daa�A. Sr: ide e�a2eF1) ootnii'� �'f. ':
oS nni6 iot 1l to � point on 6Te aanCIl�o� aelr I;� � yB� d _�� '�
1M, d2eLS¢L : i tc.�oortTveatarl� fxom' t no¢thetly aoPnli ot _.
� aeid lot. '- " a ' v 1t, -�.
dll LDI�i ptllt, �f LOL 9� d10Vr 19, Rlae m Iavine`t iQdit}nn i�. <''� .
. _ 9t.-Ppul, lyti ; Bo¢tL o{•+ �lo+ diuvn Pt • DO1n9�py'�A� R
f f x9Y+}� E�Y1} .
;san
._- 1 : . �' _'_e11' .
so �
aoFd
, e %;zom
of e
811,
'�„�(-. ,q �_
— `'<.�p:
` adti
@� �. 1q '
f s�ti
� 9ep1
/ ■�1F
';/"� �,.�,. -r-.r
terlj :lne o2 aulb�LOt 9, diatan 30 aa tW , ,� �
�a,tc xlp aoimr�ob es1C�Lot 9 C. n➢OlAt lbp '. _,
te�4y A''lar e£ s��tC.YnS_9 di�teut S'�'L,."norWxca4a _'^.'t_,
-�bnC.nsli vasrid3' of ec1A "' _'-^_>""''$c_.'.. . . •''_
. r / . "_"'�" " ' '
part �21ot 6;.Bloek��8. Rlo� s. lY?'k�_u'rd-1}d�.Yjl°a " J
]� :.yfGg 80¢ZE OS P�'11P0 driHp 'KOi Y:��.OII_� ___
t 1➢ Lln� �oI aali k �o.p e�,i�tuii. .6 S��t'yAStA�'+�a,a�f ���' -
�.s c.riy ooraer os3!eata.7.o�.:e t tq�.*vae.rir oarmz , �?''.
Fote _ � _ � ' -'7 � •
oi f, BlCOt�.�{9, Blae snd Stvtao' .ytl.alc}oa. . ��`:4 t�_
. . . , Nd,_. --, _��
s401.SFr�1t♦ B�i7WS"sV': ��aou. ., r..
. �tid.•iq�-196i6-Yeoutd�d-�A, �„4.'19]_�.A�
rr�BlxpM6' yntt, 04 edi' 1J. '. * tk af
.�. �' -�' _;_ � -
( Y � _ P� �� y� A
_�Z i_ / y _ —, 1 - �
Y �r�1 �I a L � � �_ _ ;�„'' €�
A
�
�
�
Q�-363
�
r�
��
�
t3 �-363
�
•
+ 7
j
�3��kI Pt6iZ��. � � ( ' � t - � �
- i r .1/ � . . . �
_� - - : < _ � - - .
;-t ' � , _�_t - - _ .
' -- - i i`) � � _
�
Bs .Yial r g . - � f. -. �.� r.
•�� , $Sltt Cm �n u aoe,tL�u loLl �d oy(�bl�', - �-I .
�
�4#Bink� I. pri�ll. �k-aI Q.C.B. Datc3 iaq� 18�.19b6`. - ��,
-- -so — ni.a a�� i� lf�o �. . , '— \- ' � j
�CftJ o$ SC.�A¢7' � p, '� /9��(�SnQb D��dt ya -
�'-' ' ' 11} of 6of. 1ot 9 D�otluptl,.kry;.Ye '�
�w6� 8�. 17�6_S.,kT an6 t.l� oL chs At. Pwl BriLSS.a iatal+i .��
%tl11t046 rjgyt of iy. �z9�Yt tDii �rt tIIesnef� dyiyg f.TffOP a - f
lim"Nfo6Ya para1;11 tQ IE6 1 L'l.2J, �unred atzf �nt��i... '
trom L§� olaift 11qa e2 thi saYA tTlat O= rtIIS YS;Gap:uj .�'
an4 Si. PIn3 H��1��� �osp�p�; li Oo► loo�t�d, �oQ 1Jing }!lj ot tE�
rlsat'ai �y o; 2y� pLlea6q Y11►tak�� k St. Pf¢1 F{Sle�aaa Cospan� �
h.id thi St. Pa¢7.. ida� bR�rmiw2 BilliaaQ Coay�ny / .,
11�o n11' d1 ODV:'Lpt'b S6otlek ;-'2np EB Hen3e YE, l�id $r and "�� -
i:l) 01"Cy • 1t. Ppnl'Bilktg� k' �Saxmla(1. Rnllron3 rl�gp��. �P�„� ' ��
enD3eoti gtWteQ't9 ��-F1rio�o, MS]k� shSt. PaE3 -.
HsS1rsJ. Coup�G,1 fo} tA� oon�staotlon af s �la61, �C. A'aB�YlD$ DYYAg-�--+--
, grpatedj�x q�<d andr�enrd�¢ in �oog,78._oL-3aah ge'868� ^
'' ' 1180 m tD4t ynrt of �204 E 3�otioa 6,� `
_,.._---"- Pwq. 28�Bm8� �2,'.11iog W.lY o; th� aigpt o2 v.iT liq o2- St1a �yt.. Yeal�(� �.
Hridg} �d Tetmias} HeRzoad rig6t o1 oy, /, �� � . � _�/r� �
']4Ln l.-YlLSyetsLOk. enmatil�d . f.P. Dp't�0 Fin7 E6 19$7 ' .
. . enq s•r�II 11 0'Hr1ln, �idos - pil d 1f�� E6 19Y`� - - ' '
� . _tR - ' . �h�El in B�i4 DieII,r pag� 2&f�_ �:: ��,�-. .
.._-. !%itY of sT.iYin�_ ..' �11.ih�t q�rt o1 r.h� �. ➢90 it. 015 ,
' _ sn. ➢. 1990 Ss. oi Osv. Los 1 s�etloa .:
' zl t o2 w oS et.� PsnY Brt y�' Y8 Hmg� 82 1�SnB W.;p, of 2A•
. 1 fA � , YBe k BnSl�eT. �:oaDOnl.
Johp P. 11ts •ssibr, nmar:i�:� �.3.�.n. nosa u.y u 19E7 .
� � t - �tiPllll WJ Y6 �9E� p
�V1tY oT 90. 2 �'�l, + f1a6420 }p 8�1T Lia3t PaGi C9}F'. �
' ll • pqrt af-4b� 11- 990 SL. oi� Oor.
Lot tfon 9 Ssp. EB 8�nyy_22��l,ng:-
� w.ir oi in. righx ai ra� ot'�i� eR. Exwl __Fdg?.fad.t. in�l S�ail�
'� _ "/6om➢¢v7. " '_"'___ ._ __'__ ' � .� . .
_ . . .\ . � --__
� Chtaago�� MllwanYeep St. Pccl uonCemyattm� Jek6E Mo. E9,�7.D31�� l
' ' k Pea111a Batlrex V�ompanJ . dile4 Jpnaexy 18, l9$E .
'' to pBD0189 fa A6 Pl�n� pe� 60 J.➢., 96p11 -�
Cltr o2 9t. Paql' ,��aaeemeat tn L111,�-la�al„ ;n4
4."
; � „ '"oonatrnot.arN m�SaN;n rai}me� sraJke ,
an6 y�i�G'roWwe� +1?e qeoe��ez1 slope� on snd �uvoe� that pCetion."
; 'Af the YSg6t bf wel�of CM Giouto. Yil��nke� $t E�¢L�b-}bo:{TO"- '
- taq rt t o2 ayrof
�:uwp�n Su qq lot
' � D+?'�71�1 rl .°23�'�t;
qontb�rmu� i�ll�bi
- a.+d Termlujl
1-��1 - ;OOm11-D2�':.itj
, . aa ,r�w •r' ;%�i '+.
. . (: � �.onr�a' r�P 7t e9'�
t r.l. . oaQ�mgi}(s ➢.. �Mi,
'�.;=:- - R�iWlnllf�f - 6Y�31
�"�;� . '� � '{ ,
� '
'/ `�,- a
�'Cc. L��
f�1� in1. 6o v.� LeL i.�-- ,- -.
:�1 5� a�ni9t liDe yY '
�a:N bfi0 St. ►. tmr�.-
iv4ayi_89-4t:'$.l�,�f0�" - -
YYtiP�`1z214iaQ� >ASbR(_.� .�—
�Etlt 1 HTOa� 14 S.encaeµi �
ioasp"}�j[il.f3¢k��.9t. P��l
2ou[ 1R�C-qOYSlOfl pi '
Bi. p11p� k PSO1tla galLrar
'mPwl+ � _"""_ _
9t. gilil C.Y. 93D36 �a➢YOT+
Q>). iTI988 � t '
� . � ..9:J. BY897� ,.. ,
li. 19$}:: .�
'!' : -. , ' _ ' y! .
:�. .
- v , '
'�.� �.r - � � �,
� .� t� �i...t 1 i/� � �� p F 4 {
�"ry�r��'/ 2.�1. �li
p �
,'
T
i`":
�
�
e
x
F
�
�
•
;�:�_ _ _ �.�=°
---. �",r
_ �� � . _
; - . . ,�
?ia:y-ocdei C.F,. 7096f eqpreved•Ape1:
a dasr i'n n.,..... 4
0�-3�3
,<
�: ,
' .
�
i;�
' I
,
; �_,__ . _
; :, - _
l�z�'. J _: -
�.�Y`Sr�� ¢,:,a , , v
ltne exten�.lag fmm��tka L 1y to �}y �Sde oF aeid }oii U#ratRgl to ! i
and 60 ft $ 1, meaeniad Y fig�t andles LFom_dye MenY�ad 1 e of. ��-
_ the west bo�ntl mnln' Cracic ot ttta � h�cago��Yllva¢kea � fj`Y�au2 •,'Li�'.
Esilwaq Com➢�Y�es noe.2oca"ted �em� upppai a -- � �
- �ASl of GoY. Lot 3)Sectlan 4 Tx6. ��aaqgx �1 jying ���=�
of the,vt. Yeol 1dg; k Sermi}iel NpilrosU T�ght ot�yaS • eG4..
ch:.t pert Lhere lying N.ly oS,a 1}na xqlch Ss pesa13e3 F��apd'. �T"•
LZj R_ E.ly a_ sured at ➢ig2i an,10s Sr>m the center 1}ne.soF Et�e ,
msfq Gtock of e Chlcngd� 51F3rau.=e�& St. Psul all:r9y Compflny� I
as riuw loc:, p¢� iYa¢ 3' Lytng 5.13 +f •ne rly�t oi xai of tRe Chleagqy, � 1'�
uI:+zukae k yU. Yr.'ui ngj].vay Camp.my nnd pt tb€•St. �7 Bridge E,
+ermleal nallYqa3 Co�pany, � �;" rt� � -
,Cil of 4�.v.�Lpt 4>�'SecGion 4 T�p• ltl Nan;e 22 lying S.ly-pnd fl1y,- �
af ch^ St.-PaLl OijdKe & Terminal fiallro.d r13hc af a�a¢�+y�yJact -
Co r.p aasemeq4 ;pq�ted Co Che Chl�.:�d�� mciwaukee & St. Pau£^tailFay
:oapzny [�r U.e ��onstrucF,lon of v y=eer, s81tl easeaent De1xg - .
�rented Gy deed 6�ok y�J T( Deeds pege R$9'.�,. ����
- _'. Lr.at p�:t uf vov. Lot 5. �ect. m q Trp.�28 hsnde Q]� lyinE N.iy
� : rLnt.>( ery liue oi Che L:. P,,,�I �+idgy &:nrv�nal NsilSOad
�1���L of :..J. , ,
>f �ov. Wt, 6&=_cV on 4 Tw➢- �y,<<�n?�' Yy ` I
y ..:' Gor. Lat-F 9'Twp; .1,f.zng�: 22
'��^ ��. 1530 tt. �C ttmt portion v; e�,v, i.ot`[ Saccia y 2vp.?8
"un6" 12 .ih3cA llea l..1% tpom C:e riFRt oP�:Tny ot' `he $6; ;PCUI
_'eId_• 4 ;_;m1na1 ne.lr�nd._ �
,: s[rlp o: lFnd tl�d'.c:.t�tl toa l��se puipoy�:s +n f;.e �lat >:
?C')i.: '3'!�Lt.rt CJ C:pOYl%htl %.!1a ! c. :�1 f,f�� �jl.`LC¢ Jr C�lt
�`���+��] ��-�+�C/ ft_�3=_t_r of Gee.d's, . �c ,ry �*d� 13Y5.+_n "q2' TovJt'
�-'CS , �- ?9.
" °Ar1J �+` la�a de81c_t.3 `�r i° �. ou'?os:_ �n ✓" -2=< ot � .
L��[ev!^s , th r :ntl rec�r_ r _5a offic_ tbe ' -"
-- ' Cu.�t, 3=gi=_,=r oi Ue>:� n . 18H6. 1� ' �
. _ . .' � .. R ?J�n Plats__ �
tTc ;Cr1D �� /��ntl ACdlc�t?fl�r��' I y� �J.�S•32s�on rh4�lpt oP ��
,:_r�. JLe�^iCLn �,nd rac.,c�K..t �� :h�'1CP2ce of the ua�as`Y �. -
..Cy .: �1�!:,__.1.L.=33s�,Ye:_.=� •.t , U;A', in �i^ Tuwn VLaGs
(T,,rr^ns) P ;:- ' "
'h- `Gr!� lav-+ a�dlc+.r,od ^�r 1>. �., -, uri�sev >n�C?�: �te.t o^
'.; 1•;i. tlltton vn•l rvcor,a' ' r,i:� �;`lc^, c�N"1.,'as+y -
L'1 ' o!'�u2sic, Y^bro:'! ]t:�. 1't3^� tn�^r" -�a� Y?a[3�
��1Zt
T;�., ' 9 ' • ' ���
str o oi 1c�9 d�1'c-?zA f�- 1'c. :.i �nt �oses �n'-t'rie. 1�Q-of
�-��':: d e.1�1}ttoz� and r=f,ocH_'d )` �Ne �,flce o( th> ��p�y�
°.oanf.y =gist:r of-D2^_ds; ➢¢bruaiq 9tb� 135 5. 1��"N^�TO;�n.Pla s
��a= �3 . � F
�
�� .
�'!�= gro rt1=c !n en= sjxth'matd y I��Ired for sCYVet og 2evse.
'.J�i9o5g5 un9er ord�y of'LOnmor4COw cil, e�provnd Ye.y 1S� 13ij1 �,
' on pxge 4� of Conncll Ptocsenld•gs f tt�ey y=gr� as Tollol5 exKa7��nd �
leveG eDUtGind elrport fiom �eIos �trnet ;o Nfsconsin Nvenue9,
open� extar�d and r.itlen.a gtreet or �=vza sIOng t$e YSSSls $j?�i I�.
niv=r from 6. 4L e ot tb4 CSty, in': =ct3m 9..Twp. 18 RenE�� to .
• � �_�
_�� - � �
'- - . �_� „ . . . ,il , \'�
. �� � ' I � "' %
,{ .. � ,,�- . . �
�• . . . . '!t4(� -���
j '
. / � 3
���_��) ` � ..�� .�� i.�t� f
/
�
�
`_
ro
3
�
�
•
r
u
� � ` � � �
�i
•
•
l
Q6-363
�:
(
+�
�
-_ �� .. -- - �/�'- .`�`fc:- ..y
- � .i - y, � �7 -� :.
� . _ . _. 87S'-ET-�Y��E.s���.
� _ �,
v'�° t I
_ .�`�' � _ _ _ ` _ T . .
- ' ' . � ' � . R. �.� ' � �
\ j-
TAe Bt;iy u2 �gpQ xy�g� bltw0an the qiap:seiy�yS��S�ea.aad.B1o41�9-¢b-�
and'63 Ye�t' $t. Psql Rea7 EB.ta;e-k Imyio�amehL 3yppluo+w ed'ditloq p{ ��
dea;o[ted 'SOf L�e� pniyenetl oa-fhe yl"ai u[ s�{A-aCG;tlon adp. s;- �,:
' oorC�d 4n tAe A'm/�y�ybanL1i88gtstez'�b; I n6a'oi2lae Js`u -
Yn ��E° Tvwp'P1�is..p��'E�. ' � . ' . . p1 .
TEe etrlp of T6frd_ded,yoa ed'16� levge � \
Covtv SaoorGed In tAe Dn�dce CeOaty�d�gieter of
DBede oltloe Hyril 29,�186B; the plat o3 �ld CohtuYea 3dd1t10ry wae �
coyled, oerfltlsG sA to oorz�otneea and tzm�mitteC to yLe $��iet�:
ot Deedn oS21oe, Sa'Pawe�y q¢unp ppm `3].1846. fTho p.}a6 0: e�ia
toutureo eddk2{ov r4e sooe<'ed vitS oertnl� �xpaptiona 0y DOOiq 02
tpe ➢3atriak CAurt QS Rameey couaty ¢4Ba9i �Te1 �otr. ;y'�146g�1�d-_
D:t.�LO, 1908, �betrxot offlce Doovment'f ,Q?$26�fo gpoY 6{4 Dedbb �_ �
Ynga 29.
Tne etnlp;ol, laqd`d'edicated Ior pux,oae� on tpe p1cL,01
5[oilbricyo uapltioc and reaordW- tn the o.'Sio� 01 tpe $y'}asy Coonty
rtegieteT of De'ede OBtoDir y, 1tl8T, dn "10 "Rowp Pjotp 4 . .
TRe atrlp ot lsad dedlaeted Sor levae puxyoaen on jb< ¢18t o1 �
�BmDOell�xdlltio¢'end vLtfordad Sn tna oi5los oC Lhe �am¢ey popnpy-�.
H9dteter oi ➢sadr�Ayril Y3, Itlb➢,,,jp ^ 6^ ;5wu=yyqt� }q, , �
Thomna U g ylZe / 4.J.D. Deie6 Yai, d, 18G2 �
�'t�" -" PIleQ Juia 1l; t1B92. il�
�14y,_qi S� g�ql � ' � 3¢8996 fn 30( �'ydrpeBe SRb __�./--�-
ly1 and be °' nll L�at sraot or yaro�F IqaG ,_
�`B . 1A8 ln the County of ReMaey m] 9tat9_ti¢
�ommentiAng eR. the y,g, o0tc6r oT CnmyDel3e nddltton sn3'
L6anoe S.ly the B. L•am➢'�elle adQ1CSOn LO jy(
S:&. ponyy �id Cemp�l3e�edeltion th�ne� S. to�tLa yia)Savi➢➢1, -
rlver, thanod•ID'Iy along YS�a1ee1DD4 Rber to s polA4 da�,'8�
02 p;eoe u} pegimlvg„fiJ�evoe X, So aaid p>ca� of Eeglml�pg: �_.'�
Pragd�d yfet nb^ppr9,�oi eatCReal Setete :.�A�.pfepinef nRBl]
avqp. p ' yg�d dr 000qaled ezuePt Spr fl etre. C nr bve��� ' .�
asY�ertue',jl. @polg;•g,zeoutriz Dqed dats: Yey 8, 1891 �
of J'pmee g�� deaeeaeC. Plhad doas 30, 1896 , 'i
� - 13B�34 Sn 292 DeeES p%ge 663 �
tlty of 3t. Pa+i . eo 9nEtvl��ed �(2 oi Eqt I B1oeY ;i
�: �4� ' 20 l. Fmpa�addiW on� Ae1ng prope[Ly
tnyqu E� wq�d party oi tAe second yyr[ uad�s piooeedfu� foi tlt� '•
oi+afiip;, t4e�ing nnd eztanaSon of atreat cr levea Sion Ylseoaxi
eS:eeL to ploe gtieet, oonf}rmed !y Boaxd �f P¢p110 Woiti 'I
Ju1� IB, 1850. � _'- �- �
I
imII N. i.uDy � ➢eed,D - 4 aa� 9, 2B91I� ,, ""
to Ptl J¢ne 10, lELD6 � �
Jlt,� of St. Pavl . 1 �4�in E42 Deede �b6 '
� i
j
i \
_1-. ".
� ,
Y11�eG DuYrene k vtfa '
- to
� I Clty o2 St� P>al .
� ," .i , C .- _
� WS�;�am,Bp}ton SDenoar
�etel f
I,CSCS oS�St' Y � ..
:1 _ -- �'-.__ .. . .._
�/ �
Y �_
;• from 8tete Street to�i�entei
jv�od"firmed �pl� 19, 1890.
' _' �9�
� �' 1 1 �� '' .I�
k.. ��`� � ,...���y x . �/.;.�
➢a�6
undtvidsd 1/R oi Lq .1 Bloot' .
20 P. amee nddltYon. .,
W.D.
Y1`Ld
ll8.p
I,esa
f
,�
, ����
. ,_....
_ _f._ i
. �.�:. tl\\�, �
i �
n � :
�` { � .
� ,
_ ., . :
�
P
�
�
0�-�63
• �}i _
�� �'.; ;, ,
'�'�"T_. ��:i�,T,�z!ri, . , ;:r _ `,� �. �--�- . ,f.--, �__
;� �
. col�ne Yaday k n¢icaa6 - , iE.D. Datnd � 12 �1�9�t`
Lo . 111ad Swu 10� 18�1 � "
' Clty o2 92�iPe'3 � ETE De�Qa.yag� 668 � '- j" _
' eqn:l onQ14Id�Q lfi o; Xot 10,;�louk
' - EO BrooY2�nd fu uoqd•�yg-�s'ad� �
' ' tatSUg a or Uses Snom BfeL� �tnet ta oinj4r 11nY�bf
� l•laeourl stree+. - - " ' � . � �'� ,
i ' � �
� ido ]. Yo0n3ie k tae�md .,,' KD• Dutdd Jm.�D, 3841 . _
� . . tc , - � �b}ea Jvne lo.� �.J6Q .
,� C�ty o1 St. Pa�k �-. 29E Desdl�,y� �\� .,
{,� -�. -• �� a mi`a.i.t a ot t� io $� ;
¢t° it �.- . ' ZO Hrootl�ad'"ioz ooudemvf�� anp;+7,ab•
r lug 6 etreet p� 2�+�vlrem Sta�.e ttre�1 to o�Ltet 11os of Ii�aeoo.FhT
f eLrs9L. - ," . - P /
5 , �
;; - �"JOTn b. Oltvle� LL2� h.D. llAte6 Yey 6 1891 __
•�_ te .' 813ed Yey 9. 189�- '/� -- -
:t±' ' �1Ay of is. Fac! 191 Dee3u v%6s 68E �( -' -
' ' ' � Eqa11 unal�ld�Q 1�6 at lote 7; B�, .- i
�;y' Blo�� 18 Bx�ooYi�bd Soe opeq}�g, vldehing ar.d� cej� lon.of c- .-
t eet OS ls�e< t�2 Statb �sLaOeL �.o the uenNi °Soe of Hfe�oa[S .�
. .,��. n�.�9�, fi �. -., : F -
Ch�1e� p. Cel] �' � " Eel9ane Lated Juae' ,� 1BBY
,-�"�' � y�io _ �Iled.luna 31��1091 ��.. -'{ � ��
, JIi) 61 �.4t. ?uc l�' � 38 Blaol. pag�.624. -
- V, ' }6H3.52 Del�g 1f6,cI'CReFyampenxetioo
�' f'; � 5 - ' unII �dpmsgee ailofed n d ded b�
(.:�`� the BOarA o2 A:D11 � Norte 1G mn�tag Lhe' aoceeamYA; 1 �'� �?� t a� -'
- 6amngen, ainrde, e�ate anQ KpeAa�e 3or aonlsmniog pd fif{} ' �
� ell ot �LOtn 1, d SwuY 18 .8ionklyny iar a etr��q. or'. �� �_k�a
. '6t�ty Nard �rom St�t� ctreet ;o tha eenter 11w o1 Y18a�arf� ` '
• � fltTeet 4a ooqllTmeq Iu�Y 18. 1890. �� " i � ..
�
4,y 9ybeeter Ylpp k vi�{• Y.D. d�tad �una 4. 1d91 -�^'�
,p PSled 7ao� N+, 489f '�
� C1sy ot 9t. Pnvl � � 138133 tn ZAf Deede Yego 54� .
} ' Equal nnQlvl6ed 9/1� 01 Loi �10 'dlo�i
'}'' �' !. . ' 2o Brookl7vQ 3or oofarmning Bod tac-
��.- =<.E ing tr�tre�t,pr �evas from $tete atraet to oevtex Iioe o2 Mie9ana'1 -
., � it294C� `: ' " � .
� Ortio Kipp'�6 wite � _ '��.D-,Dated Sept. 21 18+1
� to Ytled SaDt. 2g� 1891
Cliy of SL. �enl '�- 14bY3P fa E89 1»ede Peg� 3T�''
� eqael ana2vtd�C 1/R o1 ;ot IQ Blouk
� 20 BKOOklynd S�nr uondemning anE tuTing a etreet on Yeeas 'iom I
3tnte atieet ttioenter 11na.of Nieno rl vtraet. �
;'.� leyle tl. CIlensy s Ausbend ' ".D. DaCed� 7m. 3, 1891 .
to Sl9d June.10� 1897
� Olty-oS St. Pnnl D8�3B Ln �7E Dsedn�yaga 666 . '�`-
. eqval vqAlvldqd 1/1{ oY�pot uBlook�'
, 20 8x6oklynd for mndemnlr� gad F ring a�Lreet saa lev���lrom � '
SYatl.atxe4t eanter�,�llno ;� Y B�oUti etrlRt�_ .� ( ;
+ y
llelen g- Wop6 b , 4 9euelpt Dste¢ �ag.�El�, .691 , /�
5�}verd N. HooB - )ti.a sevt. ][. 1691 � � ' �' T ,'
" LO ' ' � 1N�6Q SR' 29{ Pe�di WBa' e%�'�
- J1tY o1 St..P�al' , all Lpoes y�rt� b2�Lotty'1 : ouk 161�
. . nUn��ll t sPe�?WFa Wdi2knµ ] n8 J`
' II'IA,Sroa r liae dxum Srom g.S.;aoxaar oi Lot e�Etab�: 37 Dm�! `
Sy�no�x� tdditLdn to ibe o�nter ot the elln� rLl'a2 rpna tnroag4 - ,��) �
r -
_ .� . ' �.�� .
� � � � . � - .,k . � � ' .� '
/ , .
, �.
. ,_ - «., ':_-�_ � r
� • �. ,� �� � � �,
� �"? : _'_�.`_ ' _ �i�� _ ,.�aE.; .t.i J r� -r�l "�_ _
•
_ „
a
-363
�
� ;�. ; . .,�.
�° � � � . �;;, �r.ir, ?..�z�r�• , -
- � r,\
� _ ,_
;:� �
- �
� . �looC 29 at t6A acd of ad1II.➢qAx�ll,� gNO�-re �ddltloa fat , '
'aanAemning and {ett�,4 atre4l ps leiee fz�c- Stnte Kra6Y to �
�'' the osnter 11P� of 111seOnrl RLreeY eo aop2�imeA Eq Boeid oi �- �
PuDllo 1lozta Jaly 18��1H90. `_
9erah Mxnton 8 �neenna ' M•D. Duted A➢-• u. �e� ;` ,/ ;'� _
"" to � llled lane 2E. 1886
Ctp➢ of 3t. Penl Lot 4 2 f�stlle k iWbarte '
. � saa�seon. - ' -
/s��,oai n. zora, �nmazriea Q..:.D. Dated ;e) B/ ieea � ,
po � Yiled 9ept. 11,�dH , , , _
Jiti ot St. Paul , I 124 Deeda pag+ $OZ�
ell thnt pprt �e ➢or of LnY9 1 +
' ? 31me 1 3aaSIIO h imbexta ndOftion �a La�e tl.'ly 3�a �
evral+ht line'draon traw :1.3• uorqbr ot nl�z< 196 NaDQrtnoeo ,
--- n6dttlon co .��«- oorner of Dlou¢ ?¢+rr�nl� �33itton, Da1ryT neme
�� „rnr..inna cucop Oy ulty tor openind, axtendi�g enQ'wSCening ot a '
eaveac oa lavey ulong the #lealanlygl !ctro. Onnk Itom tte 5. ,
ilnerot cF.e LStY Sea. Y Tvp. ZU Funga 22 U tAa S. llne at j*�e
Jlty In 3au� 12 iap, 2Fl Nevge�23 ooqflr'o84 ky doai6 of PuL}So
� . nonFe July e8, lUb£. , "
!ruri.:tn �Ytiwuf n nlfe M•U. 1l�tah J�ac L8, 18E3 . �
po Ptlea Jany. .1, kB06
� • ..sJ „r :.c. 'tnul * �o �:�81ou� z tlsalllq'E � ,. .
� � !(oEerta ed41�.1•n. � .
" Lrl .,. 6umPreY�`�' :�tte' M1.�. �tteL d�.3.� 2. lbu3 .
�_� . q dilaa Jmy. 1.'1886
..c� 01 a4. rnul 151 lluean rn��a 301
� e,il tent y�r., �2 •iotn b, 9, e D1oo< 4
���� � - . .�, ' .. � Bnvllle a r.o.erts nddl�3on, d�1..� hee
• '\ baan\tukeo ar venaemneQ� Dy oltY to vYen o.�aaatl3e� a latep ,
l� �1oc�r Ype HlaetBulpkl dlvar ln the 6th ae d,
` �� i trunc Dufonr 6 wtie _.Y.L. LnieM1 O�G. 3, 16Ht_
:� � Lo � FIleQ Ue�BmO�r �N, 16tl2
l�tj of St. 2ua1 � 1« Lanav 4a e 142 � � �i
L�n i wa:t �siiid'� xooe�ca � ry,
, ' _ , udtlltion. - '
t � ,
{�ohn J. :�tivinr S xlte .uted Ju3Yl. . lbtl0 S ,
to ?.ied patobe ?4, 1891
� �t. FYn] ., 1490j9 Sn 20 �e�ds page bE0 �
�� ' lOtn 1, 2 dl :< 3 tlnzSFle k ftoCaitH _.
' . ..aainion. , � �
irap< 3qert n.x:Ya +�•U._Oeted': ��• 1 lBg2 �
tow Pllsd Deoeml : 28, 1083 '' �.�
- :ItY of St.�P,0.a1• —. 322 peede pe ' 143 _� I., .
� � Lot f Jloo� tlue111e � �o0ecif � '
,.Gdktlan- ' _ ,
.\ � nlbart �a. Luwcoa, oauhelqF x.p.-Lns�d > d, Idb� . ' �{r'
di;�d beoao �jB,'18B_ Y -
'�. I dltY�ot sCj Puvl': ',],{b Ueeda F 708 . = _
�� � -S '� ' �RZt o; Lot Glm" t 4 da flie � RobeYte
� �/ u4dlTlnn ly 4.�] of a�robMlgpt 11➢e '
� irawn lrom F 3.£. ��ozpyz'di n1oJY'M6 hob� on eddktlon �f tb� ;i.lJ.rl
,� �'� uoroer af dl`oJr 4 tlatahulla .Wd11# n is,. fOr a�eFaeeti ot levae' _
� nloog tha Ytaalxea1D11 r1eBr bu yahf!=m^� -BWTd o� Pa01ta �� _ .
� _y
' �ozaa july 2tl, 1CL'L. � � '
�� . .F '_9 "
i� " � F J �_ l . . _ ' ... , .' t ' I_ \>'<
`��� � � i���� � � .I .. ' ,� M ' �`\' `" .. �� . ��
•
•
w
�
1
� � S:/
. . ._ J� �, `„ � � '-, --- �— e - t ` �- - `
- .,d�c �Ij�J-�.� \ ix T" - }� . ) - � �.� ��� . . " yx
. :.' r `' �7 1� �1.�-� - ''
t . , . ,� ' �= s - .
,.
-- S:.�ue; D.,LOYff rri 1 �:. N. D. ated �v.-si9i1�3.-i'v
� � , : Co - Fll Yune 22i � 7.886 - : �� �� � "' - , i.
- ' �,��`. �' ._ ,�. � d'-,.-- ,_
=�5 �.FSEy of St. Paul ,,�< .� 19 Dae4s.➢aB� Tj
- '' -Lots 1, 3, { Siock'i�a 2,(`Lfe�' ' -
'�'c�},� ' HOOarts addlq.On 1yIng N:Iy of e�straigh[�llna drgMrsi fro�` �h� N.G:� . �
. co�3,er oi elock 776 koDeitsons additian to t2ie N16.: cornu ot.Block k'
aaunoiis addSj�on. LoLe 5„ 6, ena sii cnas paFC or �ocg 3 q;;8,�q '� .. -
, 1G �unneli & Spencers e�ditiop lyfng N, of a live di�Op��iti�f� -
�. yo3nt on E, s}dg ot "olock 29p 150 tt. S. of 2ha".N:&�. �rne� D(/! -
::oia eie�x i6 co a point un cne aiae,or ewce�l6; •i15„tc.`x. 4�. �� �
[::.; S."A_ comer f�eteof. Lots 1�,2� � q Block 3Q. 7�{n�e"ll���p6qcers -�`
a_. i�.1on„� �10� 11 Bleek Y4€6� Go�7.81ofk 19.jH�o ��, �'� .
,Y�� '� ' . �;�. t.' �.-� • _
pelSF,da�Soltwnrxi.. widov . .. '.Q.C.D. Deted Aug.�i7. 19Y6'.,` � `,
to F. 6ugust lj� 1926 d� �'
' CSt�t st, EaII , , q16156 Sn 81q Deg3s paga�.88 r ���' ?� �n:.�`,' %
_ , � ' � ColvuQnclug at the ii.W. cornp�; P ' '�j
�� - LoE` �'q B2ock y Baz111e & PoberLs eddLtion� Ltienue N.W.ly; nlong f.�e ' i
S. W. l y i lne o f 3u i d 2o t lq-DiqUUCed g distanc� oS q 8.1 fL. Ne�o ���'
�:: �W.ly eK ari anQle tio tye rSghC Prqm �asbdg scrSDed lina of 76?� �_
. ' degreas 45 mirmtes�o dl9tanca ot $$.'�2 ft �£o a polnc ot�be61 '���` �i�. �.
:Thrnce N.W.ly on last d0s4tlbed'line p1�od�ad 18 5,FL• �o,U'.5�_�` '' �`
,, HacEOr 11ne"^en the E.1� s19e of the N1ss3s SpP1 hi'JeE� Ui§�oe,� �
--� �,ry HenDOr /llne to an intersect3oa wltt� the'+�.11�.�}!'��� ��" '
_�'�, lSng ot Cvst¢r streat (i�bw.Ypcated) yiodaced N.W,ly tiom s81d.;?-�'�� ' �
�'��• ,�Baz111e & FoDerts tDenca S.P•.ly glong snld Southwestecl •�. `� �Y
—'� 111TYOC Custer 6Yr^YC (vocaFed) W a pd} nG i$a PeeL N.8'.ly oT Chp� .k, ��,,�'
N,.N'.I� llne of 3yock ¢ Bez111e & Robept5 additian �eosuretl�Aloq& '1 �F ,
'�--�setd E.w.ly ltne of Cuscer Stneet.,(vap:.ted) [nance�S.ly [o e � t��,� �
ppl�t 306.06 ft. from said p'pint'of begA��inE on a 31ne x�lch J,s y�'� Y.�i�a��
.. I:IQ ft.,A.:F.ly o: and ppeallel te the F.tr.ly it0e of Blofp d ��y '
• -;. 312S1.1B�h ROb9CC5 addltion.thancas.x�.1y r,loPb this`�ltnel'to-'poS� .I.�u -
oi bakfru�ing. � � 'ri' - �
�� � �1���
}�__._ yVieat Eid� Fealty Co.� et al 6e.il Dnfed �z¢t. o ly➢Q ' !` ' '"9r
� ; � ea ' FiSe senti..�1�7 i9�qe , �'.- °�
,'�ity o�' 6t. Nnui -+`. 669a72•in 990 Daeds pcga 5� '-� • ,�'.
- •5 Year� lsase drented te FmO;iv�q I '
� d� � 'rioisc & C¢r.ick Co.,From OGt. 2].;'n \ ii'
*�� 1J.95 r�1t6 opG;un Cor e�.t°nsiun for r.n atlai�ional "5 yzars �,(j� -�
, whick option w6s duly ezereised. Cov¢� ��� pjj> E.ly. Dy;a line�� ,'� y .� . {
,� pPTnllpl w2th lid 10 ft. Wfst of Esn^it�lln••'y',pf E. P.06ErL5t: � ,?+.
�i_.,_�.on�the A, Dy-the �Yestern l;�e of S. kotlayt yC�."'Vn tt+e b. ty e• ���.- .
"line dra�vp ynralle} w�(py nnd 50 fL N.],y Rom 6h@ 5. �'w4a � �• �� �,.°
'�� SSne of the levee yhe4e saldNlne crosees S. Robert Et�Snd on f d �?
th- N. ty'Cbu yTa�fie �rldge Pler r.hich lles nearest.to�tne f4ng__ ���
oo+.�t3tut}n� the N. powd:.tZ 11ne of LOts 1,9�j�¢ $lcZck 1 � +.
�.- kObeLL9 BddiLiVn., , ,_ � . • `
, �S�.ohn 8ovetter @ wltx , �. + y ��
_ ri.n; pacea nea a i383 � .
2 - � co Filea Suoe "92, 1�5, + �. : �
C�ty of`:.t::Peull' __ -�- -167 �aeds pege 4g1 .. �ne �' „�
ell thet poitiort oY Lot_ ] Bloc4(�� "•
Hxzille 8 AoDerts.nddltfon Lekea by LRe CFty-of &t. Peul "for' -
__ iha bth ward leva� e� eallea. . "- T '
i �'n ABdwerd yenish . - - CerCSPic860 p�� Title d68j80 ,� � ,` '
ta � � ,. �' . PS1ed.Jme � ' ' r•
:'-�� C�ty of Et.-Paul ' 193 pt P1t2es pege 219 " % ��
' �� � . � B}dCk "G^ RoDeYGdoris addltiod ' '
�"�"���P.11 th t strip p2e¢p or ' e;c U{¢xeYtom the fol]�wing:
���- j �, percel'of lgnd j0' ft«� 3i+ 1ridE� ore oi' le'sy..- �
�n.t5h 19 parVaS ssld Dlock ^Gn.pnd compeSse& oqlq- mdE}i�bY�said, � �
•.,�v,^D eg�.iea x1W.2n9�ft. on aSdeanA'21}'ft. oR �
�: _ • n �bld@, of the' oa tein TfDe of_ tt{¢,mune-8�.1y oy' {,ye` yivo-,(2)� 5 � '
i��MeY'f�acke-ofithe'�"ceg`c�',SC. Pgvl�'fjuneapoli! E Osahe' R6��ila� ' �-
aC az�st over pad ar}oas e�1d Htock �¢^, \. - iP�, �� �'
� � t - •
�� ' 1 10 � � 1' N� .� �
_? 1 � i ��f i _ ' i ,(_
�- J � �, ; s - y<F � � �l.
t � � � � - ' - ,� � ( � 1
� � � � v / � .-\ � e
��'»��.'.���,*.��* . ... � .w�..;a x .'}:>>x i �!, , . �_. � d�y. l � �J. `C � �,i/ ��
•
��-3��
r�
u
�
�
�
•
Q6-3�3
� ��s��. ;, _- � = -
-_ " f : , _ . : - - =�- _ � .�- - ..
�> = _
- r B Ij of .iiEi 3ae��y `stt��Y 50��p Gat`�p'"Yrv7aii ��' ' s�� . .
Add�tiya yroLn¢ad to 9d11'B�eK Sn HbbeStama�add].fioa taltc for 7
a s roqt or li�ee-dJ{yroo�e6lpes fo?_iES. opming� �rtanaloo and , y • � �
�•+rSd'!'vleg of sCr�et ot" lacfN e3ong £be Yieelaelyyi_RSysr'tros 8. FSne �
_ of tha G7ty }Sm1tE BoC.'9 'twy. Q73 AaijgB 24 ty ths 8. ;Sne of Clty -„'t;.
1lmita�-Sn Sec..S2 Tip. 28�Heage.23� caniSrned Dy HosiC oz Ai61ic -� .
. torks Sn19. 2$�:18P.2: . . . i . ' •
Hertin Imhoff # wiTe .' N.D. DnE9d Y¢rch g3� i885 � ._ �
� �¢� : .� - Ffled'JUne 22,'1886 .
CSty.oS'6L�na�,� �. " 192 Deeds Dage 15�- ' " .
' " '- dll oi Lots 5r b Block 187 - '
� •' Aobertaons edd3tipn bakan_f¢r pF�1ng nad ezteuaiory of e atnelt or
.levaa along Devk of YtpaSasiPD1 HSver, being a12 tGet yert aqE portioh �
ot eald lota lyinF N.ly�of tGe 6.1y 11rte of YcCatthy.'Strset in �
'Irv2ne5�addltion/.pio3uced to L131 atteeE in Rabertaons edditiou and
Da1o8 a plece ot �nnd 63 ft. .Sda ot"Na N, end npd 26 f0.. ov B. Fad .
�LEE leugt6 oi'.the nldt,h of Lh6 Cao lots abOVe nomed.' .
. ' Yary 8.'LaDut & tiu:Umn1' .N.D. Datad Ayrll 14� 1903
to � Piled Nayamber.l&� 1904
City of St. Pau1 , '�$3�3535 In�q57 Deeds Dage 3$0 '.
� ontl: f or w�,ly 3o rt. ot ct,a
following CrSCt of land, cemmenclnR et a polnt in n line N. of Y�llmore
xvanua parfillal W- th�. N.1X. o2 aeid Fillmore e'venue end dis4aut.�
35n'ft. trom the N.ly l.ne of xaid Plllmora a¢enuB. auch polat >f
.-'� commancement being 6. oi tl,E.ly 11ne'of South HaDashe Street end .
dlstent 20 it. fron en13 N,g lina ot So. Wabaehe eCreet rnra tng
frqo seld 'yo3nt ot cocmenCem nt In en 6.1y dlractiou and pereL y1.YA �
seitl N.ly 11na of�fkllwoa%� �¢. a dlstenes of 15J ft. to c poir.G�
thence ruming Sn fi.W.ly dtdection erld perallel vl[h seld N.H.ii line
' . of S: +�aDeaha SE. �o dier¢pc�of 50 ft.. to a polnt. runnfng th=.-=e 1n n �
: W.ly d3rection end 'perallel Ith the saFd N.ly i[ne of sald Fll.mor'g '
� Avenue e dla��rce of 150 ft. to.point� ruMing tnence S.ly and - ,arellel
r with tha seid N.E.ly liva o3 5. �'abashe St� 'e distence of §0 i:. t¢
'' the yoint•of comme[�r�ment.= �Said peT(ry Qult,Claias Lut 4 BtpCk "D" ;
� RoDertnOns additi� ( �
John B. Sanborn k�wiie, et al t�LD. Deted June 25. 2883
' to .'[' t Piled DecemDer• 28, 188j
City of St. Paul ' � �!'1Y6 Deeds pege 313 �
� n perpetuel eesement�for Cha mr➢oae
of a qublic leVee over end upo4,,�.ats 1�2 Ulock 183 end'over flnc
upon LoW�1�2yj Block ^Y" RoberQ,yons eddition.
�e
DenSel D. Yarril•1 & rtrlfe ��W.D. D¢p¢d August 16� 1$p3 '
� to � <xiiea June �2, 1886
= City'ot 50. Peul �� Y6y'Dgeds pege qOj. � -
� �.d'yerpetual eaiamm; for Na'� r➢oee
' oI a DVb11C ],8vea,o[�etreat ove%'and upoa�lot 2 31oCk ^A^� Lots �j� � y
� 4 filoCk ^C^� LOts 1�'2� ; Block ^E^� Lot 5 91ock 183 �d Lots 4.5
Bloi$ 188 AoDertaong atlEltlon� and siso�liots 5, 6 Block 2� 4ars'.all ` �
� ' addItSoa. -
�. �. � _ . ., �,� .
9att�ias 6aeh k wlfe .��W.D. DeteE Yay 1 1883
� to Fiiea Yer 26, 1ab3 �
( City o� S0. PenT . � � / 11� Dseda paQe 99 - ";' .
�� � Lote lJ 1 BloCk ^Bn Aobartsonu — '
eldiLion, tha aeid propetty Aeving bean �0ndemnetl D� aaid Cicy'�or ��?
-{ £hx oyQning of n straet oa lerae along thc be+ilc ot U�e Ylssianl,pl . —
. . Bivar. - . ,'
�
-�,�"..E .�";:— - l ' +
��� � 4sw:.+. � � \ �' _
_`"' . "" _'a _ _ ',
��]_<,�,;: 'q�.
u:9�i:�>'"�'d��:.i� �:_.:a-:�.,_-' _
�
�
.
, � !
� �
. :.'�. �i.� .
�
•
�°�—���
,- �. � �,
� �
r
Y� ' - - �� _ � � T �` -
� _ ' � � � � � ��
`Aanaoa B. ldavs wife_ - N.Da �atc ,tm 23
: Ln - ..� - . ' PSke4:Jtm ?4� �� -
" 'cih' ai St. Peul:' � � 19Y DeeQs �ge `. q: � . ." '�.:�} - F ', _
. .' ��- ' . Lok yyw.AOEert36 -
_bfing Me sam8" propenty'conde�a4 b7� aecoad.F Sor ead— -'.
.rldening of a atreet or levee Qopg YSe5SSS1F. -�iseT. t }' o � m S. 11ae ' �
�. . of eald Clty S4e. 9 T�p. pA &�ange 22 to 6� 11 > of. TLs uyCy7a Bec..12 �' ' �
Twp.•28 Aange 23rae�eonflrn�ad'by H�p,ard ot Put cc Worx� a�y iB; i88sf �i' ,�
� Frqdetlek`L. Olusteed� baepalbf'� IP.D. DflEet day 30� �j88j — '_ �; '?�
_ to ' � � FS1ed -0ecc �er R�188y . � :.' j ;, -
' City pf Gt. PRUl 116 D@'ed_ :a9 1' ' •
_ �� LotS ), E iock } y Ii�laae s6d}iian, ' -
' - ' ' Deffi&.em pioPertl tafen.an6 . ; - �
�° condewned for a aCreeE or levee along YSdn1= op1 R;Yer:} � .
i' Ia a8 Applicatiah oS Decrae R9� i8 � "} "��"
' ,�arQholomax fl. Norlerlty ' DSStrSC[ c ir£ Rameey`County f'� �
et el � . . Dated Ocb .e �/� 1Q08 J �-
� , � , F43ed OcL >r ]0� 1908 � � '
Y362325 1 >49 Deeds.yaga 24� .-
'Decreee thet c$e plat of Coutures addltion L ieat BL. P4u1� -
� racorded Sn ^ti^ Wes4 6t. Peul Town P7ata 2ag�. .0 De end deme Sa �
I - �ereby vacated end �ell tM streets. nnd aLley�- md yorLlo a of tEe
.
4
� eame in qaid eddition whera stre@LS ere by n :e Yiner+n $treety �
f Flavins ytreet,�Denis �treet, Bugena Street, +rtenae Straei��mQ- --- -.. ___
� Josepnine Street De end are hexeby vacated� -
'�. Thet tltle in aM tb the streats end e�leys vacated is'hereby ' -
'
' vesied Sn the foIloxing nomed petStSOners. '. '
I '.i�� • Haitholomew H. Yorlaibty� _ Nore dde F
. -L'eurice A. � '�' . CatN ne Gonray �
Fatrlck H., � Ynry ancy ' � �:�
�:_ JoM N. - � Juli� heT.00d � " i_�� �-�
NSChael J. ,
� erce➢Vthat the CIt1e to ffiat portion of Flfl•�� u S}ieet lying yatre� .
,��__..snnter�line thereof end "t�e N.ly line o[ Lot . Blqdk 6 in eaid�� �
edaltiort as *el� as E.ly Gelf oC elley ad)ac�:. . Co saYS ot 1 Fn
S'. lying Cetween N. ehd S�line ot sald Lot .�rodueed W.ly p ''
�- seld ti[le £s heraDy JeSted in the oxner"of ��: d L9t 7 Hlock b� ��
, kary L. e. Fu1}et eG al °' �,C.! . Deted Decamber'1� �dS85
' to . � F'11e� une 2P� 18d6 ;�
� Qtj ot St. Psul 151 ..� ds Pega j93
. ' Late Q 2 Block 194 '_ �
.? � . . • Itv:.... addlEion �
� Am...nFle Tvrnbull k hasband Q.0.:. eted�SepLemDeT�ay. 1982
, eo , f11e. '�a 22, 1886� ' ; ,
- CSt� ot St, Payf1 .' 145 �`F+ds pflge 203. y
�' �' f Lot ' 4ock 191 Tr�inel eaditlop
' 2homn"s D. Lewis k wiPp ;;.D. ! ted NovemDer 1g,, 1883 .
�� ' = Co . • Filaf �une 22� 1686 ' -
Cic �ot bCl Peul 16y :, as yene 388 '�
� s LoY ` lock C" k Lot qy Block�^Eti
. � ��'; ' . • RoDert ,ons addltlon. � , �
• �` SamuU7 sSngle W.D. � COd Dec�ber B, 1884 .
. + tb' ' � � - ' Plle� uns �2R, 1886'.
City'of SCS��Padl 192 i.-� ds Dage 12. ��^
' t � _ . + Lots -, 9 Block 3�ot y - �
EloCR Yd� BpopklynQ� slso Lobl Block �C^ do:_ teoaa ¢dditlon. ,, .
. i . . �.
. � , , � 1j_ . . .. � ' •
"[w�.` . . Y ' ' .
�-
__ . � .:� _ __..�_' _
' . I. ... / •- ._o`��-� -
�
n
�
•
r �
��-���
� � � ,
a�u�x. �:�«i-�30`z . —__ -- - — - . , . .
1 I '
u
" � w'tillsa seiieuhi�� �r{� 3 :. � � � n. ;tea ius�+iti 8: . -
• to '� - = 31t pr11 1',-}886 � ; '
.'- 'Clty of St. Psul ;` ' - 16� 3de ynye 334 ' :
. - ' ' -" . - 7,ot :loek 2(i Bsoo¢17m�'lddl- :
:'� . _ ' • . . . . Ftx . - - _ i . '
' xDeonhui� rion e �nia - � r . . �a.n. �sed ivae id.:i863 � .
.. _ � to i . ' .. P11� 5cCOS6� 2d 1886`i
. " �C1�Y of &L: Peul - 19q� Sde pn(e 14
. ' . . Lot B1ocY�19 Brook}y�W
. . add] �n. ,: . ' . .
.� � �Howerd"H1ll & wiie . (�.6. Dated DeeemDer 3� 153j
. •r . Lo - � F;le Itiyg 22�r1836 ,
CSty of SL. Pnul � , � � lqb >de+pp ge3Yj' � � � '
:` � Lot: , �-�9 .10. 11� 12
. , aloc 7, Erocklypd eaaicion ',
� Or_ L.: Lamyrey L xlfc K.D, tad Jepur.py ). 7�984
. , jo, . „FLlc .ns 22�, 78H�.
C,Sty of St. Paul - . ' '15b �de pe(�e ,j9 (�%
Lot= j. q. 5� 6�lock 20
& Lot 1 BloCk 21� er.d Lots 1, P� 3."4, $ Hlc 22 p. Ambs eddition. _
-The obJect af thls G,nveyance Ss,co grant ani sC la said Clt t6e
. rlght�.4o use nnd 6c�upY seld lmds for strent lsvee putDee� ,.
%
�1 � .
� , Yt Ee1nb �tlerstood end agreed CRat th sxty ot cha,second
par� w111.not sell or ezc5e�a c[q�-oP aucR yi,p 't�[ x,� i �o` t[Sist
+nc.. ��_� �
� oDCa3nlny CnE consant of the CSTy Gouncil of t CSty of Jt. Paul. pe aty'
QT Lhe flrst p>rC� ta such sale�or exchanye. �
' To �ove sY.�'Eo hold Ne same Cogethar n ell Lha AeredlZa-
. ments'and zpputtenances thereunto belonging or � uny xlse appertaining '
„ Lo tha said psrty at tno second paF�. its succ ors end assigis " _
4oriver. �
� �
IN 2e5TILONY WHE2�:OP Lhe sald perty of e tirst )art hae •
caueed theee Preaents Lo Oe Bzecu[ad by SCS,4a_ , lts Co::missiorter
- ot Pub11C Utilitles� its City C1erR and its Co raller. and SCS '
�oryorate seal Co ba hereunto affi�ed the dey . yeeq�tLrst aGOVe
;�rltcen. � 1 . '
1 CITY OF $!ffiT PAO' ' � � �
��.. �'� � ��� � :
�
t
1' y �
e �>
�� o s er P D 1c 0 St as
:. � ,rn ::r /
B
i% �, Y � a����
{_ .La� B �
rk� � . Comytrc er �
/
_ 1q_ .
�'
� .
�
_ __' _ _� '
.. .-� . . �' . . . �., - . . ... . I .. ..
@
�
"'� x ��: �= k�'� • =:
� ,
-- - -�= P°�` „ ,_ �. .
, � . �._ .: _ _::,.,_,_ ,_, .
r ; - , • ��- �:.. -
BTASC0P11I27N560'll )� ' - _ . ' � �'... >
.. �OUNIT OF:AAY86Y . 3 � �` --- _
�
' '- • ' :. ; , -
. on cE1r � . eny E931� �n , rz as...aocqrx'-'� � . .
- y blio althln-e d�or a�iQ c�er0onnil t�aarM xflMear.. . .
��� -YaDwy� Clpd� R. q ➢. 8aott cu6 x�1L IC 6oqqi1Ck—'
� c� me yarwPI233' �iW+m wEO brin aacli CY me : r�iwQm d3d bay .
Nat fl�ey are, rsapgetivsly !3�e �eyos� Cyr..m1 J�e'r o1 Pub�Se� -
f\ �Otilitle6� CSCy ClaTk Cnd Lhe CompyinllSr e t:r Wip�jittph :-' .. .
nemeE=f4 fTa f0regding Snettwu�t� and J�ek � e6e1 eiiqsaq� �-
- to s5:id 1riaErumeni:-is Ue o4tDOr�ta Jeo1 ot : Paorpnrst2on anQ '� '
M� sald Spntrumckt r.l ax'eouCad and naelx . Dc¢�lf of n�d=_.; .
_' coryorntioq py aptl�or}qy of bts CSEy Cmnt� - :ng Co�n411.-:`�`�. '
tilc Na. 9`�72j eyy�r,ozsd_Su�e Y9,.19;'$, d�a :a1e iill¢em `.
Ychouey� Clyde'F. Yey� '�Sllinm F. SCOLt n.�d : 8E F. UotCrlolr � '
actmo*ladYe sa2e inatromevL �o De the ftee . nd dsad of p}Qq -
. � coryorariGn. _ 1 ' � �
:r�y1.tIDG.,r � .. _ .
= � "`:' ' k - �� � � � D�z
� ,� , - -�--• �.
-!�'�` � dofsry PuDl'Sc _ � Coun[y YSnneeo
. "Ax � . �r,i Hy commY9 ] 5a'3_ � - t '� � .
�'
1 . : ' .''� (NOTAF.I6! .. L} . . �
. '%. . �`• . S�, ... ��_' _ . . -
' � ' 'e5 � . '� �� 4 ; . . ,
��r �� � +r� .fb� � . .
ril� : u: �
�:a!ro.+e�s--....�.�..,A,.�;�„' '� , . _ . .
� '�+a.; _ �_ t �
. �� , _
a: ° "�,:.�. _ �; -
' _ ' 4 � fp.. �
- � " . _� V . -. .
1� � , ' meti ; uN �. )e:4/hart '
�' . ; � p ��� ., aM�Yi � " . .
' RMOI S➢ y , �. /ee t pl�.e6 . � • ' •
� ' �. ew�q���. dµ � � - . . .
' �� 4 e { ._.�_ . W � '
' . . er uAYt�� ��rn�t • - .
Q `�- j��
\J
•
�
r
CIPortNr-.A N 4�AU � '�
' !ro �M �n . WT�Mirv , ; ' 1
�� ^ �N
M L:Y 4� y��� y�yy�y
. . �eolCwrlD��'yt'.YI" �OMI��e�- . •
• ' �W�. .. . •.
R. 4
4 _. W� . . , . '
- ` _'�t. •
x_.��.� `; .>,s.
i
�.PileA Ser r�tioM on LLS� 9 dsy of .7yy, A.O.1D3q;'��. :SO o'oleuk �.Y,� .
� . , . � ,
: ry '
� . ` ..�. .____� ,. - - - � . -`�
>:`� . ,
- ` , .� � -4 � i
{ j ✓� i(? 6:p u
� �, ,�, !,.� a ?�;n'r��tq�+�s�� Fi�� 4�r=
_ 3ay, � �����.1� .0 t�, ���k'�I r�=,.��'
�
_ :�,
e
�
\ J
•
�/
i
,� 1.
�
jj \
��
w r, yot_a�u�aa�.� eyyaat n;iyyes..
�aey.� Clpde R. ai�,��R'ilila,m:�F. BootL and Hsjold `- �-
az ysrsopsl y;di,owa ahb btlqg aach by me duly�_b�orn did, �_
: they are :espectively L3ia�Ysyos, CommtIIsibner of Pub21a, � �
Lities, Ci ty Cierk ?ad the._ CompLioi2�'r O'f thr corpQraLt�h � ��- .
:d�in tha torEgoing inatrumeat� and �tha.�'the ef�lx.flc�' .�
sy3d�instruvsr,t;�2s the�eorporat� 8ea2 of ^etd�-eorporat�hiaad�� ' �
�, aald i;�stru�e}�t »as execuxed. neal ia behalf of s8}d-- �.
��oration by a�tnori�ty of bts City C..unc. Da3ng CounclA.���-- ,-'
: No�. y�72j a;rr,ov_d.3une z9,.�1933 e�ad e�aaid FElllam -� '.
�ney, Ciyn-e n. kay� 7�ilifom �F..Scott ap� arold F.��Do9Qriclr �_ .-
zoKlsdg� �s!d 1listrument :o be the Pras L und desd oP y,tid. -
?oxat4oa. _ � .
: i� �� . . , ,, � . -.
. - , �� - - -"'E L��—�-; � " " '� J -� �.
' _ :+oLary'Public maey Covnby Yinneso� '
� dy commi�sl)n plres' ' �
(tiOTkfiI; Sc.JZL}� ' .
` • . rT �i �.� .
I � ., �
.. C P. No� i6TT �: v �CU �R lpav✓ , : .
" I �� P.Im�{e�tEi f
l�Wtl4asR. . . '_+9%Of�.![I�. ' _
a
� �� ACoptee�y fGe.0 G6nef(IUne➢I.11A
ApwOVeA`SUVY O. Ilii. .
1]u�f, 141ii) _ _
i .
i �
1. .. _ . <..��.zs� .:�.�. _.w.,_ a
r�oor� on Lhe. 9 dsy of Jva�, A,D 1P34,� r
. 'L �
�r � �
�
.
��
r
'� .
. ,
, •
f
Dt30 0'o2ook d.Y 9 �
�_
� , � , .
. ,� ., _ ___ �- .
a +�.
� � _ . _ i . . � .
ry s' � .
, .,, r_. �:h. _ tt - . .
`' ,}. ___"—_" '-_. e^� Yi '_ ' j ` '� . . ' .
' f� i. �'
::�
� �.� ; � �
� .� d
�
L_J
Z�
�� la
t �_ ' � S
� N 112 I
� Sec. 09
� T. 28 I
� R.22 � j
� RAMSEYCDUNTY I
M/NNESOTA �
t PARCEL MAP i
I
Ra//a9� Guml RrNte WaBs
' lsndSnneyDiruw» ._:
Ram�PGwnN�S� y ' '
S i � `
S V�cwn Mvp � �
� ' �
f . �
�. _ ;- J : d
_ - -�; :.��,-� � �
F p % �i
, <1,
��
_-' � ' f
�� i
�- � �
i F
�� � •
2 '� ' •:vn...
$ � � ��!'T•
w °•�� �.i
� ao , o xo w � �� /
� E t`- �'K
t2aao �
i
; i —_ t -�'—_.' ^— " -.%
i. E "��_.
.,� �o� — - -
�.�..4 ���� i
R �OC��P \ m.-.u.= I
_ � `�..'2� � �
a-�. �� � lT" `�-
�< ?�` `O � � (
�� r^r q
� � ` � ;�.(!r
�:,. •
e
, ..�� ,�f = � I
¢ � t � �� � . _ ...--- -
�
s'�� i
..' !
� !
. , ,� �
; �.. -�. �z! ';r'_ -- - - �
,� �/ -.
�L„�_i, ;
yk . �
[ � :�
r � w,w- Evs�v -. -- r-
' .. w��isowa,n � �;
� '
!.
L- _ ;�
�- _ •-�Si/ t /
f_ �ti,. �' �
!'°,� - �
�� +� r �rub.e..�cawrm �
' urmeegae.c,wwv.aav�n
. S.MLY �SStOLl65l
� (N)�566ffiS
� _..
� � � ° vemi�� nramm
f'
x. a�etwe�aweYwn
� iq�rem�4n� _ .____ ._ _ . _ _ _
�I
�
_ . 9
-. - ' - ". .>-` - ;\ i
;.. _ -
-=--'��,� �-, --. ,
` ,���� . ^� !
i�
� . � �
� . _ _�� �,'s
��� � .
. � �. 1, "_ � __ -. . � .�,,..
_ 1 . _� J , ;. �
_ �s ' - i
� _ j -' Li
� � � �
- _� -- -, 'T� gi_ t�. r
���/ "—!
_ .. -`_.� • � - ' i ` _
. _ - �;,_� ; , . � �' .
i �y:
� � � `�.
� i E h
- a . � _ .�.� , y � ,......, r .:\'•_
, -� ,
: ,� ',:-.
� r i �� . �
. . . �.��._.._.___"L__T-..
Y1H� Sy3tm 4ei�itta
e .� ASVISBD eo1'. 300f
— '___ __ _
MmOd2l i ]23:143W3
� N
��
�
N
F
0
;m
�
IN
I
;Z
�
?
ol
1 �
e
�
�
�
S 1/2
Sec. 09
T28N
R 22 W
RAMSEYCOUN7Y
MINNESOT4
P9RCEL MAP
�� RmnaeJ'CwnNFreAlic{Ywks
I laMSnrvryDiviumFamsey
C rrtyGlSCroup
Yaniry Map
4�2�ii
W�
mo o mo rm
�
f`=200'
t2400
�'.. Q OpmWalu-IY9G
� Q Mwidyal Bowdare
R•.=�sravrcts
, ��lnerrwoia
'� �mrdau uwa
'� .4dwB�f.N dcSitIL3933
. (QS])}f6.)J�
9
__ � . _� _ .. . _._.. � _ . . . _ . .
—'.._ _. _. . . .—"_._.._'___—'_" !6 7Au1m0514:18:502fA]6
�"'
N
! N
I �.
Z
� �
N
I F-
o�
O
V
m
i,�
N
r
�
C?�
t
.
�t
�
�
r�,rm�r �as�ars � � ° � b �
�
•
THE PCXtT AUP�tPPY � THE QTY � ST. PAOL, a body corporate and politic
arganiz� �nd e�cisti.ng w�der the pzovisions of Minnesota Statutes,
Chapter 458, herein called "Grazitor", foz and in consideration of One
Dallar ($i.00) and other valuable mnsiderations hereby conveys to the
ME£ROPCF,ITAN AIRP�PS COFbffSSION, a public corporation and aqe�cq under
the laws of the State of Minnesota, as "Grantee" for the purpose of
assisting Grantee i.n its runway develop�nt project at St. P�aul Daantown
Airport, penranent easeinent rights in real estate owned by Grantor in
the County of Ramsey and State of Minnesota as designated on plats
attached hereto as F3diibits A and B and m3de a�rt hereof.
Both permanent easeaents sha11 inclnde the right o€ ingress and egress,
along with the folla.ring specific rights:
Exhibits A delineates the easem�nt area re�uired to permit Grante�
the right to constmct and maintain a runway safety azea; the right
to construct and rtaintain airport approach lighting and�ther naviga-
tionaL aids; the right to prohibit placearent of any above ground
struature ar object, grading or other eonstruction which v.ould create
a obstruction to aircraft operations; and the right to prohibit any
other use of the area enoatqxzssed by the easeirent which oould be an
obstruction to aircraft operations. An obstruction to aircraft
operations shall be interpreted in accordaixe with Federal Aviation
regulations and F�esal Aviation Administration Pdvisory Circuiars.
Said ease�nent area to include all property within lines para11e1 to
and 750 Eeet on either side of the extendecl.nuiway centerline of
Runway I4/32 tbearing S. 34° 37' Lb" east) e�ttending frcm the
t�C/POrt AuthoritY Prc�ertY li� southeasterly to the river.
P.xhibit B delineates the e area requized to pezmit Grantee to
constxuet, imintain, and use an airport access road and its asso-
ciated ditches, �r, and any nec.�essary utilities, Said ease-
ment area is described as follaws: Bornsby's r�arrang�nent of block
5 af Brown and Jackson's acldition to West St, Paul, Ramsey County,
Minnesota, part of lots 7-10 lieing c�sterly of a line 50' c<esterly
from ancl parallel to the centerline of �he Chicaga Rock Isla�i and
Paaific Railroad; all af 2ots ll-16, inclusive.
Grantor, for itseif, its successors and assigns, cbes hereby grant and
convey to the Granfiee a11 grasses, shrubs, trees and natura], growth now
existing on said lands or ttiat may be hereafter glanted ar grown thereon
which Grantee rennves pursuant to this easem�nt.
Grantee, for itself, its successors and assigns, does hereby indelmify
and hold harmiess Grantor frcm clauns against Grantor by reason of
Grantee's use of said pranises pursuant to these easgnents, and Grantee
shall cause Grantor tn be nam�3 as �Iditiona2 insureds on all insvrance
r 1
L_J
•
•
f
�
.
��m���
policies required by Grantee of Grantee's contracbors or sub-contractors
for the vz�rk coni there�.
Thf3 Pe�a[lent Fa��wn�'Sh,ll rHt13it1 i.n effect so lOng as SC. Paul
DcHmtam Aizport is cQerated as an airport.
IN TF;'PIMONY WE�F. the said Grantor and c�antee have caused these
presents to be executed in its corporate name bY apPropriate of£icers as
oE this ��` day of Avgust, 1985.
�
�� /1.i C
✓%.ir � ,.t�� �
/
d�.� ��
l.� cf— wt� s
witness
t .�.� . �..�.� •• � •
�'��� �
� l« . �.
„_
— ._.=y
r�
LJ
�
�� ���� idd �ssrss JW
���
� ^.�..
� '•'.✓.•:•' •
O `� Y i ��
� ,
� , ., �
�• .
� ,
i �'�� �
' �" � �
: .' � � .
� i s :�, � 1 1
� %°' �' ,� /
i �� �
�� '' i i �/
/!` _�� i /
������ 0 �� / � �i
� \R , ,\Q � � .
�1��,��� � �� �
. n � i
� / �
// J
. �
, �
���
�' �
-.'a�, � :
� �
-� Ma �� �
z �r¢�
� cnmzw
a 1i Q �z�o
. z z(Y��s i
z��2p`� �'�
��'�¢�� �
v)w—i Q
w�W p
�az�z Q��
¢ � U �� P /
!is �`
0
z /.
c ,
7
! �
4
84
/ �,
0
. / Q
l
��
-o
�
1 �� *
� ..
.
S� � +
. .
.� t,_
��
z
W
� �
��
Q
� ti7
� � r ;. ..
1 Q
r
0
f..
� � -e I
r �r•
5 X
a �
�
�
ti
:. ,�
vi C'
/ �� ��v
�� T
Q� U�
: ���
.��-
f
� `�C� �
C
J' �
�
�
� f
/ /
i
' �i
i �
i
.� .
,
. .
_� .-
/� .
\ t /:
/ / �
� �.
. �
� �
�
�' i _
� i i
� / i
/ /
, � �
� � //
/ _
� /
i
-' //
� .
i �
� �
. i
, �
/
� `.
�`,>
8
�
�
� r �
•_._�`_______=====a_ ':.
� ' � '� / `� \ o � _ � �i �
i � • �
i
/ �
i �/ �/ �
-' � -'=�� EXHIBIT B
, � -.
, . -�� .�- -
� ,- , , ,
�� . '
i �
i ,�
� � . ��
� �
� �.".
� �'
�i
r�
t�
� , --�
�� i
� � ��J
I � � �
� � //
/
i � � .
� .^� i /
'; I i //
'`' % �� f!
. 11
� ' � PERMAIJEM'
� � E�lSEMENT FaR + I /
� ,hIRGbRT hcCE55 Ra4�J� f
' � AND ASSoGtqTEt7 � !
� � pr7CNE5. t ' / "
�� f �
U f �
�
:F
��
..
�'_='= v'
\` U
�
•
�
Legal Description
Hornaby's Re-Arrangement of
Block 5 0£ Broxn & Jackson's
Additio� to Hest St. Paul,
Ramaey County, Hinnesota, Part
of Lots 7-10 lying Aesterly of e
lfne 50 feet weaterly frara and
parallel to the centerline o£ the
Chicago Rock Zeland 3 Pacific
Railraed; a22 of Lots �'1-'f6,
incluaive
// / •' O / .
� `\\��
���\\`? O Q \
.�0� � O �
Oxner Ho. of Conveyance
Port Authority
of the City of
St. Peul
➢oc. Mos. 164z947
(Abatraet) and
4g2998 (Torrens)
(1965)
0
� �
�T_\'•
! . ,�
riat 28 2008 I;24PN
•
190DlandtnatkTOViaz
345 St ee[er So-ett
s�u ead. �n�ow
ssioz-s�s�
� eORT
J 9
6 �;1� a
m
�bS lti�
March 27. 2006
Mr. Joh+t Chof
City Attomey
Office af the City Attomey
400 City Nall
Sf. PaW, M[nnesota 55102
Tel• b5h224-5686 �
Faz:651-223-5198
7oli fre� BOG�328-SA77
yry/W.S�a,cCm
SUBJEC7; METROPOLITAN AIRPORTS COMMISS[ON (MAC} PROPQ3Ai.
' Dear John:
The Port Authoriry has been aware for qulte some llma that MAC has been preparing a pian
for the construction oi a levee and a flood wal{ systam around Hofman Fleld to protect it
during a 100.year flood. Part of the proposat catls for a sacailed compensatory excavation
alohg tbe rrver natY� of thg port Autborii}�s SoutNport lndustrial DSshict and easta�ly of
Hdman F'�e[d.
p.2
The proJect was approved by the planning Commission on February 2A, 2006. An appeal
from ths Ptanning Commission's action has been take� by a variefy of ciUzen groups to the
City Councit, and it is our undersfanding fhat a pubBc hearing before the City Counc(I is
� scheduled tor Aprf[ 5, 2006.
A revlew ot iha proposal by City sfaff and MACs outsfde counse! sinca the appeaE was 81ed
with the C(ty Cleric in�cates Uiat Ihe Port AulhoritY has an easement for levee purposes wer
the shorcline easteriy of iha airpwt whe+s MAC proposes to undartake Its compensatory
expvation, lE would further appear as if MAC Ss the successor in interest of the grarrtor in the
undedying ptat and tharefore fBe owner of tha fee interest In the land.
Therefore, Yo the axtent that tlie Port Authoritys rols as a property iMerest holder is gemtane
to the Co�ncf4's canslderation of this matter, piease consider this letter as nottficatlon of tha
Port Authority's wilYngneas to grent to the MAC the property rights rtecessary tor tha project,
should the City approve Uie projed.
We ere also rolndful thak MAC as a public body has the power of eminent domain and can, N
necessary, ac4uire easement righLs not incor+ststeni with the Por! Auihoritys use of the
sMre6ne. Ifi tha C�iy..approves the si#e ptan and the propased va[iance, the Port Authority
8oard ot Commissioners pn act within 60'days to grant to MAC an easement or other
appropriate righis conststentw�th the Port Rvthoritq'scontinuedvseaf rivershoretineiar
barge fleeyng purposes_
Sincere�y.
.�
Kenneth R.JOhnson
Prestdenf
981a7.vt
651-223-5198
• '-'_ _'"' _ . . .._
�� �;-
• city of saint paul
planning commission resolution
file number 97-g1
lJQte November 21, 1997
WF�REAS, the PORT ALJ"I'HORITY OF ST. PAIIL, file # 97-268, has applied for a Special
Condition Use Pernut under the provisions of Sections §65.222(3}, §65.224(4) and §65.225(4) of
the Saint Paul Legislative Code, for the purpose of ailowing the placement of fill on the site to
elevate a proposed manufacturing building above the regulatory flood protection elevation on
property located at 747 SHEPARD ROAD WEST, legally described in the file; and
WHEREAS, the Zoning Committee of the Planning Commission on November 13, 1997, held a
public hearing at which all persons present were given an opportunity to be heard pursuant to
said application in accordance with the requirements of Section 64300 of the Saint Paul
Legislative Code; and
WIIEREAS, the Saint Paul Planning Commission, based on the evidence presented to its Zoning
Committee at the public hearing, as substantially reflected in the minutes, made the following
findings of fact:
• 1. The applicant has a purchase agreement with Citgo Corporation for the site. The site is being
acquired for the purpose of relocating Plastics, Inc. to the site. Citgo has allowed the
applicant access to the site to place fill in preparation for further site development.
2. Section 65.224 (4) of the zoning code permits placement of fill in excess of 1,000 cubic yazds
subject to the following condition:
When at any one time more than one thousand (I, 000) cubic yards of fill is located on a
parcel fnr such activities as Zandscaping, roads or consriuctions of flood control works, an
erosion/sedimentation control plan must be submitded. The plan must clearly specify
methods to be used to stabiliye the fill on site for a regional flood event. The plan must be
prepared and cet�tified by a registered professional eHgineer or other qualified individual
acceptable to the planning commission.
This condition has been met. An erosion/sedimentation pian prepazed by TKDA has been
submitted. Review by staff from the Department of License, Inspections and Environmental
Protection (LIEP) has found the plan meets applicable standards for fill in the flood plain.
moved by Field
seconded by
• in favor �6 ���in �5���>
against
f .. -
• Zoning File #97-268
Page Two of Resolution
3. Section 65.225 (4) sets forth the foIlowing standards pertaining to fill:
Fi11 shall be properly compacted and the slopes shall be properly protected by the use of
riprap, vegetative cover or other acceptable method
This condition has been met as per the erosion/sedimentation plan.
NOW, TI�REFORE, BE IT RESOLVED, by the Saint Paul Planning Commission, that, under
the authority of the City's Legislative Code, the application for a Special Condition Use Permit to
allow the placement of fiil on the site to elevate a proposed manufacturing building above the
regulatory flood protection elevation at 747 SHEPARD ROAD WEST is hereby approved.
�
LJ
u
� � J .�
� city of saint paui
planning commission resolution
file number 97-38
(JCite June 13, 1997
WHEREAS, RYAN COMPANIES US, INC., file #97-114, have applied for a Modification of
River Corridor Standards under the provisions of Section 65.650 of the Saint Paul Legislative
Code, to allow grading and filling within 40 feet of the biuff line, on property located at 909
MONTREAL CIRCLE, legally described as Lot 2, Biock 1; Crosby Lake Business Park 3rd
Addition; and
WHEREAS, the Zoning Committee of the Planning Commission held a public hearing on
June 5, 1997, at which all persons present were given an opportunity to be heazd pursuant to said
application in accordance with the requirements of Section 64300 of the Saint Paul Legislative
Code; and
WHEREAS, the Saint Paul Planning Commission, based on the evidence presented to its
Zoning Committee at the public heazing, as substantially reflected in the minutes, made the
following findings of fact:
• 1. The applicant is a representative for the owner of the property in the Crosby Lake Business
Park. They are requesting a modification of river corridor standazds to allow the
construction of a new faciliry for Harris Contracting Company, a 79 year old mechanical
contracting company currently headquartered on Territarial Road in Saint Paul. Due to
expansion of their business, Harris has outgrown its exisfiug facility and chose a site in the
Crosby Lake Business Park to allow them to remain in Saint Paul.
The modification is being requested to eliminate the need for large foundation retaining
walls for the building and a retaining wall for a portion of the pazking lot azea. The
applicant adds that eliminating the retaining walls by grading on the setback allows the
building to blend into the river bluff while maintaining the bluff appeazance similaz to what
currenfly e�sts.
The requirement for parTcing and the need to provide for an interior service road necessitated
the placement of the southeast corner of the proposed building within one foot of the 40 foot
setback line from the bluff. At that point, a foundation retaining wall of appro�cimately 10 to
12 feet must be constrncted to support the souUleast corner of the building. By allowing
moved by Field
seconded by
� in favor 13 with one abstention (Field)
against
C��-3�3
• Zoning File #97-114
Page Two of Resolution
grading within the bluff setback, the grade can be raised allowing the construction of a
smaller foundation walL In addition to grading neaz the southeast comer of the building the
applicant plans to grade within the setback from the bluff line for the construction of the
parking azea west of the proposed building to f ll a deep ravine and create a natural grade in
lieu of constructing a wall to support the pazking lot azea.
The applicant states that once the grading and fiiling is complete the area will be planted to
revegetate the bluff consistent with the existing condition and that of the adjacent properties.
In addition, two exisUng trees on the site near the bluff line will be retained and protected so
the grading will not cause injury to the trees or their root systems.
2. Objectives of the River Corridor Development Standazds• The city has established
development standazds for the river corridor to "maintain the aesthetic integrity and natural
environment of the river corridor....to reduce the effects of poorly planned shoreline and
bIuffline development; preventing soil erosion; and implementing metropolitan plans,
policies, and standazds." (Section 65.401)
3. Findings for the River Corridor Modification•
• A. Site Conditions: The majority of the site is flat and devoid of vegetation.
Slopes The majority of the site is quite flat. The southeastern boundary of the site is
the edge of the bluffline where slopes range from 25 to 65 percent.
2. Soils The majority of the site is located on urban land, with soils appropriate for the
development. According to the Soil Survev of Washineton and Ramsev Counties
identification of the soils for the majority of the development site is not feasible
because the soils have been greafly altered in various ways by consiruction. This
azea is iden6fied only as urban land and is described as being more than 90 percent
covered by buildings and other impervious surfaces. The survey also notes that
runoff is high and often flows into storxn drainage systems. If improperly channeled
the increased runoff from nearby azeas may cause severe erosion. Tlie survey adds
that on-site vegetation is essenfial to properly evaluate and plan development for
specific purposes.
The soils along the bluffline aze Doerton-Rock outcrop complex, 25-65 percent
slopes. This soit is chazacterized as very steep and well drained. The survey notes
that because of the steep slopes the soil is poorly suited to sanitary facilifies and for
building sites.
•
4
0�-36�
• Zoning File #97-114
Page Three of Resolution
3. Site issues affecfing construction The River Comdor Ordinance restricts
development within 40 feef of the bluffline. If modification from this restriction is
approved, the filling and grading should be done according to the plans submitted
which indicate a tapered slope to the existing grade.
B. Hardshin The River Corridor Ordinance states that the Planning Commission may grant
"modifications where it appears that by reason of exceptional circumstances the strict
enforcement of this chapter would cause undue hazdship and strict conformity with the
standards would be unreasonable, impracticai, and not feasible under the cucumstances."
The project meets this condition. The need for the access road along the westem
property line pushes the shvcture to the southeast, and closer to the bluff line setback
azea. The project presents exceptional circumstances and strict conformance with the
standards of the River Corridor Ordinance makes it unreasonable to require construction
of foundation and retaining walls that are longer and taller than would otherwise be
required, due to the prohibition of grading and filling within the 40 foot setback azea on
the property.
C. Burden of Proof The River Comdor Ordinance states that "the burden of proof shall rest
• with the applicant to demonstrate conclusively to the commission that such modification
will not result in hazard to life or property and will not adversely affect the safety, use or
stability of a public way, slope, drainage channel, or the nahual environment such proof
may include soils, geology, and hydrology reports signed by registered professional
engineers."
The applicant submitted detailed plans, drawn by a registered architect, showing that the
development can take ptace without causing a hazard to life or property. These plans
were reviewed by city staff: The plan provides suff cient detailed informa6on for staff to
assess the ability of the proposed filling and grading to take place successfutly on the site
withouY deh impacts.
NOW, THEREFORE, BE IT RESOLVED, by the Saint Paul Planning Commissaon, that under
the authority of the City's Legisiative Code, the application for a Modification of River Corridor
Standards to allow grading and filling within 40 feet of ihe bluff line, at 909 MONTREAL
CIRCLE, is hereby approved.
.
Page 1 of 1
Tom Beach - Fwd: floodwall
06-363
From: Patricia James
To: Beach,Tom; CC-Agenda
Date: 4/4/20D611:18:37 AM
Subject: Fwd: floodwall
»> <Hldundas@aol.com> 4/3/2006 9:25 PM »>
Dear Saint Paul Planning Commissioners
I am requesting that you oppose the Holman Field floodwall. Saint Paul needs to:
1) preserve its neighborhoods by reducing a+r traffic noise
2) preserve the environment
3) respect our neighbors on the river
I believe that you have heard from many people about the first two concerns. In March, I
became aware of the third. I visited the Nationai Mississippi River Museum and Aquarium (in
association with the Smithsonian Institute) in Dubuque lowa. One of their interaetive displays
was a large table model showing Dubuque and the Mississippi River with water flowing
through the model. The water flow could be adjusted for factors including other cities building
floodwalls. The model simulation demonstrated how floodwalls cause problems for other
cities, like Dubuque. How timely for me to see that display!
One of the museum films talked about the Mississippi River being like a street where we are
all next-door neighbors. The film spoke of not doing harm to your next door neighbor.
Please oppose the Holman Field floodwall.
Thank you.
Rosalie Bunge
file://C:1Documents and Settings�Beachtom\Local Settings\Temp\GW}OOOOI.HTM 4/5/2006
Page 1 of 1
Beach - Fwd: Airoort Dike
From: Patricia James
To: Beach, Tom
Date: 4/3/2006 323 PM
Subject: Fwd: Airport Dike
»> "Benton Hummel" <Benton.Hummel@state.mn.us> 4/3/2006 1:51:40 PM »>
Since I have been assured that only select speakers will be allowed
to address the council Wednesday night about the airport dike and
that my value will be as a warm body, I decided to get my two big
questions in ahead of time. The first is "Who benefits?" The short
answer is Minneapolis, as usual. We are not talking about bringing
in a gaggle of tourists who will stay in our h,otels and spend money
like drunks. We are talking about people who will be met by
limousines with tinted glass so that they won't even see any of
Saint Paul as they are whisked away to either eastern or western
suburbs. Instead we will get a 20 foot wall likely to be_as ugly as
home-made sin and the increased corporate jet tra�c. Corporate
jets are loud. Not only will this degrade the quality of life on
the East Side, but it won't exactly thrill the peopie who have paid
for classy living on the downtown banks of the Mighty Mississippi.
T'm sure Minneapolis wili mention sacrificing for the common good,
but why should Saint Paul not be considered as part of the common
good?
My second question is "Who pays?" The Airport Commission has said
they will buiid the 20 foot high walls. Will they maintain them, or
will the expense be passed along to Saint Paui residents who will
not be using the airport? I can remember taking Capitol Airlines
from Saint Paui to Chicago perhaps 10 years ago, but Northwest made
sure they didn't last. I have not used the airport since. Will the
Commission pay for the ongoing dredging that will need to take
place? Will they cover the graffiti that is going to spring up
before the walls have dried? Somehow Saint Paul is going to wind up
getting hit in the wallet on this, and we do not benefit.
Please vote "no" on the airport dike.
Mary-Benton Hummei
1199 Seventh Street E
Saint Paul, MN 55106
;
�������
file://C:�Documents and Settings�Beachtom\Loca1 Settings\Temp\GW}00OO1.HTM 4/3/2006
OFFICE OF LICENSE, INSPECTIONS AND C�
ENVIRONMENTAL PROTECTION
Bob Kessler, Ihrecto> ' J � -- /,
SAIHi
PAllL
�
AA*A
.
CITY OF SAINT PAUL
Chnstopher B. Coleman, Mayor
March 9, 2006
Ms. Mary Erickson
City Council Research Oifice
Room 310 City Hali
Saint Paul, MN 55102
Dear Ms. Erickson:
COMMERCEBUILDING Telephone: 65I-2669090
8 FourUr SbeetEast. Sutte 200 Facsrmile: 657-2669124 ,
StPau{Mrnxesoto55 1 01-1 024 Web� www.lrep.us :.
f would like to confirm that a public hearing before the City Council is scheduled for
Wednesday, April 5, 2006 for the following zoning case:
Appellant: The appeal was filed by Friends of Saint Paul and Ramsey County Parks
and Trails with Friends of the Mississippi River, Audubon Society and
District Councils 1, 3 and 4
File Number: 06-051296
Purpose:
Location
To consider an appeal of the Planning Commission's decision to approve a
site plan and variances to allow the Metropolitan Airports Commission to
construct a flood protection system
644 Bayfield (Holman Field)
I have confirmed this date with the office of Councilmember Thune. My understanding is
that this public hearing request will appear on the agenda of the City Councii at your
earliest convenience and that you will publish notice of the hearing in the Saint Paul Legal
Ledger.
Please cali me at 651-266-9086 "rf you have any questions.
, NDTICL ��'
Sincerely, �,,P� f� „n,.-,w ;`m.,r ,, ;�.
public hezr3rig���ori"VJednesday;�=iCprll 5,
2006, at 5:30 p:m.'in"3he cCitiy, Council
Chambers, Tlvrd Floor City_fiall,'15 P3est
•
Tom Beach
Zoning Section
H:\COMMON15ite PIanlBig pro�ects\Holman Fieldlrequest for cc hearing doc
F7iends of fhe=lviississippi.l2iver Audubon
Society, �and �DistrictLouncils �1; 3 and 4
to a
approving a site plan and"variances to�a1-
low the Metropolitan Airports Commission
tn constn3cf-a-flood�roPection-system �at
644 Bayfleld.StreeC'(Holman FYeld). : _ .
- Da4ed: A1�Iarch 1�5: . -<.. -.-- -
_ MARY�32ICIS�OkV� . ;. .., -.. � -
� Assistant Citq'Council Secretazy ` -.
..: .,: _.,,._ :_ �azeti'2o1'_, . .--__ s ...
_= S2-PAIIL'LEGiYL3.EDGER �___�___
$2112051 � - -� -
AA-ADA-EEO Employer
OFFICE OF LICENSE, II35PECTIONS AND � e , �° °'
ENVIliONMENT'AL PROTECTION O � ,� C� .+�
Bqb Kessler, Director
c.�sr
rar�_
�!�
IIIAAA
�
�
�
CITY OF SAINT PAUL
Christopher B. Coleman, Mayor
March 28, 2006
Ms. Mary Erickson
City Council Research Office
Room 310 City Hall
Saint Paul, MN 55102
PURPOSE: To consider an appeal of the Planning Commission'-s decision to approve a site plan
and a request for variances submitted by the Metropolitan Airports Commission to widen the river
channel and construct a flood protection system consisting of flood walls and a levee.
RE: HOLMAN FIELD LEVEE/FLOODWALL APPEAL (File 06-051296)
HEARING DATE: Apri15, 2006, 5:30 p.m. City Council Chambers
APPEAL FILED BY: Friends of Parks and Trails, Friends of the Mississippi River, Audubon
Society, Dislrict Councils 1, 3 and 4
PLANNING
COMIv1ERCEBL7ILDING - Telephone: 657-266-9090 --
SFourthStreetEas{Suite200 Facsimile: 651-266-9724 ,
StPaul,Minnesota551 01-7 02 4 Web: www.liep.us
DECISION: Approve with conditions (15-4)
ZONING COIVIIVIITTEE RECOMNLCNDATION: No recommendation (tie vote 4-4)
STAFF RECONIM��PiDATION: Approve with conditions
SUPPORT: Approximately 20 letters and a petition
OPPOSITION: Appro�mately 201etters and emails
Dear Ms. Erickson:
A gublic hearing has been scheduled for 415106 to consider an appeal of the Planning Commission's
decision to approve a site plan and a request for variances submitted by the Metropolitan Airports
Commission to widen the river channel and conshvct a flood protection system consisting of flood walls
and a levee.
THE PROJECT
The levee/floodwall is intended to protect the airport during a 100-year flood. It has two components:
Compensatory excavation
MAC wants to excavate material along a 3,200'-long section of the river shoreline neaz the end of runway 32
in order to widen the river channel appro�mately 75'. This is needed to compensate for the impact of the
proposed leveelfloodwall during flood conditions: if this compensatory excavation is done, FEMA, DNR and
the Army Corps of Engineers have determined that the levee/floodwall will not increase the 100-year flood
elevarion above 3ts current level. Most of the fill that is removed would be taken off the site and disposed of
in accordance with permits issued from the MPCA. The shoreline would be replanted with native vegetation
and a limited amount of rip rap would be used to correct e�sting problems with shoreline erosion caused by
bazge operations.
Part of the leveeffloodwall would be located in an area that is currently designated as River Corridor
Floodway (RCl). A levee/floodwall to protect a large area like the airport is not permitted in the Floodway.
So after the compensatory excavation is completed, MAC would apply to FEMA for a Letter of Map Revision
(LMOR) to move the boundary of the floodway closer to the river shorel'me. (FEMA.has already given
preliminary approval for the changing the floodway boundary.) After the Letter of Map Revision is approved,
AA-ADA-EEO Employer
0�-��3
FEMA would no6fy the City of the changes and request adoption of the changes to modify its River Corridor
zoning maps so tLat it is eonsistent with FEMA's maps. If the changes are adopted by the City, the
levee/floodwall would be out of the Floodway (RCl ) and in the Flood Fringe (RC2), allowing MAC to
proceed with conslruction of the levee/floodwall.
Levee/floodwall
The top of the levee and flood walls would be appro�mately 8 to 9 feet higher than the elevaflon of the
airport. It would consist o£three parts:
• Part of the flood protection system would be a permanent sheet pile floodwall. The north secfion of
the floodwaIl would be constructed ne� to Bayfield, the airport road that runs along the river. Tt
would be appro�mately 4250 feet long but it would be lazgely screened by the e�sting trees and
shrubs that haue grown up along the shoreline. There would also be a shorter secfion of sheet pile
wall at the south end. It would be 1,450 feet long but it would be set back from the shoreline.
• An earthen dike between runways 31 and 32 that would extend approximately1000 feet. This secUOn
would be appro�mately 600' back from the river.
• The remainder of the levee would be a temporary wall that would only be erected when a flood was
predicted. It would ea�tend approxnna.tely 2900 feet. At its closets point, at the end of the main
runway, it would be appro�umately 200' from the shore.
THE REVIEW PROCESS
On 12/29/06 the Metropolitan Airports Commission (MAC) applied for Site Plan Review and River
Corridor Variances to widen a portion of the river cliannel and construct a flood-protection system made
of a levee and floodwalls. Variances are needed for staudazds regulating steep slopes and the minimum
setback from the river. -
The Zoning Committee held a public hearing on 1/19/06 and the PIauuing Commission approved the site
plan and variauces on 2/10/06. Approval is subject to the followittg conditions:
• Work on the Compensatory Excauation cannot begin until MAC obfains all othar required approvals
including those from the Army Corps of Engineezs, Minnesota Pollution Control Agency and the ,
Mivuesota Department of Naiural Resources.
• Work on the Levee / Flood Control System cannot be begin until MAC obtains all reqnired approvals
as specified in Section 23 of the Final Environmental Assessment (December 2005). As part of these
approvals, FEMA must issue a Letter of Map Revision for the boundary of the floodway and the City
Council must approve a revision to the River Corridor Zoning Map based on FEMA's actions so that a
portion of the airport where the levee would be built is rezoned from RCl (Floodway) to RC2 (Flood
Frittge).
Tlus appeal is scheduled to be heard by the City Councit on Apri15, 2006. Pleasa call me at 266-9086 if
there aze any questions.
ISSUES RAISED
The main issues that have emerged during the review and appeal aze listed below.
Reviews by other agencies
Approval of the project by the Planning Commission is subjecY to MAC obtaiuing approval from all the
other agencies that need to act on the levee/floodwall. However, objections were raised that the City is
acting prematurely and some people opposed to the project ha�e stated that the City should not take any
acrion until all other agencies have acted on the levee/floodwall.
The status of the reviews by other key agencies is listed below.
Army Corps of Engineers
The Corps is reviewjng the proposed river excavafion, including it impact on flood levels, what
maintenance/dredging would be needed to clean out sediment and revegetating the riverbank disturbed by
the project. The Corps has not made a formal decision yet but its staff has concluded that the project will
meet their requirements with certain conditions. Army Corps staff "believes the proposed excavation wi11
provide the required storage compensation and that frequent maiutenance dredging will not be required.
We aze preparing a permit decision document that will include conditions to require sedimentation
monitoring and submittal of the reports to the Corps, MuDNR and the City of St. Paul. The Corps is also
satisfied that an adequate revegetation plan is being developed.... The application is currenfly within the
�
�
�
�
� ��^�.�� .
adntinisfrative permit process, and regulatory staff anricipates completing the recommen rion ecision
documents within the neat few weeks."
Minnesota Depco-tment of Nacm-a1 Resources
Staff from the DNR wrote that their "questions aud concerns have been mostly addressed and we aze
working on some of the fine points of conditions in the permit to address the few outstanding issues like
the mussel survey and long term maintenance. We agree that the Army Corps of Engineers permit and the
DNR permit shouid have similar condifions, so it will take a little while to get those hammezed out. We
also cannot issue the permit unless it is consistent with all of the City of St. Paul zoning ordinances which
apply to this project. Once the city determines it can issue the appropriate permits, the DNR will be ready
to finaiize our action."
Minnesota Pollution Control Agency
The MPCA is not reviewing the question of whether the levee can be built. However, they will review it
for an NPDES permit that will regulate how the material removed for the Compensatory Exca�afion will
be disposed of.
FEMA n
FEMA has issues a Conditional Letter of Map Revision (CLON� stating that FEMA intends to revise the
boundary of the floodway once the Compensatory Excavation is done. FEMA's floodway boundary _
would be moved toward the river and the proposed leveelfloodway would be out of the floodway. The
City historically has adjusted its River Corridor zoning maps to be consistent with FEMA's maps.
Watershed
The Watershed organization for the azea that includes Holman Field is the I,ower Mississippi River
Watershed Management Organization does not issue permits and has defened to the City.
� EAW
EAW was done in 2002 and a decision was made that an EIS was not required. An EA was just
completed and a FONSI (Finding of No Significant Impact) was made in January 2006.
Conformance with Comprehensive Plan
The Comprehensive Plan acknowledges the importance of both Holman Field and the Mississippi River.
Land Use Chapter of the Comprehensive Plan, Policy 7.6.1 states_ "MSP and Hohnaxi Field aitports are
both very importaut to Saint PauPs economy and quality of life. The CiTy supports maintaining and
improving them in their present locafions with full attention to noise mitigafion."
On the other hand, Strategy 1 o£the Mississippi Kiver Corridor Pian says "The floodplain and shorelines,
wetlands and natural habitats tt�roughout the River Corridor should be protected: '(page 6) and that one of tUe
purposes of the plan is to "protect and preserve the Mississippi Rive Corridor as a unique and valuable
resource....." (page 8).
Kiver Corridor Zoning
It has been pointed out that parts of the proposed leveelfloodwall would be located in the River Comdor
Floodway (RCl) and that the zoning code only allows this in the RCl "where the intent is to protect
individual shuctures." For this reason, approval of the levee/floodwall was made conditional on the City
revising its River Corridor zoning maps after the Compensatory Excavation has been completed and
FEMA has revised its maps so that the levee/floodwall would be entirely in the Flood Fringe (RC2).
Increased air traffic
The appeal states that the levee/floodwall would lead to increased air traffic and noise that unpacts
residential neighborhoods in Dayton's Bluff, Highwood and the West Side.
� MAC stated that the flood protection system is intended to protect their e�sting operations and that they
do not anticipate that it will cause an increase in air traffia Their projections show an increase in air
� traffic, regazdless of whether the flood projecfion system is built.
This has been disputed by a number of people opposed to the project. They contend that the cost/benefit
analysis does not justify the cost of the flood protecfion system based on the eacisting operations and that
the reason for constructing the levee/floodwall is to allow for increased haffc.
Q �� .� 6 �� �
Impact on flood levels ' �
There have been concerns that the flood protection system would cause the flood levels to rise, Based on
the computer model that has been reviewed by FEMA, the DNR and the Army Corps this would not
happen if the Compensatory Excavation is done and routine maintenance and dredging of the channel are
performed.
Visual impact
Concerns have also been raised about visual impact of the wall blocking access to the river. The part of
the flood protecrion system that would have the most impact would be the 4250 feet of sheet piling along
the river. T1us area has many e�sting volunteer trees and underbrush along the shoreline. The Pla.nuing
Commission agreed with staff that this will lude most of the wall from the river. People opposed to the
project state that there are enough gaps in the vegetation that the floodwall will be visible.
Trail access
Concems have been raised that construction of the sheet pile wall along the shoreline would block access
to the river, especially the secfion along Ba�eld Street. At this point, there aze no plans to construct a
trail through Homan Field. MAC and the bazge operators to the south have concerns about a trail along
ffie river and its impact on security. In October 2002 sfaff from MAC, Saint Paul Pazks South SainY Paul
Pazks, the DNR, Metropolitan Council and the Saint Paul River&ont Coxporation looked at the issue of a
irail through and azound the airport. A memo dated 2/13/06 from the River&ont Corporation says that
this group identified a hail route on the west side of the airport that everyone found to be feasible.
Properfy ownership
Questioas have been raised about who owns the shoreline where the Compensatory Excavation and
portions of the floodwall would be located.
People opposed to the project ha�e stated that porlions of the shoreline aze owned by the City of Saint
Paul and therefore MAC does not have standing to make an application for the levee/floodwall. This is
based on properry maps that were created for previous actions involving Holman Field
City staff is conUnuing to review the pzoperiy records as new infoxmation is obtained and will provide an
update on tlae question of property ownership when the City Council meets on April 5.
Sincerely,
��
Tom Beach
L1EP Inspector 3
ATTAC�NTS
Appeal
Pages 1— 206 (See sepazate list of attachments to appeal on page 7)
Resolutions, staff report, minutes Pages 207 - 228
Plans, maps and photos
Tnformation submitted by MAC
Pages 229-236
Pages 23 7 —
�
r�
�
�
�
�
APPlICATION FOR APPEAL
Ofjice of Licens� Inspections and Environmentat Protection
CommerceBuiiding ���i ��� �� ���
8 Foudh St E, Suite 200
SaintPau�MN55I07 �/�� �j ? �003
65I-266-9008
APPLICANT
PROPERTY
LOCATION
�� .l . %i�
p.�7lM� . �'r�/' ' � / il
� ��. ��_/ i� � /
i
,,,
� �i , i. ' � �
� -
�
�► �� � • ' �
' � . �, I / i r i� � Y� �l �
i i
�
s �
. � �A .Y•,h � �,. , .�� � . r � I
i . � - •
�.. -- c c ' i� '� J s1/.
F�"�� ' � , �:�:�% . - ,. ; y l!.Z."'
� TYPE OF APPEAL: Application is hereby made for an appeal to the:
� Board of Zoning Appeals �-Gity Council
6 ��P �S �3
��
��
aI ���
under the provisions of Chapter 61, Section �, Paragraph ____ of the Zoning Code, to appeai a decision
�
• made by the_ Q��e�7!'st(�v� �Lry�-�-_r?-t%�._____
on �� �? � _ _ ��__, 200 � . File number:�'��nS / �____
(date of decision)
GROUNDS FOR APPEAL: Explain why you feel there has been an error in any requirement, permit,
decision or refusal made by an administrative o�cial, or an error in fact, procedure or tinding made by the Board of
Zoning Appeals or the Planning Commission.
G�;k��z�vnx-'�c.
7 ��
� ApPtiqnYs signatwe_�� EJate 3 3 D� Ci[y ager�t _
U
\
�, � ( � �LJ Ea � �y J J c�,�
�?'�_?�3
Grounds for Appeal
o�-���
Appeal of Saint Paul Ptanning Commission resolutions 05-17, 05-18.
�
RE: Variances and modifications that are inconsistent with the F�cecutive Order and
legislation designating tfie Mississippi River Critical Area, Comprehensive Plan for the
Mississippi National River and Recreationa! Area, Saint Paul Comprehensive Plan and
Saint Paui Zoning Code.
Saint Paul Comprehensive Plan calls on us:
To protect and preserve the Mississippi River Corridor as a unique and valuable
resaurce for the benefit of the health, safety and welfare of the citizens of the city, state
and region.
To preserve, enhance and interpret the Mississippi River Corridor's natural, aesthetic,
historic, archeological and ethnographic (cultural) resources.
To resfore and establish the unique urban ecology of Saint Paul's Mississippi River
Corridor. •
Tn reinforce the Mississippi River Corridor as Saint Paul`s front yard and the backbone
of a community-building network extending beyond the shoreline and into the fabric of
surrounding neighborhoods.
To expand opportunities for using the Mississippi River Corridor as a city amenity and �
enhance citizens' quality of life, including increased public access, recreation and
education. •
Saint Paul Comprehensive Plan - Saint Paul is rediscovering and redefining its
relationship with the Mississippi River. Increased environmental stewardship and
establishing connections to the river are central to this rediscovery.
The floodplain and shorelines, wetlands and natural habitat found throughout the River
Corridor should be proteeted and sustained.
Along the riverfront and its ftoodplain, new development should have a relationship to
the river, a need for a river location or the capability to enhance the river environment.
Parks, trails and open space are an important way of allowing people to come to the
river. The Ciiy is working on a number of initiatives, including the realignment of
Shepard Road, to increase park and open space along the river.
Saint Paul Comprehensive Plan - For nearly a century, the Mississippi River's role as
primarity a transportation and industrial corridor led the ciry to think of and treat the river
as its "back yard". The city is now gradually rediscovering and celebrating the river as its
front yard -- a majestic and unparalleled natural amenity that unites neighborhoods and
downtown.
The City Council is requested to uphold the Comprehensive Plan and Zoning Code and�
deny the variances and site plan.
-1- �
,
�
�
�
L J
��- ��-
� l /
PLANNING COMMISSION RESOLUTtON FILE NUMBER: 05-17 VARfANCES
1. Planning Commission Error
The property cannot be put to a reasonable use under the strict provisions of the code.
RESPONSE:
* The floodwall will have no significant impact on the airport's size, use and character.
MAC Chair Vicki Tigwelf letter dated February 8, 2006. (Attachment �
� In 50 years the number of days the airport was closed because of flooding by the 100-
year flood, is 148 days out of 18,250. That is less than 3 days out of every 365 days
in a year.
� The airport has operated since 1926 without a dike.
� The levee/floodwall system to protect the airport from flooding cannot be constructed
under the strict provisions of the zoning code.
` The City Council determined a floodwall is not a reasonable use when they adopted
Sec. 68.214. (h) which establishes the dike as a prohibited use.
2. Planning Commission Error
The plight ofthe Zandowner is due to circumstances unique to this property and these
circumstances were not created By the landowner.
RESPONSE:
* These circumstances were created by the landowner. Saint Paul created the airport
and is the fandowner.
' Flooding in a floodplain is not unique to airports or this property.
" A floodway and ordinary high water levels are common circumstances for property
along the river and not unique to this property.
3. Pia�ning Commission Error
The proposed variance is in keeping with the spirit and intent of the code, and is consistent with
the healtl; safety, comfort, morals and welfare ofthe inhabitants ofthe City ofSt. Paul.
RESPONSE:
` St: Paui Zoning Code prohibits construction of community wide f�ood control
structure in the RC-1 Zoning District.
*St. Paul Zoning Code does not list community wide flood control structures as a
permi�ted use in the RG2 �oning District. �
" Within these districts all uses not allowed as permitted uses or as permitted uses
subject to special conditions shall be and are hereby prohibited.
"Code requires a minimum 50 feet setback. The proposed variance of as little as zero
set back is not in keeping with the spirit and intent of the code. The distance
requirement does not apply only to buildings it applies to structures..
� Airport noise and pollution connected with a near doubling of flights and a projected
increase of based aircraft negatively impacts heaith, safety, comfort and welfare.
° Loss of views and access to the river negatively impact the welfiare of inhabitants of St.
Paul.
4. Planning Commission Error �
The proposed variance will not impair an adequate supply of Zight and air to adjacent property
-2-
�
06����
nor will it alter the essenrial character of the surroundirig area or unreasonably diminish �
established property values. � `
RESPONSE:
` The increased noise and pollution with a near doubling of operations will negative y
impact property values
` Building 9 feet tall and mile long steel wall that eliminates views of and access to the
river alters the essential character of the area.
* Building a mil8 long wall that looms 22 feet above normal water level and has as little
as zero setback from ordinary high water alters the essentiai character of the area.
5. Planning Commission Error
The variance, if grantec� would not permit arry use thc�t is not permitted under the provisions of
the code for the property in the district where the affected land is located, nor would it alter or
charxge the zoning district classification of the propertY•
RESPONSE:
* The stated intent of the variance is to ailow a use (dike) that is a prohibited use.
6. Planning Commission Error
The request for variance is not based primarily on a desire to increase the value of income
poteniial of the parcel of lavu�
RESPONSE:
* The only reason for the request fior the variance is primarily to increase the value of
income potential of the parcel of land —to keep the airport open during periods of high
water.
(a) Planning Commission Error
The burden of proof shall rest with the appdicant to demonstrate conclusively that such variances
will not result in a hazard to dife or properry and wild not adversely affect the safety, use of stabiliry
of a public way> slope or drainage channel, or natural environment; ...
RESPONSE:
* Sec. 68.402 calls for protection of shorelands, flohd hla�atervlevelds and bluffs. It
requires a setback of at least 50 feet from ordinary 9
" USFWS wetland mapping shows weUands in the area of the proposed work.
* MAC has not provided evidence to demonstrate that wetlands are not affected.
* MAC has not provided evidence why they cannot keep the dike off the 12% slopes.
* MAC has not provided any evidence that compensatory excavation will not result in
changing the navigational channel.
* MAC has noi provided any information regarding the effects of the disposition of the
sediment load deposited downstream during natural events such as flooding.
" MAC has not provided any information regarding the protection of habitat of
threatened or endangered species such as the Higgin's Eye Pearly Mussel which the�
DNR is stocking.
-3- �
06-363.
� Yariances shall be consistent with the general purposes of the standards contained in this chapter
and state law and the intent of applicable state and national taws and programs.
RESPONSE:
" There is no precedent in Minnesota for compensatory excavation on the Mississippi
River. If approved it would estabfish the precedent that developers could alter the sivar
to allow development of the floodway. This is in stark contrast to river corridor
regulations that call for development to be setback from the river and away from the
slopes.
"Critical Area regulations and MNRRA Tier 2 requirements call for protecting, restoring
and providing public access to the shoreline of the river.
*The Department of Interior letter dated August 4, 2005 states that constructing a dike
system along 9,�55 fieet of the Mississippi River is inconsistent with many MIVRRA CMP
goals and policies. These include preseroing riverbanks in their natural state, restoring
denuded shorelines with vegetation, increasing and restoring wildlife habitat, and
preserving views of and from the river.
7. Planning Commission Error
Be it resolved, by the SaintPaul Planning Commission that the provisions of Sections 68.402 artd
68. 601 are hereby waved to allow Compensatory Excavation and a Flood protection on property
located at 644 Bayfield St
� RESRONSE:
" Misrepresentation of Material Fact. Title Opinion and maps showing the proposed
Compensatory Excavation is not located on airport property. (Attachment )
" MAC is not the owner or leaseholder on the land.
` The variance approved by the P{anning Commission does not inciude the area of the
proposed Compensatory Excavation.
' Sec. 61.301 states explicitly that any person having own�rship or leasehold interest in
the subject land and or/building (co�tingent included) is eligible to file an application with
the planning commission for site pian review and variances.
PLANIVING COMMISSION RESOLUTION F1LE NUMBER OS-18
Planning Commission Error
1. The site plan is consistent with the city's adnpted compreherrsive plan
RESPONSE: Site Plan is inconsistent with comprehensive plan.
" Minimum setback at least 50 feet from ordinary high water
* Threatened and endangered species wildlife habitats shall be protected from
alterations which would endanger their survival. Threatened and endangered mussel
species live in this stretch of the river and are currently being stocked and reintroduced.
Compensatory Excavation and maintenance dredging would be an alteration of habitat.
� * No commercial or industriai development on slopes greater than 12%
' The Mississippi River Corridor is a State Critical Area requiring special protection
' USFWS maps show wetlands located where work is proposed. (Attachment )
* A 9 foot tall mile long steel wall is not compatible with the preservation of �
�
Q � s -� ,- �
e ���..� �
environmenfaliy sensitive areas
' The survey of plants and wiidlife was done in December so a good evaluation of
potential impacts has not been provided
Planning Commission Error
2. The site p[an is consistent with protedion of neighboring proper[ies
RESPONSE: Site Plan is inconsistent with protection of neighboring properties
" Airport noise is projected to nearly double operations negatively impacting surrounding
properties.
Planning Commission Error
3. The site plan will have no impact on vehicular traffic
RESPONSE: Site Plan is incansistent with no impact on vehicular traffic
* A near doubling of operations will have an impact on vehicular traffic and as a result
will affe�t the neighborhood.
Planning Commission Error
4. The satisfac[ory availability and capacity ofstorm and sanitary sewers, including solutions to
any drainage ptoblems in the drea of the development is being met.
RESPONSE: Site Plan is inconsistent with drainage problems.
' MAC is currently constructing the sub-drain project �
* MAC does not have the required MPCA permits
' MAC has not done the necesary soil and water testing for potential pollution
The Zoning Code must be revised first before consideration of a proposal such
as what MAC is requesting.
Zoning Code and the Planning Commission resolutions do not allow construction of the
dike unless the Ciry Council supports a change to the Zoning Code. If the majority of the
City Council does not support construction of the dike a veto would only mean that the
river would be excavated with the negative impac:ts of that action. MAC would
needlessly spend millions of taxpayer dollars on a project they could not complete. It
would be an extremely irresponsible course of action that would serve no purpose.
FEMA answers to the February 18,2006 letter that is attached. (Attachment ). Floodplain
management regulations adopted by a community that are more restrictive are
encouraged. More restrictive state and or community regulations are encouraged as
long as they meet the minimum requirements established by the NFIP. The GLOMR and
LOMR are based on minimum floodplain management criteria established under the
NFIP. Community adopted more restrictive or comprehensive floodplain management
criteria take precedent over the minimum criteria. Eithe� state or local regulations that
are more stringent than the minimum NFIP criteria prevail.
Economic Impact �
; The MAC claims there will be no significant impact on the airport's use if the dike is �
�built or not.
* The EA shows a cost benefit of i.21. When the real cost and actual number of tloods
-5-
;�
�
�
�
O.b-363
are used it fias less than a 50-cent return on the do{lar. A poor use of taxpayer's money.
� The dike does not guality for Federal funding if actual costs and floods are used.
* The Regionai Office of the FAA is looking into concerns raised about the Cost Benefit
Analysis. The FAA is still working on a response to those concerns. (Attachment )
* The MAC is still working on a response to concerns raised about the Cost Benefit
Analysis and EA. (Attachment )
' Business regularly claims taxes are a top concern. Wasting tax do{lars on pork barrel
projects is contrary to that concern.
' Minneapolis does not have a Downtown Airport and does better than Saint Paul at
fitling office space.
` Chicago recently turned their powntown Airport into Open Space and a tourism
attraction and Chicago is thriving.
' Anoka and F{ying C{oud were originally Tier 1 reliever airports established to handle
business jets. Their neighboring communities went to the Legislature and got the Anoka
and Flying cioud airports removed from the Tier 1 status.
" Medtronics has built and continues to expand their world headquarters near Anoka
not near the St. Paul Downtown Airport.
` Development is booming in the Western suburbs in spite of their apparent economic
disadvantage not having the Downtown Airport.
` Efforts to preserve and restore natural and aesthetic qualities and increase
recreational opportunities along the Mississippi River are some of Saint Paul's most
important economic development tools.
' Building a floodwall transfers the financial burden of flood control from the private
sector to the pubfic sector.
Attachments:
WSCO letter
District 1 letter
District 4 letter
Saint Paul Audubon tetter
Friends of the Mississippi River letter
Friends of the Parks and Trails of St. Paul and Ramsey County letter
Representative Sheldon Johnson and Council president Kathy Lantry letter
United States Department of Interior letter
Dorsey and Whitney letter
Tom Dimond letters
FEMA Region V responses
Draft Cost Benefit Analysis
Final Cost Benefit Analysis
�
�
o�����
�
FAA Region response to CBA
MAC response to CBA
Request,for withdrawal of application
Title Opinion
Airport property line maps
Ramsey County property information and maps
United States EPA letter
MPCA notice
USFWS NWI Wetlands Map
Presidential Wetland Initiative
USFWS Wetlands DefinitiQn
National Wetlands Inventory fact sheet
FEMA Wetland Regulations
Conscious Choice article
MAC Chair Vicki Tigwell letter
John Grzybek letter
-7-
�
♦
,
��
:� ;:
:=
- - _ s
;
. _
��� � ��� �-�.�y z
;.. � , t _
�. ��; ;
� - ;
�
s
i Y YL _
�� 4 i : x >� '`... � . '
"' � 3 I,. �.� 9`\' Vev s3f � a � _
.. n a 1 2 f ; � � ��� ' v
_� v .�' "i $�Y -"' '�`�h a �'. ��� /"�- �
: � w.—.. � ! � .. � .
' . , �_' " ,r•so-°.,.:. ,-�'
. .i'�. �._ ` '` ,: -...\•'.��"' , r. .-
.�
�' _ �
=�, S '
_-_ . . ' ., a.�i .,... . ,
h
_ � � d!. tN�
. .. ..v �.. . ..-.. � �_ .� . .�. F�. ...� . .....
, �
V1/ES1 S(�E CITI�ENS O�GANIIATION
0 �-3b3
��
927 West Winifred St.
St. Paul, MN F 107
Phone:(659)2�8
Fax:(651)293- 5
www.wsco.org
7his resotution is in opposition to a proposecf dike around Holman Field Airport
The Environment Committes of the West Side Citizen's Organization is opposed fo fhe
construction of an airport dike.
A 9 foot steel wai( surrounding _many parts of the airport w+ll permanently block visual
and physical access to the Great River Flood Ptain maki�g the neighborhood LESS
natural and LESS connected.
WSCO supports City Council Presidenf Lantry and the National Park Service in their
stated positions to the Metropolitan Airports Comrriission against the dike.
The construction of a dike sysfem afong 9,355 feet of the Mississippi River is
inconsistent with MNRRA goais inciuding preserving river banks in their natural.state,
restoring shorelines, increasing and restoring wildlife habitaf, and preserving views of
and to the river. •
The Mississippi River Corridor Plan caiis for protecting and enhancing the natural and
scenic values of fhe river. It also calls for protecting and enhancing access to the river
and views to and from the river. The proposed dike at HoJman Field is not in keeping
with these efforts.
Sec. 68.211 of the Saint Paul Zoning Code does not include a dike as a permitted use.
Sec. 68.214(h) states that community-wide. structural work� for flood control intended to
remove areas from the regulatoryfloodpiain shal[ not be ailowed in the floodway.
WSCO does nat support the proposed rezoning and variances for slopes and 'setbacks
that would be required to build the airport dike.
President of West Side Citizens Organization
District 3
�
l��
I
� Page 1 of 1
�
Tom Beach - Re: Holman l�eld
Q�-3�3
�Yom: <disfricticouncil@aol.com> �
To: <Tom.Beach@ci.s[paul.mn.us>
Date: 2/6/2006 5:12 PM
Subject: Re:HolmanFieid
CC: <kathylantry@cistpaut.mn.us>,
Tom:
<ellen.biales@ci.stpaul.mn.us>
The District One Community Council, at its meeting held 7anuary 23rd, passed the foliowing
resolution opposing the construction of a dike at Holman Fie{d. The resolution reads:
Whereas, the District Council supports the efforts of the Nationat Park�.Sesvice and their position
stated in their August 4, 2005 letter to the Metropolitan Airports Commission that constructing a
dike system along 9,355 feet of the Mississippi River is inconsistent with many general MNRRA CMP
goals and po4icies, including preserving river banks in their naturat state, restoring denuded
shorelines with native vegetation, increasing and restoring wildlife habitat, and preserving views of
and to the river, and,
Whereas, the District Councii supporks the position of City Council President Kattiy Lantry stated in
� her letter to.the MAC dated August 4, 2005 that the Mississippi River Corridor Plan calls for
protecting and enhancing the naturai and scenic views to and from the river, and,
Whereas, the proposed Perimeter Dike at Holman Fietd is not in keeping with these efforts: Sec.
68.211 of the St, Paul Zoning Code does not inciude a dike as a permitted use and Sec. 68.214(h)
states that community-wide structura4 works for flood control intended to remove areas from the
regulatory P400dplain shall not be alSowed in the floodway.
�
Therefore, be it resolved, that the District One Community Councif does not support the proposed
rezoning and variances for stopes and setbacks requested by the Metropolitan Airports Commission
to build the airport dike. '
f11E:��(;]��OCllmP.T7YS ATit3 .t'P.ttinos�Rr�arhtnm\T nral .QeftinrcclTamr�\(:�xT1AMM i7TT�f
l\
�/ninnnt
From: "Karin DuPaui° <Karin@DaytonsB(uff.org>
To: "Tom Beach" <tom.beach@ci.stpaul.mn.us>
Date: 1/19/2006 1:52:40 PM
Subject: Dayton'sBluff-AirportDike
Hi Tom
Sorry I can not attend the meeting this afternoon.
Our board passed reso}utions opposing the constrUCtion of the Airport Dike
in 2003, again 2005, and still supporfs tfiat position.
The proposed dike is iocafed in the State designated Mississippi �Liver
Cri6cal Area. The Mississippi River Corridor Plan calls for protecting and
enhancing access to the river and views to and from the rfver. The proposed
dike is �ot consistent with Saint Paul's River Corridor Plan.
The Dayton's Biuff Community Council has concems specificaliy relating to
the
dike:
t. ,
OurOngoing Need to Protecf our Environment—ArgumenYs are being made by
the
proponeflts o4 the dike that it wiii have little or no impact an the river
during times of flooding, however, an ecival numtrer of argumenfs are atso
made by
environmentalists concerned for areas to be impacted upstream as well as
downstream.
� Livability and the Noise impact issue — St. Paul Downtown Airport
recommends
that pilots use their noise abatement tra�c patterns to lessen impact fo
the
residential biuff area adjacent to the northeast boundary of the airport
(Dayton's Bluff and Mounds Park}. Dai(y we observe aircraft on take-of€ and
landing faking shortcufs off the recommended roufes and passiag directing
over
homes and churches. Much of Dayton's Bluff is a desig�ated Historic Disfrict
and the home� proudiy re$ect architecture"dafing back fo the 9800s.
Historic '
Preservation Commission guidelines requjre that these homes maintain fheir
arcfii�ectural infegrity, whfch prec(udes sugges6ng noise soundproofing
programs. It is not unus�al for residents to experience on a daily basis
rattling windows and dishes and inability to carry on conversations because
of
the !ow flyovers. .
Funding the Dike —A large portion of the funding for tfiis dike wili
be provided from faxpayers' dollars even fhough the airport is not used or
owned by many faxpayers, Users include 3M and other private corporate air
fleets.
We are concemed that the amount of traffic usi�g this airport witi be
increasing in the coming years. The Metropolitan Airports Commission (MRC)
says it expects tittle inerease, however, the current situation is already a
problem being voiced by cifizens over past five years to MAC. Dayton's
Bluif
citizens have strong ties to the area. We are commitEed to mainfaining and
�
�
��
�
� supporting resources in the metro area, rather than moving elsewhere to
escape
the above-mentioned issues. We urge you to join us in questioning the need
for
the St: Pau1 powntown Airport dike. For more information, ca0 us at (651)
772-2075.
Thanks,
Karin DuPaul
Community Organizet
Dayton's Bluff District 4 Communiiy Council
798 East Seventh Street
Saint Paui, MN 55106
(651)772-2075
(651) 774-3510 (fax)
"St. Paui looks.up to Dayton's BiufP'
�
�
f Afton •-'/�ppfe'(�alCey • ,'4>G'en7fiCls • Bayport ! , Cirde �Pines • � �oteage C' • rUeCCwoorl' ! �Eagan • �Fafcon {fezgkts� .
�� � " _ ������� �
� � Saint-�1'c�u�Audu6on Society . �
. �
' � �� � , �East Metro 12,egion . ;
v ' _� _ . February 9, 2006� �
� � - P4 6ox 7275, Saint Paul, Minnesota 55101J275 . . _ � �.
' • . ' - . , "� _ 65Y-292-2596 _. . _ . _ - . - . ' �
� - www.saiatpaulaudabon.com . - . � � ,
� " The Honorable �hr'is Coleu�an' • . , � ' : � �
,. � Mayor, City of Si Paul '. , ,
w 390CityHatt ' ' • ,. , .,
' �_ 25 W�st Kellogg Blvd., ' - �
, Sainf Paul, MN 55102 � _
, ,' �
`� _ � . � ': �
_� • " . �
� � Dear Mayor Colemann � � . - �,
�' , . , .. �
d •. The Board ofDirectoES of the St Paul Audabon Socieiy urges yon to'pm�cf die,ttird, fish and •
� `''� ':, ,wildtife resources of the beautifut Mississippi Rives in St Pau1 bY. �PIp�g �3' Permits' or fimds h ,
• , for au e�qiarided perimetez d7ce around Ho1�anField in St PauL �+�
b -- . ' �•� _
� ! In yeazs of high watei tlie airport floods for areason= the river needs this area Yo: store and move o
� 'the large amoaints 4f water that come dowa the Mississippi and 1vl�uesota rivers ia tiines of .' •
� - ,fioods. : . , . ' � • . �
a - ' - " .
The St Paul Audnbon Society is conbenied t�at raising tfie perimetei dike to proteEt fhe airport �' .
during times of•floodiug will raise watec leyels on.the other side ofthe main chanriel, along the � `�
V ' isiand's that st�pdrt habitat for aa ezctensive Ctteat �1ne Heron and Cneat Egcet fookery as well as '�'
� � habitat for other floodplam fozest bird species. The Mississigpi Rrver throughout St Paul is a- �.,.
�' Nafianal Anduboa Society internatioaally designated Import�t Bird Area. It piovides critical' , o
� i- habitat for over 300 bffd speczes that are enjoyed by our_ cirizens �d vis�itois fo o�,commnnity. � '
. -. • - . , . . .
d Raising tbe dike will fjuthe� conslrict the river;,even with the e�ccavation that is proposed in 9�e •
� Corps of Engineers plap (Public Nofice 2005-7386 TJF issued December 23, 2005). We shoutd �
�- �� �� ieazn to live with the river aud gro-vide faa� t�is flood storage area when theriver hirds, fish, '�
`' �� wildlife, mzd the pe,ople who tive along the river, need it • � ' �
. � , .� � , , .. '� , o
. � - - _ - , . . y � .
• � .' Thank you foryouraonsideration of our comments, ' , � • .
. - � ' . , � a
� � , . SJmcerelY . , � ' . , � :
� �� . .
� ' �
' � `' Ciaig.Andresen, Eresident , A
� - St Paut Audabon Society , ^��
�_ - . . . . , �
� cc: Gene Merri�n, Commissioner, Minnesofa Depadment of I�at�aal Resomces `
. St Paul City Council Members � �
AttacLment: ,
�. Signatare'Sheets: S[ Paut Andubdn Society members who ate residenfs of the hity of St PauL \� �
�. � , . �
� . � '�
�'IP`taso� . al°p�vp i xrzva tutfls yyto�,r . r�jvp y7.roN, •. 7iodma�,l . �cozy8u� mal� � mac/Z'�un°ryY '. naodflzuutyy,
; �
l
�
i
�
�
�
.i
5
St. h'aul Audubon Soc�ety Members/St. Yaul ttesidents Attachment
G, �
� �e a � V �
We oppose the construct+on af a Mississ"sppi f2iver dike arou�d Holman Field
Airport as proposed by the Metropolitan Airports Commission (Refierence #2005-
7386-TJF).
The risk of constructing this dike is that future floods w+ll creafe a disrupfion of fhe
water fevets on the other side of fhe main river channei. This. area along the ,
isiands is habitat for an exfensive Great 8fue Heron and Great Egret rookery as
well as floodp(ain forest habitat for over 300 bird species.
Name — Si n Name - Print Street Address & Zi
���% /hA-RGa-,e`/ ifUAGAf,,.] ZI�! Yiy.w�w�.� t.�
��
1'�J'i�' � �
a �� �,
�o �tc,h �/1 YSD�
�Jff U ' C!`� f Y�/
7ti""�'�, 1 ���1 ��ht �r++
�(JQ�JIL� � YY���
9 � r� �� A�1�
� .(7rh,o,r,� � �t'uca.�.efe��n
�
L'
lLtc �t,c,�
�
�Y
u, � �..--.,.- - s. _
��.,...,��..� , l�k,�- �s/ �.
7a� �l/�v�.MNsSi
704 t-I-�ll R-ve� 3,��.
atbs a�ac� Av<
zlba agd<
5�- Pcal,.[. l�
2�S�aZ �C�Pt fcr
fn�c.
�� 9
�� Il9
����
V
SS//a
\�
Fehruarv 9. 2��6
�
5t. Naut Auclunon Soaety Membecsl5c. t�auC Kes�tlenE�a �,� � f', �, Attachment
� ��
We oppose the constructian af a Mississippi River dike around Ho(man Field �
� Airport as proposed by the Metropolitan Airports Commission (Fteference #2005-
- 7386-TJF).
�
�
�� .
Fe6ruanr 9_ 2�Q6
The risk of consfructing fhis dike is that future flaods will create a d'+sruption of the
water levels on the ofiher side of fhe main river channeL T�his area along the
is[ands is habitat for an extensive Great Blue Heron and Great Egret rookery as
we!! as floodp(ain forest tiab+tat for over 30Q bird species.
�
. 05-��3
Friends of the �Vlississippi Ri.ver.
46 Easc Fourth Screec, SuiLe 606 � Saint Paul, MN 5>101 • 65U222-2I93 • fax 651l222-60�
Working io protect tbeMississijipi River aizd its watershed in t&e Twin Cities area
�
Februaiy 9, 2006
St. Paul.Planning ComrilissY'on
1400 Ciry Hall Annex "
25 Faurth Street W
Saint Paul, MN 55102
Deaz Planning Commissiori Meinber:
T am writing to offer Friends of fhe Mississippi River's perspective on the proposed Holinan
Field perimeter di�Ce and to urge you to oppose the_project, �
�
�
Friends of ihe Ivlississippi River is a local non-profif orgapization that works to protect and
enhance the Mississippi River and its watershed in the Twin Cities metropolitan area. We
are a citizen-liased organizarion with over 1 active members, more than 200 of wham
live in Saint Paul. FIvIIt works to preserve and restore the river's fish and wildlife, its
floodplains arid bluffs, and its unique scezuc, natural, recreafionai and cultural asset§.
We are very concerned that the Holman dike would, if built, very significantly degrade the
ecological, recreationat and scenic vaiues of the. Mississippi Rive.r in Saint•Paul.
- ----------- -----____. .._ ---- --��_� __.. _-- - _..,_..�__ _.�_.,�..,__ , .
Construction of a perirneter dike azound Holman Field would permanenfly remove 516.2
acres (eight tenths of a square mile) from,fhe Mississippi River floodplain. This huge former
wetland_at the big bend in the river woutd rio longer be able to perform.its hisforical function
of flood storage. In addition, massive excavation of fhe river bed could sei�iously�damage in-
stream habitat including; potenCially, native mussel beds: Chan�es in the width, depth and
contovrs of �he channel will also.increase flow eeTocity especially on the opposite, outside
bank and a major redistribution of scouring_ and sediment deposftion• is very tikely to occur.
dnce land is behind" a dike it is extremely di�cult (both politically and economically), if not
impossible, to rehun"it to fIoodpiain. In fhe event that in tfie futz[re,an airport was rio lo�ger
technically or economically viable imthis location.this land would come under intense
deveYopment pressure for commerciaT, industrial or residential use. BuiTding new structures
in the.�dississippi River fToodplain is very poor policy, sets a bad precedent for future
development proposals and is, for practical purposes, ureversible:
Scenic values and visual character "
The perimeter dike would permanently alter approximately 9,800 feet {l.8 miles} af `_
riverbank by installing eaxttien berm and sheet pile �va11 to heights up to eight feet above �P
Prznted an I00% reeyeled paper with say-'vased ink
�. }4
",'�... .,-.'. . ': � . .. .. �_ . . ' - _ . ,
' :^::__'._.,,:... r .� _'.,''_ { � , ��r y y . ' _ - - "
' . . . . ' � ' - - ` � .. . - , 7/��V: ''��.� V' J... � -
gro�nd 1e�eI �'zom the river fhe heigt�t af the proposed wall_wiii varg ac:c,oxc�ng to. tfie wateF- �. �.
lev�l. From the= 0rdi�ary I�igh. Water 11%Ia.rk to �tke Eop -of th�tvail wi�I �e 19 feet Duri�lg
lokv water (typiEally dunng the latter ha3f of the sutnnier a�d �tie fall} the hetght o#'.the wa11 �
above fiie wafer.co`aid�XCeed 2_i. �eet 'Fhe resuliwauid be tct very significanfly:degrade the->- '-
v�sualaud seenic=character of the iive� iu tkus �o�atirin_ 5�eeifiea�l� unpaated wo�td be tCSers :
_. oflndia� IvFotuids Par15 iase�`s �f.the Sani NFargan Tra�Y oa�e oppasite b�nk recr�atio�al" -
boater's aa�d toi?i� boa�.passangers: As a�reque3��padclter 6n Tfus. reach�ofthe �IississippfI Ca�
a e,st .o � e s ng zu�gresston at e eot�. �#�on o: a. s,o� �e ma�ces ugan the s��ise's ;o� a-.. .
licsa�er at fh� wafer level: � 2(�foot sheetg�le-�oad�yakl zs per,haps the miist unposiug; '
_ unt�elcomin� aEtd Yeastseenic feaiu�e t1�aE ts�e cau e�pe��nce an the r�v�r The piogosed'dif�e�.'
, wo�Y1d �ave ainass�ve-negati�e im}racf a� the visi�al�•bharaEter o�t�ie nver;ui Sauit �'��i: �"
�fiuimalbenef � to- the citizens crf S�t pattk
� vvbuld th�nk=fhai a proj�at �itl%sezeh ct�tiimeu�al af£ecfs'tb'ttie Mississ�gp"r I�i�rer-�?r Sai��
:� P�txl wai3Lct'pur�iartto coufe�su�ZSfaizYial�eccsno�nie bene�iCs an�the oEf�ns o€Sa�int.Pa�Y1 :
;. _.. . —.,:._ _ . . . • ..
.. ". . .: ;:_ • . � - 7 S�i?isriigIy Yliis:is not:tlie �e.�n:faat,_-tfie:projecf'_.�propbsers: tlie_groject:ean_not: .. .; .".., . ,
- sha� a:gosi&ve: �est co benefif ratio. Aecorilfag tb�ll!�elrogolrt.aii Ar�pozts Cc�mi�u§sxoa
: ,s. `.- ..� . .:-.... . "
� -: - .. : -- :,...�..
p . �. ., . . �.. _.
: _ . ... _. (�Cj �r.e p�n?aiy, tienefifis of ro�idis flood;ccin�ioL`at.I-�o�nan �'ie�d are tkiat th� a � oif :: ' :,: . : _ :- .:
. . wi1� 1i� b�ttet "a�Tz Yo - -
� _. ._ : •.•.. . °_. _::. '.._ �.._
.:
, .--•` . . ,
.
�° re�iatil. se�u :. , .:... �_ . ., g . . Po .
,. '.: . , � , . ,: _" Y. : "e tfie roie it�asTieen assi ued iii 'tI�etiYt'ri`cifiies;air;ttans -rfatib�t'. :.•_.:':.� < -
need� .. ' ; ; ':. `
proviiie.ca�3��stent at�ct, ctepe�dable sezvtce tt� �� comnxu�tiby's:busmess inierests-
avctid forcmg ifs teaant�.'Co fund costlx reloeafre5ns fo:t�ie IvZrnneapo�t's;St Paul Irifernatwaal �_
_., . . � .
Ai�3orf and.¢tlies rglie�er a�iport"s." � _ .• .; . .�: . . -
' _ �__ .
_ _''_'�'���.='.�'� -
th �.res €rnse fa eonik�eri�s f0 f�ie E�'t3�.fioii►.I?IoitliweSt �1ii�aes�tti� MA : �o� = < :� `:� -
_-� . . ...:.
. .:,... _
..... >.. . .. ,`.
: . .. :.: � ... :
,.. ... :: ., , ._, .: ...:,.�. ...:: .. . ........ .. .... : . .. G _.._ ..: �.
, , `� , xeasoa,for t3ie propt>sed=dike; is.nof baSed�:oia �coiiaz�c-n,ee� on apositi�e �elicfit-eosT :: `. ,:: .. < .::;. �` ±
ratiti: £t rs h�sed= o� mtir.��iu�c�g fihe use af 1YfSl�: by generat�avi�Cion airEra$ by k�eping� �he ,.
_ " �_ .:aiiporE�enYdunngup-#o '-•: :` : '= - -
• . ..... . .. . . : .. ,.. .. _ . .
. ;- .. Based: u an fhe . . `�°� a -' - - -
_ _... . _
_ -.. -. , .. . .. . . . . . �,.. . �
: -: - :,,..;- •: .....::..: . . : .... . ......... ...: .
:.
. :: .. ...:: ... p. ... MA. s vv�?'f[g�ties;:spice;:T�2�i.�oIin�ii�ielc�tiasbe�s�'�tctseii:atriYat�irf210'... : - ;-`.
- , days due to fIu6chng_ No one ts argii�ng that �alu��i�Fieid does�tt't crea�e a sbgn�c�nt -
� . . . .. -
•" - ' : . ; - : e6oricj�rie:Ge�zeft;ta t�e z� ioaat ec�no�i tiut the_ ;res ect ris ;osersha�ie�fail� t-0= �eseiit� �.'. .'_:;:.:.'...''
� 5'" F 7_ 3� P . �
"�c4nvi�iug ��i�Yeuce fhat fhe a�argiiia� 2r3djfionaI dependaT�ifity o�a fl4oci: protected aiipot� .
� ; iv�1�:c�eTiver t�eas�Xalile ecoz�omio bene�ts.taYkeett�zens ofSa%x�t Ra.�T; -
= � �; `Thaii�e .:ati fii� - .6uz:.carefEit'eonsidera�ori of our t�ews on.= 's riiatit�r:.�lease fe€�° free fo : : :' '- = � '
=- '=<--::
_ , ;. :
.. . ::
, ,..
�` : ,,. �_. .:. _. . �. , :..... . . • ... . . . .:: : .. .. _.. :"
:-.::.. :. .:: � ; _.
-' ' : ° : :: �qlifaqt.�ne �vitFf an . , , _ . -
: . .:. . ,. _ . , . 3' quesfions.that.ycni risay ka�e ctr.if yoii.�v�i�Id;k�e tfi.discuss 4he'�ssuz in ; ,., .._ ; _
` more depth:..• � - _
,. _ ., . - : .
-:.. _ .. . � ..: - -
::
.: ....: . : . .. . : _ _ -
, _ _, :.. :�;. :_.. _
-.:, ;
� ;..;°::
- '� : . ' ": ; `: :.
- _ .: •:: :,�:'$inee�=e1�;:`-: .
,- _ � - � .- - ' _
< , ::.: -
— E,i Glark .: : - - � _ - _
.. ,,....
:
- - ecutiv2 Biree o � . - � `
f. z
_ _ - ..�
- - - �:.
}
0 b-3�,�
' Augast 4, 2005
Bridget Rief
Metropolitan Airports Commission
6040 — 28�' Avenue South
Miimeapolis, MN 55450
?�'H n�rv�zsARY Dear Ms. Rief:
1985-2W5
i6z� a��nw�a nve. 'I'hauk you for ttie opportunity to review and comment on the Draft Environmental
St PaW, MN 55116
651-648d5q3 Assessment on the Perimeter Dike and Itunway Safety Area Improvements Project for the
Fax - 651-698-8161 St. Paul Downtown Airport. Tke Friends �f the Parks and Trails have comments and
www.fiendsoftheparks.org .
questions below:
���a�n�
Andrea Vento 1. On a e 6, the Gulfstream V aircraft are referred to as"airport's critical
Vice President P g
� Michazl Prichard aireraft." What daes "critical" mean and does it haue some special meaning for
Jeanne Weigum -
Treasurer FAA purposes. Apparently there are only seven GV aircraft at the St. Pau1
Sames R. Bricher
Directors DOWIlfOWll f�1TpOT'C.
Duke Addicks
Chaz Brooker
Jeffrey Croonquist 2. The floodwall will reduce the length of the runway to 5,509, a reduction of
Mazk Davis
Trudy Dunham 1,000 ft., which will not permit full use of the airport. Which airplanes (and how
Thorstas T. Dwight
Noil Fmney many) currently at the St Paui Downtown Airport need a runway between S,Q00
- ..Williarn Frank ' �d 5 ,509? .
- Stevc Hauser
Marityn Lundbefg
RobeR Ne[hercut
M� M. xo�� 3. On page 11, 9�' line: What is meant by the clause "...fi�ial levee elevation
s�on �,
Piem Regnier would be optimized during final design."
Marsha Soucheny � . - � . .
C}�nehia Wheeler .
Director Erturims 4. While there is no mention of the cost o£the project, it has been stated in the
T Portcr newspaper that the cost would be around $30 million. There is no discussion of
�°ff`;° the cost/benefits of this ro ect.
Bab Bierscheid p ] � .
Dan Collins .
Marc Goess .
Greg Mack 5. While there have been only seven major floods in the past S 0 yeazs on the
Tercy Noonan .
Bob Sandquist Mississippi River, we question whether the benefits outweigh the costs of the
Execunve Dircctor �
and Secretary project. s
Peagy Lynch .
6. On page 27 it states, "MAC is willing to discuss trail connection options." We
believe there should be a firm commitment from MAC to allow trail connecfions.
The trail connection shonld be identified in the EA.
7. On page 30, in the third paragraph it mentions, "MAC would make reasonable
efforts to accommodate the visual impact..." A more specific proposal should be
made.
� �
l
06����
8. On page 43. The last sentence says, "MAC is rvilling to discuss screening �
options. A specific comcnitment should be included. As written It is meaningless.
9. Neither Figure 6 A or figure 6 B show the visual impacts from downstream.
An addirional photograph or photographs should be added.
10. There will be dredging to excavate along the west bank of the Mississippi
River. There was no mention as to whether continual dredging will have to be
dane or who would pay for that dredging.
11. There is no menfion of where the dredge spoIls will be deposited from the
excavarion and graciing and whether tkey are contaminated.
12. In Chapter 68. Zoning Code River Corridor Overlay Distriets it states under
Sec. 68.211 Permitted Uses — floodwalls aze not &sted as a peratitted use. In
68.213. Floodwalls are not permitted as a condifional use. Tn 68.214.
Standards for conditional uses in the RCl Floodway District, (h)
..."Community-wide structural works for flood control intended to
remove areas from the regulatory floodplain shall not be allowed in the
floodway."
13: What will be the financial impacts to MAC attd tlie Airports wifh Northwest �
Airlines continuing financial losses and potential Chapter 11 bankruptcy?
The Friends believe that an Environmental Impact Statement would require alternaxives to
fhis project, cosf/beuefit analysis and an EFS should be required
Sincerely,
Uv. +�lZtLc. ��
Andrea Vento C��'J
President
�
1�
�
�r
� Sheldon Jofinson
State flepresentative
a�st��� s�e
Ramsey Gounty
August 4, 2005
�
Bridget Rief
Mel�opoliYan tlirports Commission
6040 28�' Ave S
Minneapolis, MN 55450
612-725-8371
Fax-612-794-4407
Re: Draft Environmental Assessment
Received
�� �;t;��
Minnesota
House of
Representatives
a
AUG 0 5 2a05
Airport Developrnenf
The proposed dike is located in the state desig�ated Mississippi River Critical Area and
the Mississippi National River and Recrea6onal tlrea. The Mississippi River Corridor
Plan calls for protecting and enhancing the natural and scenic vatues of the river. The
plan also calls for protecting and enhancing access to the river and views to and &om the
river. The proposed Perimater Dike at Holman Field is not in keeping with t}iese efforts.
The issue of the ��ie��shed is e5pecialiy relevant given the amount of work and money
#hat has gone into esiablishing the Bruce Ven#o Nature Sanctuary and tha Sam Morgan
Trail (directly across from the proposed sheet pile dike), as well as the view from
Mounds Park. ,
intent is to protect an individual
Sineerely,
�����'�-��--,
Sheldon Johnson
Sfiate Representative
� � . .
� 2301 Howard St 5., St. Paui Minnesota 55119
229 State INfice 6uilding, 100 Constilution Ave.: St. Paul. Minnesoia 551
� o! EmaiLrepsheldon.johnson�house.leg.state.mn.us
r .
as a
'��'.
,�r�f��d.u��.
use dikes ivhere the 7
� -��` z£�1k�7�•. �r r JJ.
�
,.e,'�'��� �fi��cr� , ,
���-�
Kathy Lantry
CityEouncil President
City of St. Paul
��
�oo p cyo-+<v,
Fax (651) 2g6�4765
�
F. �, :
� ���
_ ���i�,
.� _ a � = ' `
�' +
� �
�'
]N REPLY RFFE$ 70:
L8024(MISS}2/B
August 4, 2005 -
United Stafes Depart�ment of the Interior
NAT[ONAL PARK SERVICE
Mississippi Nationai River and Recreation Area
111 E. Kellogg Blvd., 3te. lOS '
St. Paut, Minnesota 55161-1256
Bridget Rief
Meiropolitan Aizports Commission
6U40 Z$'� Avenue.Soudi
Rdinneapolis, MN 55450
Deaz Ms. Rief:
Receive�
AU� 0 5 20fl5
Airpo� Devetopment
Our office has reviewed the Draft Envuonmental Assessment (EA} fQr the proposed Perimeter _
D'ike and Runway Safety Are� Improvements Project at the St. PauI Downtdwn Auport (Holivazi
Field). Holman Field is located entirely within the Ivfississippi�NaYional River and Recreation
Area (MNRR?.), a unif o£the National Puk System. The MNi2RA was established by Congress
in 1988 to prutect and enhance ihe nationaliy significacit hisforicat, recreational, sceniq cultural,
nafural, econoiniq and scientific resources of the river comdor. The National Pazk Servica is the
primary advocate for national interests in the corridor and has mandated reriew responsibiliries for
federally funded or permitYed activities. The visions aad poIicies of the MNRRA Comprehensive
Nlanagement PIan (CMP) provide guidance for National Pazk Service review of this and other
federal acfions in fhe corridor.
General Comnients
We recognize that the St. Paul Downtown Airport has piayed ari important role in Saint Paul's
history and continues to make a significant eontribution to tlie economy.of tlte Twin Ciries. We
also realize the inconvenience and hardship sacperienced by airport users, the airport itself, aad
the regional airports system when major flooding forces its closure,
While v,�e understand the desire to provide reliable air service at Hoiman Fieid
major flood evenis also note that���-�`�����������:;
�
�
�
ri�,�e nu� unpaemenianon orwese gcs�[�is auncult to ach�eve m fhe oontext of aiiport
operational needs, tiest effotts sliould be made Y6'mazmiize the integratIon of MNRRA CMP
goais in �s ptaiuiing effort, :
�
��
O6-3b3
future grourth and development with restoration
programs that reconnect and restore remnant natural
communities.
'� 4.2.3. The City will continue to support the efforts of
�
�"� organizations such as Great River Greening to restore
native grasses, shrubs and trees along the riverfront
dowrttown and elsewhere in the river conidor.
Figure K
4 Z 4 ' �.� x,,� r � � �� � � w � � ��
.�-.� �3;�����-�.'�.� �* r�+�tE@-� �'��.��- �.._ .
� � y� � r A r structures. In addition the City
wili support efforts to restore the shoreline to a more
natural character within 100 feet of the river to facili-
Trail between Warner Road tate wildlife movement, and to improve the aesthetic appearance of the
and the Mississippi River floodwall. Such efforts must be compatible with current channel design
and flood control management, and exceptions are made for marinas.
and other uses requiring river access. Redevelopment should include
removai of unused docking facilities (i.e., at the Koch-Mobil site).
4.2.5 In all new developments, threatened and endangered wildlife
� habitats shall be protected fmm alterations which would endanger their
survival.
Figure'L
Ber► Thompson's visio.o of
"The Great River Park"
4.2.6 The City will integrate its plans cuith the work of the DNR's Metro
Greenways and Natural Areas Collaborative. This metro area collabora-
tive has identified high quality native halaitat remnants which couid be
linked into regional greenways, providing continuous habitat corridors to
support native plant and wIldlife species. Many potential greenway
opportunities exist in the East Metro area, including Saint Paul.
;t
22 CifVnf.Saint Partl
. - asir+r�aarous
sa..zr[.i . .
i.`s'm YoRX
'�/+aFifMl•roN 4.c.
' . Dbt+YUA -
� s�xnwv+�rs�e
taxnoN
OIW F6pIN6s
a12OHORACE "
S.u'�' Nt� CiSY '
PARCO
SQVSjiIIAN CALfPO1lAIIA
Mr. Gary Wa[ren
IvfettopolitanAizporY Comtmission
Dixector.-Airsisle Developmene
fiQ4D 28th Avenue Sou¢h
Minneapolis, MN 55450
iVovember I3, 2002
Rei
Dear Mr, Warren:
DORS�Y & WHITNEY LLp
S❑t�a 45oa
. 50 SacrTy Sir,�H S'RtBE�c
MtiSNBAPOt,�3. M�ArCte9o•cn 5540L-1496
• 1�c.seHONC: (fi72) 340-2660 �
_ I�nx; (612,1 3bD-2868
wµ+w.doqoylnwcem,
THOAtlSS 2TI7FCHA3S
(612) a4aZ8z4
FAS (619) a40-3807
1SII�111d2Q�j�OSBCfj; W_C'4IIl
Holman Field Flaod Protection Envirtlninei�t�ReviGw
�
�
Tho fnllowtng comments are submitted on behalf af Nortttwest_ Airlines, Inc. in regard tu "
the Envirnzuncntal Assessment Worksheet (EA.VJ� prepared by the Metmpolitan Airpo�ts
Commission (MP,C) fortt�e Holir►an Field Flood Protecdon PCojcct� 'rhe project involves .
coristruetion of a dike along the shoreline of the Mississippi River and excavation of a porti.on of
the banks. The project will also result in the loss of wetlands. •
k3ased upon a review of the EAW, it is clear that an Environnicrital Impact Statement
(�IS) is necossary. An F.TS is mandaiory for any prnject thac has the potenLial for significant
eavironmcutal eff'ects. An Environinental Impact Sta;ement (EIS) is CCq{tired in ttus instance
becausa the proposed olimination of wetlands an,d the consEructiott of fhe dike has the potential
for significaat environmenEal cffccts_ The E�1W i& also incomgleCe and, therefare, does not
suppon a negaCive declaCation, hecause it does not praVide Sufflcient in£otmation regarding
environmental impacts associated wrth (i) the flood �isks poscd Uythe dike, (ii) tlle wetlat�d _
destruclion, and (iii) die MAG's predicted increase xn the ntii"ization o6thc aixport if, thc dike is�
coustructed. ------------------------
Y: - - gackground - - - -- -- - -
" The MAC has proposed to conshuct 2 dike along the ea&t and south edges of Holman
Field to prcvant future floodin� by the Mississippi River. The dike is proposed to be 9,800 feet
long and range in h�igltt fro� 4 to 8 fect above ground level. Tho top of the dike wou]d be
��-��� .
aws�cr . ::
NoRZtiE.67avtuLrt�dc
r�a�¢
_ YN.OAf.tO
1tDNC I�NG
cxsnr rwv�
��0.
2OriOn1G .
p[SSOtII,M1 .
HHnNOF[ni
YIfNLV�lV50.
�-
�
�-
,
METROPOLITAN AIRPORTS COMNIISSION
� �aE��t�i55A�,
2 } v
�
r � z
_ c
+ �
, '� � F
s � �
c
' March 28, 2006
Minneapolis-Saint Paul International Airport
6040 - 28th Avenue South • vlinneapolis, .ViN 5�4�0-2799
Phone(6L2) 726-8100
' City Council
c/o Zoning Administration
City of Saint Paul
O�ce of LIEP
I 8 Fourth St. E., Suite 200
Saint Paul, MN 55101-1024
' Subject: Planning Commission Appeal, File No.: 06-051296
Metropolitan Airports Commission - Holman Field Levee
,
��
�
�
i
,
C�
,
�
'
e
Dear City Counci( Member:
�5-353
The Metropolitan Airports Commission oversees 560 of the most economically important acres in St.
Paul: the St. Paul Downtown Airport. A 2005 economic impact study by Wilder Research estimates that
the airport sustains 853 jobs and generates $112 million annually for the area economy. The airport also
serves as a unique transportation anchor for businesses making siting decisions. Nolman Field is the
primary reliever airport for business aviation; in fact it is the only reliever airport capable of
accommodating many of today's modern business aircraft.
Despite the airport's importance to the region, it has been subjected to repeated flooding, resulting in
closure of the airport for weeks or months at a time at a cost of millions of dollars to the Metropolitan
Airports Commission and businesses that use the airport. Unlike other properties along the river, St. Paul
Downtown Airport has not been protected by a floodwall. Until now, funds for floodwall construction were
unavailable. Due to the work of many local, state and federal leaders and the commitment of people in
both the public and private sectors, we now have the funds needed to move forward. The federal
government, the state of Minnesota, private industry and the Metropolitan Airports Commission together
have committed the funds needed for a project to protect Holman Field from a 100-year flood at no cost to
the city of St. Paul. I ask for your support in helping us move this project forward so we can safeguard
one of St. Paul's most important public assets.
GnGosed you will find our response to the appeal filed in opposition to the Planning Commission approva!
of this project. We have also included for your convenience a comprehensive overview of the project.
We welcome any questions you might have and look forward to your support for this important project to
the city and the users of Holman Field.
Sincerely,
��� =1�� �
Vicki Tigwell, Chair
Metropolitan Airports Commission
The Metropohtan Airpo�ts Comm�ssion is an af6rmative action employer.
� www.mspairport com
ReLevevAivpocPS AQ2LAKE•ANOKACOUNTY/BLAINE•CRYSTAL•PI,YINGCI,Oi7D•LAKEELMO•SAINTPAULDOWNTOWN
9 /RPOP Z9
Zoning Files 06-000725 and 752
On February 24, 2006, the City of St. Paul Plam�i��g Commission voted 15 - 4 to approve the
perniit application submitted by the Metropolitan Airports Commission (MAC} for the proposed
floodwall and runway safety area airport improvement project. The approval included the site
plan review and t2u�ee (3) variance requests to river corridor standards: for slopes greater than
12% and 18% respectively along portions of the shoreline (68.402.b.2 and 68.402.c.7); for the
earthen levee to have slopes steeper than 18% (68.402.c.7); and for a portion of the sheet pile
wall to be conshucted within 50-feet of the ordinary high water mazk (68.402.b.1.b).
St. PauI Downtown Airport Improvement Project ` �� 3 6�
SITE PLAN APPLICATION SUPPLEMENT 3
' On March 3, 2006, this approval was appealed to the St. Paul Ciry Council by District Councils
1, 3, and 4, the Friends of the Parks and Trails, Friends of the Mississippi River, and the
Audobon 3ociety.
,
C
L�
L_
�
,
J
LJ
�J
i
i
__
APPEAL REBUTTAL
Listed below are the MAC's rebuttal comments offered in response to the appeaL The rebuttal is
presented in the order of the appeal for simplicity in reading. The text in italics represents
language from the appeal to which MAC is responding.
I. Introductory Page — GROUNDS FOR t1PPEAL
Yariances are inconsistent with Mississippi River Critical Area, Comprehensive Plan for the
Mississippi National River and Recreational Area (MNRRA), St. Paul Comprehensive Plan and
St. Paul Zor�ing Code.
MAC Response:
a. The airport project is not inconsistent with the goais and policies of the NiNRRA or St. Paui
comprehensive plans.
b. The MNItRA comprehensive plan recognizes economic activities and commercial use of the
river comdor. Tn fact, it states that auports pre-existed the establishment of the MNRRA and
are generaliy recognized as important contributors to the Twin City economy.
c. The projects will actually enhance the diverse values of the corridor by improving the current
eroszon problems along the river bank at the airport where the compensatory excauation will
occur, and by maintaining most of the exisfing vegeta6on and trees in the area of sheet pile
wall installation.
� 03/28/06 Page 1 of 11
�
,
1
,
'
'
'
�
�
'
'
'
1
,
St. Paul Downtown Airport Improvement Project
Appeal Rebuttat
�� -� �
�.:-.�;�3
d. The City of St. Paul Comprehensive Mississippi River Corridor Plan allows and encourages
the use of vegetation, soil bio-vegetation, and native plantings to enhance the look of the
river corridor. These techniques are being incorporated into the project.
e. The best views of the airport from the river exist at the southern end of the airfield. These
views will be maintained and even enhanced by the proposed vegetation plan since this is the
azea of temporary floodwail. Only during flood events will this azea be walled off, and it is
during those same times when recreational use of the river halts.
f. The City of St. Paul Comprehensive Mississippi River Corridor Plan (3-14-01) includes
initiatives to have a full length trail along both sides of the river. It notes specificaily that the
trail in the area of the airport and Pigs Eye Lake is not planned to be directly adjacent to the
river bank. Note, however, that a trail around the river-side of the airport is not feasible with
or without completion of the perimeter dike project due to the airport and barge security and
safety concerns.
g. According to the St. Paul Riverfront Corporarion, a pedestrian and bike route around the west
side of the airport was iden6fied in October 2002, "... that a11 parties believe is feasible to
provide such a connection".
PLANNING COMMISSION FILE NO. 5-17: VARIANCES
1. In SO years the number of days the airport was closed because of flooding by the 100 year
flood is 148 days out of 18, 250.
The levee/floodwall system cannot be constructed under the strict provisions of the zoning
code.
The City determined a floodwall is not a reasonable use when they adopted Sec. 68.214(h)
which establishes the dike as a prohibited use.
MAC Response:
a. Historically, the St. Paul Downtown Airport (STP) closes during any floods of a ten (10) year
' return frequency or greater. Therefore, only considering closure days during 100-year events
is inaccurate. The airport has experienced a ZO-year, 56-year, and a 75-year flood all in the
last 12 years.
'
'
,
b. The Federal Aviation Administrarion (FAA) recognizes the impacts to the national airspace
system when STP is closed and some flights are diverted to the Minneapolis — St. Paul
Internarional Airport (MSP). Although the number of STP airport closure days may seem
minimal, the impact in delay time and cost add up quickly. Delay costs alone at MSP would
be over $2 million if the 2001 flood event occurred in 2008.
' 03/28/06 Page 2 of 11
L�
�1
,
I�
St. Paul Downtown Airport Improvement Project
Appeal Rebuttal
�6-3�3
c. If the 2001 flood event were to occur in 2008, it is estimated the airport tenants, users, and
airlines at MSP would incur close to $7.2 million in impact.
d. The number of days in total STP was closed in 2001 for aircraft weighing 100,000 pounds or
more (typically the ones needing MSP as an alternative) was 231 days.
� e. As noted in the Planuing Commission Resolution, dated February 24, 2006, the existing
shareline in Yhe area of proposed compensatory excavarion typically has slopes in excess of
50%, far exceeding the zoning code. Therefore, the proposed excavation and requested
, variance, while sfill exceeding the zoning code, will greatly improve the existing condition
and bring the shoreline c�oser to the zoning code requirement.
, f. Secrion 68.214(h) references Mn Statutes Chapter 103G, which deals primarily with
wetlands, dams, and work in pubIic waters. There are no wetland impacts from the perimeter
dike project, and there are no dams included in the project. This statute outlines the
� provisions required in order for the Department of Natural Resources (DNR) to issue permits
for work within public waters. There are no sections of this statute that would be violated by
the proposed project. MAC continues to work cooperatively with the DNR on this permit.
' The DNR cannot issue the permit until the City finalizes its action on the site plan and
variance requests, but expects it to be issued in April if the City approves the project.
� g. The proposed project is not a community-wide project and does not remove areas from the
floodplain. It is proposed to be conshucted in the flood fringe upon completion of the
compensatory excavation after FEMA revises its flood insurance maps and the City rezones
� the property to be compatible. City ordinances allow Yhe dike to be constructed if it is in the
flood fringe and not the floodway.
,
�
�
�
,
�
LJ
2. The circumstances were created by the Zandowner.
Flooding in a floodplain, floodway and ordinary high water levels are not unique to this
property.
MAC Response:
a. As noted 'm the Planning Commission Resolution, dated February 24, 2006, MAC took
operarional ownership of the existing airport facility via Minnesota Statutes in the 1940's. In
addition, the 3M hangars were constructed and owned by the federal government during
World War II and were subsequently transferred to MAC after the war. The locarion of these
shuctwes, which limits the positioning of the sheet pile wall, was not created by aither the
City of St. Paul or MAC.
b. The unique characteristic of this projecY relates to its use as an airport that is part of an
overall system in the Metropolitan Area The St. Paul Downtown Airport (STP) is the only
Intermediate airport in this metropolitan system, and the only one with a runway length in
excess of 5,000 feet. It is the pritnazy corporate reliever to the Minneapolis — St. Paul
International Airport (MSP), and the only airport outside of MSP that can handle operations
by certain jet aircraft.
' 03/28/06 Page 3 of 11
'
�
L �
'
'
'
'
�
t
'
�
'
'
'
,
�
,
�
St. Paul Downtown Air�wrt Improvement Project
Appeal Rebuttal
Qb-3�3
3. The St. Paul Zoning Code prohibits construction of community-wide flood control structures.
Code requires a 50 foot setback. The proposed variance of as little as zero setback is not in
keeping with the spirit and intent of the code.
Airport noise and pollution connected with a near doubling offlights and a projected
increase of based aircraft negatively impacts health, safety, comfort and welfare.
Loss of views and access to the rzver negatively impact the weZfare of inhabitanzs of St. Paul.
MAC Response:
a. As noted in the Planning Commission Resolution, dated Febniary 24, 2006, the variances for
the levee and floodwall are consistent with the spirit and intent of the code. The slope
restricrions and distance requirements are intended to control erosion and development
impact on the river from individual buildings, not from flood control projects. The side
slopes for the earthen levee will not haue an impact on the character of the river. The
reduced setback from the river for the sheet pile portion of the project will not impact the
character of the river because it will be screened by existing vegetation and will not be
visible from the river.
b. Forecasted levels in MAC's long term comprehensive documents do not represent a
"doubling" of current operations. Aircraft operations at STP haue decreased by nearly
60,000 annual landings and takeoffs since 1990. The number fluctuates both up and down
annually driven primarily by the state of the economy. It is expected aircraft operations will
eventually increase again, but will be influenced by economic factors (a good thing for the
City), and not dependent on the existence of a floodwall.
c. Considerable effort is being made to ensure the appearance of the sheet pile wall does not
detract from its surroundings. Existing trees and vegetation will be substantially preserved
and will largely obscure the sheet pile wall from view (see attached renderings). MAC
intends to plant additional vegetation on the wall to enhance the aestherics. Ba�eld Street is
not known or marked as a public access road, there is no designated public parking ar
designated river viewing locations, and there is no existing public access to the river that
would be impacted by the project.
4. The increased noise and pollution with a near doubling of operations will negatively impact
property values.
Building a 9 foot tall and mile Zong s1ee1 tivall thaZ eliminates views of and access to the river
alters the essential character of the area.
Building a mile long wall that looms 22 feet above normal water level and has as little as
zero setback from ordinary high water alters the essential character of the area.
, 03/28/06 Page 4 of 11
'
�
LJ
LJ
'
�
�
'
,
,
'
'
,
St. Pau1 Downtown Airport Improvement Project
Appeal Rebuttal
MAC Response:
ab-363�
a. The Ramsey County taY assessors office has provided information regarding property values
for neighborhoods around the airport, all of which indicate an increase in property values; not
a decrease. The number of aircraft operations fluctuates up and down annually driven
primarily by the state of the economy. It is expected aircraft operarions will eventually
increase again, but will be influenced by economic factors, and not dependent on the
existence of a floodwall.
b. See pazagraph No. 3.c above.
a The "existing chazacter" of the area is lazgely unscreened exposed sheet pile towering 20-30
feet above the river along Warner Road. The proposed airport wall is set back on a�erage
approximately 30 feet from the ardinary high water edge. There are azeas where this distance
exceeds 100-feet. In azeas where there will be less than 10 feet, the existing vegetation will
remain and screen the wall similar to other segments of the sheet pile wall. A siguficant
amount of the existing lreas that wilI remain on the river bank are taller than the proposed
sheet pile wall. The MAC intends to plant additional vegetation screening on the wall. In
addition, the sheet pile will be painted with a zinc-oxide surface similar to the earthtones
used on the Eaton Street dike or any other color the City would prefer.
S. The stated intent of the variance is to allow a use that is prohibited.
MAC Response:
a As noted in Yhe Planning Commission Resolution, dated February 24, 2006, Yhe
compensatory excavation will not change the use of the property. Once the compensatory
excavation has been completed and approved by FEMA, and FEMA has issued its Letter of
Map Revision (LOMR), the City will be notified that the floodway boundary has changed.
At that time, the City Council will be asked to rezone the area removed from the floodway
(RC1) to Flood Fringe (RC2) which is necessary for a levee to be permitted. Therefore, the
variance for the levee should be conditioned on rezoning the area from RCl to RC2.
b. It is MAC's impression based on comments made by City staff at the Zoning Committee
� meetings that it is implicit in the CiTy's site plan/variance approval that the City will rezone
the affected property from Floodway (RCl) to Flood Fringe (RC2) to allow construction of
the perimeter dike, pending FEMA's issuance of a LOMR.
,
�
6. The only reason for the request is primarily to increase the value of income potential of the
parcel of land — to keep the airport open during periods of high water.
MAC Response:
� a. The purpose of providing 100-year flood protection for the St Paul Downtown Airport is
twofold; reduce damage and disruption to users of the airport, and to reduce the impact that
flood events ha�e on the capacity of the Minneapolis-St Paul Intemational Airport (MSP)
' and the National Airspace System. By doing so the MAC is protecting the interests of the
traveling public and the taxpayers of Minnesota.
' 03/28/06 Page 5 of 11
L.
L1
�
,
,
'
�
'
�
[l
'
'
,
'
St. Paul Downtown Airport Improvement Project
Appeal Rebuital
Q�-3�3
(a) USFWS wetland mapping shows wetlands in the area of proposed work MAC has not
provided evidence to demonstrate that wetlands are not affected.
MAC Response:
a, The Environmentat Assessment prepared by MAC and approved by the U.S. Department of
Trausportafion includes a discussion of wetlands, and finds no nnpact to wetlands from the
proposed project.
b. The U.S. Pish and Wildlife Services (USFWS) map referred to in the appeal is dated from the
early 1980's. The south end of the airport was wetland at that time. Filling of that same
wedand complex was pernutted, mitigated and completed in the late 1980's when
construction of the runway and south building azea occurred.
c. The U. S. Arxny Corps of Engineers (COE) has concurred that there are no wetlands
impacted by this project.
MAC has not provided evidence why they cannot keep the dike off the 12% slopes.
MAC Response:
a. The areas requiring variances haue been op6mized only to those that cannot be
accommodated due to existing topography and close proximity to the existing river shoreline.
Although not all areas will meet the City code and will require the variance, slopes will be
significantly improved in all azeas along the shareline. In addition, the final site landscaping
in relariott to the code will be a vast improvement from the existing site.
�LIAC has not provided any evidence that compensatory excavation will not result in
changing the navigational channel.
MAC Response:
a. The following agencies are responsible far evaluating river hydraulics, including the
, compensatory excauarion. They all have issued letters to the MAC with comments and
acceptance of the Mississippi River hydraulic modeling submitted for the proposed project.
This was based on their independent review of the information submitted by MAC.
�
'
L�
➢ U.S. Army Corps of Engineers, July 22, 2002
➢ Minnesota Department of Natural Resources, August 12, 2002,
➢ Federal Emergency Management Agency, June 14, 2005,
� 03/28/06 Page 6 of 11
�
'
'
'
�
�
�
,
�
,
'
�
,
'
'
'
St. Paul Downtown Airport Improvement Project
Appeai Rebuttal
�6
MAC has not provided any information regarding the protection of habitat af threatened and
endangered species such as the Higgin's Eye Pearly Mussel which the DNR is stocking.
MAC Response:
a A field evaluation was done as a part of the Environmental Assessment. No threatened or
endangered habitat or species were found. The survey will be recottducted in the spring to
verify this.
b. A mussel survey will be completed prior to the start of construction. This survey will
investigate the presence of Higginseye or any other mussels in the river within the proposed
compensatory excava6on area If any are found, a permit will be applied for and the mussels
properly relocated prior to excavation.
c. The DNR has stated that it is unlikely that any mussels, especially the Higginseye, will be
found in this stretch of the river. Nevertheless, the mussel survey will be conducted and
relocation accomplished if necessary before excavation begins.
There is no precedent in Minnesota for compensatory excavation on the Mississippi River.
MAC Response:
a. There are numerous examples in the state and counhy where compensatory excavation has
been used. In Minnesota, projects haue been done on the Zumbro River, Minnesota River,
Chaska Creek, Bear Creek, and the Roseau River, to mention a few. FEMA, the COE and
the DNR obviously are comfortable with this proposed technique having approved the
hydraulics.
b. The compensatory excavation will have a positive effect on upstream properties by reducing
the impact of floods below a 100-year frequency.
Critical Area regulations and MNRRA Tier 2 requirements call for protecting, restoring and
providing public access to the shoreline of the river.
MAC Response:
a. There is no public water access to the Mississippi River at the airport. The previously used
sea plane base has not been u6lized for years, and the bay has been allowed to silt in. The
level of barge traffic does not allow for aircraft operations within the river channel.
' The Department of the Interior letter dated August 4, 2005 states that constructing a dike
system along 9,355 feet ofthe Mississippi River is inconsistent with many MNRRA CMP
goals and policies. These include preserving riverbanks in their natural state, restoring
' denuded shorelines with vegetation, increasing and restoring wildlife habitat, and preserving
views of and from the river.
' 03/28/06 Page 7 of 11
�
'
�
'
�
�
,
,
i
'
'
'
St. Paul Downtown Airport Improvement Project
Appeal Rebuttal
MAC Response:
�b
a. The Department of the Interior - National Park Service letter was responded to as part of the
Fina1 Environmental Assessment and Finding of No Significant Impact prepared by the FAA.
b. The National Park Service participated in the review meetings with other agencies to discuss
this proj ect. They have been invited and agreed to work with MAC on the revegetation plan
for the sheet pile wall.
c. This project is meeting the intent and spirit of the MNRRA requiretnents by preserving the
existing vegetarion along the sheetpile wall, enhancing the existing vegetation with additional
planfings, and by restoring the severely eroded shoreline along the compensatory excavation.
Shoreline restorarion along the compensatory excauation will include grading to meet the
City ordinance far slopa percentage where feasible, restoring the shoreline with plantings of
native grasses, and protecting it with riprap to protect against significant ongoing barge
operations.
7. Title Opinion and maps showing the proposed compensatory excavation is not Zocated on
airport property. The variance approved does not include the area of the proposed
compensatory excavation.
MAC Response:
a. The entire northern half of the St. Paul Downtown Airport (STP) is owned in fee title by the
City of St. Paul. By statute, MAC operates and maintains the airport and has jurisdiction to
exercise powers with reference to airport property, except for disposal of fee title. The area
includes the entire northern secrion of sheet pile wall.
b. The southem portion of the airport property is owned by MAC in fee title. This includes the
� area proposed for the temporary floodwall, the earthen dike, and the southern section of sheet
pile wall.
I_.
�J
'
,
'
c. A strip of land exists between the area owned by MAC and the river. Our investigations
indicate that this strip of land is owned by the St. Paul Port Authority (deeded from the City
of St. Paul in 1934). This was confirmed in a title search effort concluded on March 20,
2006. It is within this area that the compensatory excauation is to occur. The Port Authority
recently provided the City Attorney with a letter indicating their, "... willingness to grant the
MAC the property rights necessary for the project, should the City approve the project".
d. MAC and the Port Authority staff haue reached a consensus on the design of barge moorings
to be relocated in the area of compensatory excavation. The impacted moorings will be
relocated and/or replaced at MAC's expense.
' 03/28/06 Page 8 of 11
,
,
,
'
�
,
�
'
'
'
�
�
'
'
'
'
'
'
St. Paul Downtown Air�wrt Impmvement Pmject
Appeal Rebuttal
PLANNING COMMISSION FILE NO. 5-18: SITE PLAN APPROVAL
Ob-3b3
Threatened and endangered mussel species live in this stretch of the river and are curr•ently
being stocked and reintroduced. Compensatory excavation and maintenance would be an
alteration ofhabitat.
The suf-vey ofplants and wildlife was done in December so a good evaluation ofpotential
impacts has not been provided.
MAC Response:
a. There is no evidence thaY mussel species live in the area of proposed compensatory
excavation. In fact, the DNR has stated that it is higlily unlikely that any mussel populations
live in the area given the scour velocities and degraded water quality. The existing shoreline
does not provide good habitat, therefore, the compensatory excauation will not have a
significant effect.
b. Prior to construction, a survey will be conducted by the DNR, at MAC's cost, to determine if
mussel populations are present in the azea. If found, MAC will relocate the mussels to a
mare stable and appropriate habitat, as determined by the DNR.
c. The DNR has been stocking the river with mussels, but not in the vicinity of the airport.
d. Even though the survey of plants as wildlife was done in December, evidencs of the types of
plants and wildlife in the project areas was visible, indicating the unlikeiihood that threatened
ar endangered species would be present. MAC wilt revisit the project area this spring before
it is disturbed to confirm there are no threatened or endangered species within the project
area. If such planYs or wildlife are discovered, the impacts will be evalnate@, permitted, and
if necessary, mitigated through the appropriate agencies.
2. Airport noise is projected to nearly double operations negatively impacting surrounding
properties.
MAC Response:
a. The floodwall will not affect the growth of the airport. Growth of aircraft operations will be
based on the economy, not on whather or not a floodwall is constructed.
b. Forecasted levels in MAC's long term comprehensive documents do not represent a
"doubling" of current operafions. Aircraft operations at STP have decreased by neariy
60,000 annual landings and takeoffs since 1990. The number fluctuates both up and down
annually driven primarily by the state of the economy. It is expected aircraft operations wiil
eventually increase again, but will be influenced by economic factors (a good thing for the
City), and not dependent on the existence of a floodwall.
c. Even with the highest forecasts, there are no residential areas within the 65 DNL contour,
which is the noise level used by the FAA to deternune impacts.
, 03/28/06 Page 9 of l I
'
C �
�,'
u
St. Paul Downtown Airport Improvement Project
Appeal Rebuttal �] � _ � � �
;�
3. A near doubling of operations will have an impact on vehicular traffic and as a result will
affect the neighborhood.
MAC Response:
� a. Access to the airport is from the west only, through the Northport industrial pazk (Plato
Boulevazd and Fillmore Avenue to Bayfield Street), or from the Southport industrial park
(Eaton Street). Freeway access to these streets is from Trunk Highway 52 and Interstate 94.
' There aze no residential areas through which any significant vehicle traffic accesses the
airport.
��
�
�
�
4. MAC does not have the required MPCA permits. MAC has not done the necessary soil and
water testing for potential pollution.
MAC Response:
a. MAC has a general storm water discharge permit for the airport. The contractor will apply
for the required construction and erosion control (NPDES) permit from the MPCA. It is
standard practice for the contractor to apply for that NPDES conshuction permit since he will
be responsible for the conditions included therein.
b. Based on extensive soils information gathered to date, it is unlikely that contaminated soils
� will be encountered in the compensatory excavation area. Addirional samples are being
gathered in early April and wilt be used by the MPCA to formulate final permit requirements.
If contaminated soils are discovered, they will be reported and disposed of in accordance
tl
'
'
'
'
,
�
,
with agency requirements.
Zoning eode and Planning Commission resolutions do not allorov construction of the dike unless
the City Council supports a change to the Zoning Code.
MAC Response:
a. It is MAC's impression based on comments made by City staff at the Zoning Committee
meetings that it is implicit in the City's site plan/variance approval that the City will rezone
the affected property from Floodway (RCl) to Flood Fringe (TZC2) to allow conshuction of
the perimeter dike, pending FEMA's issuance of a LOMR.
The EA shows a cost benefzt of 1.21. When the real cost and actual number of floods are used, it
has Zess that a 50-cent return on the dollar.
03/28/06 Page 10 of 11
`J
'
�
St. Paul Downtown Aiiport Improvement Project
Appeal RebuttaI
� �-.o "° -� �
MAC Response:
' a. Based on MAC's benefit-to-cost calculations, the project cost must exceed $29 million to
generate a rario that is less than 1.0. The current cost estimate is approximately $26 million,
which equates to a benefit-to-cost ratio of I. i 3.
b. The number of floods used in the cost benefit analysis is representative of past floods. An
"actual number of floods" cannot be determined — it can only be forecasted.
BASED ON THESB RESPONSES, MAC BELIEVES THE APPEAL SHOULD BE DENIED.
Please also note that MAC participated in a series of ineetings convened by Mr. Gregory Page of
the St. Paul Riverfront Corporafion to discuss and explain the project elements and hydraulics,
environmental and aesthetic issues, and permitting. Other attendees included The Friends of the
Mississippi River, the National Park Service, the Department ofNatural Resources, the U.S.
Army Corps of Engineers (COE), the Minnesota Pollution Control Agency, Ms. Anne Hunt from
the Mayor's Office, City of St. Paul Public Works, and Mr. Tom Dimond (advocate citizen).
These meetings occurred subsequent to the Planning Commission meeting on February 24, 2006.
MAC intends to continue to work with City staff, all regulatory agencies, and interested parties.
03/28/06 Page 11 of 11
i
,
�
,
1
1
'
�
�
'
�
�
'
1
'
'
�
,
'
ppOl15 $,a�H
c�� j 4
F t 9 �
v
m �
O
9 � f 0
0 0
9 1 �
O ('. t T GO
9~ 4 �HVOP tS
yiJ �� '� }' _
6A 4' � j� Ei l
St. Paul Downtown Airport Improvement Project
SITE PLAN APPLICATION SUPPLEMENT 3
Zoning Files 06-000725 and 752
CONTENTS:
1. PROJECT DESCRIPTION
2. PROJECT STATUS
3. PROJECT HYDRAULICS
4. COMPENSATORY EXCAVATION
5. NO RESULTING AIRPORT EXPANSION
6. COMMUNITY CONCERNS & ENVIRONMENT
Updated 03/28/06
FG
�
ST:
,-,�, �=,�� �-�
� 1 ..
Y'/' 4 �;
� .y�:GJ �'yb' F,W.a . '..QYa�>— ^ '}a:
'� �� F y .. y `
��
� .
. � .•� v�'+5v;'ti. � � i .�. - � � ��. ..
",.'�'v;�a '3'Y}►
.`EiA'`ai '.�, "� « i ��
� s ♦
r, a @y a
� . c l�
\ - �
x ,, r
� ,�, v :� f m
�.� : ,_,�;
<�
�y.
'k J �:
� .. II . . . .. .. . .
�
�� w
�~ , ':~`:.. �
�
t St . Paul Downtown Airport Improvement Project0 6° 3 6 3
SITE PLAN APPLICATION SUPPLEMENT 3
�
1
�
�
�
'
L1
,
�
�
Zoning Files 06-000725 and 752
PROJECT DESCRIPTION
The proposed 'unprovements at the St. Paul Downtown Airport (STP) consist of two projects:
construcfion of a perimeter floodwalUdike azound STP to protect the airport and its users during
a Mississippi River flood event up to a 100-yeaz frequency; and runway length shortening to
address runway safety area (RSA) issues to comply with current FA A standards.
This packet will focus primarily on the perimeter dike project. The RSA project is relatively
straightforward but is mentioned since it is included in the site plan application.
PERIMETER FLOODWALL/DIKE PROJECT
The purpose and need for the Perimeter Dike project aze to:
• Maintain the role of STP as the primary reliever airport to the Minneapolis — St. Paul
International Airport (MSP) by keeping STP open during flood events with a frequency of up
to 100 years (a 1% recurrence interval) on the Mississippi River;
• Maintain a consistent and reliable level of service for users of STP;
• Prevent flooding of structures on the airport; and
• Mitigate continued operational, maintenance and other impact costs associated with flooding.
The proposed pernneter dike would be 9,635 £eet in length and consists of the following separate
elements as shown on the enclosed figure:
• Permanent Sheet Pile Wali - approximately 5,718 feet (4,251 + 1,467 feet) of zinc-oxide
� coated sheet pile driven up to fifty feet deep along portions of the northeastern and
southwestem comer of the airport boundary. Sheet pile is proposed to be used in azeas where
there is insufficient space for a permanent earthen levee.
, • Permanent Earthen Levee - approximately 995 feet of permanently conshucted earthen levee
between Ruriways 31 and 32.
�
IJ
�
��J
lJ
• Tempararv Dike - approximately 2,922 feet erected before floodwaters reach a pre-set trigger
elevation which would be depioyed across the Runway 27, 31 and 32 ends and adjoining
safety areas. The two sections of temporary wall connect to the sheet pile wall and earthen
levee sections to fully close off STP prior to encroachment of a flood event.
The temporary dike will be constructed with deployable floodwalls (made up of aluminum
composite planks secured to removable concrete-embedded steel posts) and will be used across
the east and southeast pauements of all three runways. When not needed, the temporary wall
sections will be stored on site allowing the airport to operate unconstrained during normal river
stage.
Updated 03/28/06 Page 1 of 19
�
�
�
�
'
'
1. PROJECT DESCRIPTION, cont
PERIIvIETER FLOODWALL/DIKE PROJECT. cont.
06-363
This project also provides for excauation of the riverbank along the southeast edge of the airport.
This "compensatory" excavation will widen the river channel slightly along 3,250 feet of the
southeastem corner of the auport (see figure) to accommodate the water displaced from airport
property by the floodwall during flood events.
RUNWAY SAFETY AREA (RSAI PROJECT
' The purpose and need for the RSA Improvement project are to:
• Comply with current FAA standards;
• Provide improved safety measures for users of STP; and
' • Ensure that STP remains eligible for future Federal funding.
� RSAs are intended to increase aitport safety by providing an area sufficient to bring airplanes to
a complete stop in the event they undershoot, overrun or veer off the runway. These safety azeas
also increase the airfield accessibility for emergency fire fighting and rescue equipment. RSAs
' are centered on runways and extend for a given distance beyond each runway end. They do not
increase runway length.
,
�
,
In order to meet standazds, the airport's longest runway, 14-32, will actually be shortened from
6,711 feet of usabie runway to 6,509 feet.
An aircraft arresting system (EMAS) will also be installed at each end of Runway 14-32. This
crushable concrete is designed solely to stop an aircraft in the event of an emergency and is not
usable for aircraft operarions (it would be crushed by the weight of an airplane, disabling the
aircraft from moving).
To meet RSA standards for the other two runways at STP, it is proposed to shorten the overall
, length of each runway. This will allow for the full recommended length of stopping distance
beyond the end of each runway, so no arresting system is required.
,
'
'
�
' Updated 03/28/06 Page 2 of 19
�
��
�
��
�
�
�
�
�
�
�
�
�
�J
�
�
�
�
�
06-3�3
�/ �� .
�� Flood Protection Elements
a,��� _;�;
FINTB s t. Paul Downtown Airport
�
�
�
�
�
,
'
�
�
'
06-363
Z. PROJECT STATUS
This secfion provides information on the project status relative to the environmental review
process, permitting, cost/benefit and funding of the project.
ENVII20NMENTAL REVIEW
• In October 2002, the Metropolitan Airports Commission (MAC) prepared and dishibuted the
mandatory State Environmental Assessment Worksheet (EAV� £ar the proposed flood
protection project in accordance with the Minnesota Environmental Quality Board (EQB)
rules. At that time, the project included the proposed floodwall and an airField subdrain
project, but no compensatory excavation.
• A public hearing on the combined dike/subdrain project was held by the MAC on November
4, 2002 during the EAW process. The MAC responded to written and public hearing
comments on the EAW and in December 2002, as the Responsible Governmental Unit
(RGLn, determined there would be no significant environmental impacts from the project and
the preparation of a State Environmental Impact Statement (EIS) was not required.
• In preparation for MAC's public hearing on the EAW, the City of St. Paul Plauning
Commission took public comment and issued a resolution generally supporting the proposed
project with stipulations that were addressed in MAC's December 2002 EAW determination.
• In 2005, MAC separated the underground subdrain installation portion of the project from the
' perimeter dike project since it was straight forward and had independent benefits to the
aixport. A Draft Federai Bnvironmental Assessment (EA) for the subdrain project was
distributed to the public for review and comment on Pebruary 14, 2005. MAC responded to
' comments received and submitted a Final EA to the Federai Aviation Administration (FAA)
far their review in May 2005.
'
�
�J
'
�
l
lJ
• On July 20, 2005, the FAA issued a"Finding of No Significant Impact/Record of Decision"
on the Final EA far the airfield subdrain project. The subdrain project received site plan
approval from the City of St. Paul on 7une 1, 2005, and is currently under construction.
On July 1, 2005, MAC prepared and distzibuted a Federal EA document for the perimeter
dike project, including the compensatory excavation, and the runway safety area work. MAC
responded to comments received and submitted a Final EA to the FAA for their review in
September 2005.
• On January 31, 2006 the FAA issued a"Finding of No Significant ImpactJRecord of
Decision" on the Finai EA for the perimeter dike, compensatory exca�ation and runway
safety azea work. The FAA concluded the project is consistent with existing environmental
policies and objectives set forth in the I�iational Environmental Policy Act of 19b9 and wiil
not significantly impact the quality of the environxnent.
Updated 03/28/06 Page 3 of 19
�
�
�
�
'
2. PROJECT STATUS, cont
ENVIIZONMENTAL REVIEW, cont.
06-363
The Final Environmental Assessment Report included response letters from:
United States Environmental Protection Agency
United States Department of the Interior, National Pazk Service
Minnesota Department of Natural Resources
Miuuesota Department of Traiisportation
' Minnesota Historical Society
Minnesota Pollution Control Agency
�
'
i
�
'
�
�
�,
Metropolitan Council
Representative Sheldon 7ohnson and City Council President Kathy Lantry
Friends of the Parks and Trails
Canadian Pacific Railway
Burlington Northern Santa Fe Railroad
Tom Dimond
Climb the Wind Insritute
Sue Jennings, National Park Service"
EIS NOT REOTJIItED
• Both the mandatory Federal and State environmental review processes have been completed
for the proposed projects.
• The decision to complete a Federal Environmental Impact Statement (EIS) rests with the
FAA. They have completed an independent review of the EA prepared by MAC and have
determined that there aze no significant environmental issues that would require preparation
of an EIS.
• The FA A carries out its environmental review responsibilities under provisions of the
National Environmental Policy Act and FAA's nnplementing policies and procedures (FAA
Order 1O50.1E).
� • The State EAW prepared by MAC is a screening docuxnent designed to determine if there are
significant environxnental issues that require additional environmental review, i.e. the
preparation of a State EIS. Upon review of the information in the EAW, it was determined
� that with the committed mitigation measures, the projects do not have a significant
environmental impact and further environmental review was not required.
�J
u
• The level of analysis of nnpacts is the same for an EAW, EA or an EIS. Significant
hydraulic analysis was completed before and during preparation of these documents. No
fiirther information would have been developed had an EIS been undertaken.
, Updated 03/28/06 Page 4 of 19
'
�
,
'
�
i
�
06-363
2. PROJECT STATUS, cont
The U.S. Army Corps of Engineers (COE), Federal Emergency Management Agency
(FEMA) and Minnesota Department of Natural Resources (DNR) all have thoroughly
reviewed and approved the project's hydraulics. This is highlighted in Section 3 of this
report.
� • Plauving for this project has been underway for a number of years, and MAC is at a point in
which pernuts aze needed so construction can begin in 2006. The environmental review
' process and hydraulic modeling are completed, reviewed and approved, and funding for the
project committed, so it is now time to seek the necessary conshuction pernuts from the City
of St. Paul and other agencies.
,
[l
�
�
�
�
CJ
�
'
'
'
�
In addition to the permits being requested from the City, technical permits are currently
under review by the COE, the DNR, and the Minnesota Pollution Control Agency (NIPCA).
The COE and DNR permits are nearing complefion and we have been told to expect them to
be issued in early Apri12006. The DNR will not issue its final permit, however, unfil the
City gives its approval of the project.
The Mf'CA National Pollutant Discharge Elimination Systetn/State Disposal System
(NPDES/SDS) conshuction pemut will be appiied for by the construction contractor and
attained prior to construction. It will regulate disposal of the exca�ated material from the
river and shoreline. MAC has already tested soil samples from the compensatory excavation
area, and is gathering additional samples for agency review priar to issuance of this permit.
• MAC has also met with the MPCA to discuss whether the existing general storm water
discharge permit is adequate for the airport into the future or if a new storm water permit is
necessary. MAC is providing additional water quality sampies to the MPCA from the new
airfield subdrain project for the MPCA to make its final determination on the permit.
• The permits to be issued by the COE, DNR and MPCA relate to construction practices,
disposal of excavated material and maintenance of the compensatory excauation area, and aze
typical of any construction project involving excavation. No outstanding issues related to the
hydraulics aze under review by these agencies.
• MAC is working with the DNR to complete a survey of the riverbed to identify any mussel
populations in the area of compensatory excavation. If mussels are found, they will be
properiy relocated prior to construction. The DNR will not issue a permit for mussel
relocation until construction is ready to commence, so a permit from the City is a prerequisite
to MAC obtaining this DNR pernut.
Updated 03/28/06 Page 5 of 19
,
M
�
�
�
�
'
�
'
'
�
2. PROJECT STATUS, cont
PERNIITTING, cont.
06-363
The DNR, COE, the National Pazk Service, the MPCA and MAC all participated in a series
of ineetings at the request of Mr. Gregory Page with the St. Paul Riverfront Corporation to
review and discuss in detail the project elements, environmental issues, and pernutting.
Other participants included the Friends of the Mississippi Rivet, Ms. Anne HunY from the
Mayor's Office, City of St. Paul Public Works, and Mr. Tom Dimond (citizen advocate).
PROPERTY OWNERSHIP OF PROJECT AREA
• The entire northern half of the St. Paul Downtown Aixport (STP) is owned in fee title by the
City of St. Paul (see the attached graphic). By statutory right (Minnesota Statute 473.621),
MAC operates and maintains the airport and has jurisdiction to exercise powers with
reference to airport property, except for disposal of fee title. The area includes the entire
northem section of the sheet pile wall.
• The southern portion of the airport property is owned by MAC itt fee title. This area includes
the proposed temporary floodwall secrions, the earthen dike, and the southern section of
sheet pile wall.
� • The strip of land along the river where the compensatory excavation is to occur is owned by
the St. Paul Port Authority (deeded from the City of St. Paul in 1934). This was confirmed in
a titie search effort concluded on Mazch 20, 2006. The Port Authority provided a letter to the
� City Attorney on Match 28, 2006 indicating their "...willingness to grant to the MAC the
property rights necessary for the project, should the City approve the project.
, • MAC and the Port Authority staff have reached a consensus on the design of barge moorings
to be relocated in the area of compensatory excavation. The impacted moorings will be
relocated and/or replaced at MAC's expense.
'
COST / BENEFIT ANALYSIS
�
�
,J
�J
• The Metropolitan Airports Commission developed a cost-benefit analysis that was reviewed
and accepted by the Federal Aviation Administration as part of their justification for
granting funds for the flood protection project.
If a 75-yeaz flood event, similar to that which occurred in 2001, were to occur in 2008 the
"avoided cosP' if flood protection were in place is estimated to be approximately $7.2
million.
' Updated 03/28/06 Page 6 of 19
'
�
�
�
'
,
�
�
�
�
06-353
2. PROJECT STATUS, cont
COSTBENEFTI' ANALYSIS, cont.
A cost benefit analysis for the flood protection project was prepazed by MAC and accepted
by the Federal Aviation Admiuistrarion (FAA). A rario of 1.0 or better is considered
acceptabie. The current cost estimated far the flood protection project is $26 million, having
a benefit-to-cost ratio of 1.13. The project cost would have to exceed $29.4 million in order
for the ratio to drop below 1.0.
The floodwali and airfield safety enhancement project will bring $20.1 million in additional
federal dollars into Minnesota. These dollazs come from fees paid by aviation users, not
from the general tas base.
• The St. Paul Downtown Airport generates $112 million annually to the area economy and
sustains 853 full-time jobs.
FUNDING
• On February 7, 2006, the FAA provided MAC with a letter piedging $20.1 million to the
airport improvement project.
� • The FAA funding, together with funds from the Minnesota Department of Transportation,
3M, State bonding, and the Metropolitan Airports Comxnission, will cover all costs of the
aixport nnprovements. Although St. Paul benefits economically from the airport, the city will
i
I
J
�
i
J
i
�
�
�
C�
bear none of the cost of the improvements.
With the FAA pledge in hand and support of the State and tenants, the MAC Commission, on
February 21, 2006 approved proceeding with the airport flood protection and RSA
improvements.
' Updated 03/28/06 Page 7 of 19
' "
�
�
�
�
�
�
1
�
�
�
�
' }���1
'
�
'
�
'
1
B P!
" r ` �
06-363
�
�
�
�
�
�
�
�
3. PRO7ECT HYDRAULICS
Qb-363
This section provides information on the project hydraulics and river modeling.
100-YEAR FLOOD PROTECTION
• When the removable portions of the floodwall are installed, the airport is protected up to a
100-yeaz flood event.
This protection is no different than what the city has previously allowed numerous other
property owners along the Mississippi River, including itself, i.e. the City approved removing
Harriet Island from the floodway which resulted in 0.05 feet of increase to the 100-yeaz flood
elevation.
THE MODEL
� • The computer model used for this analysis (HEC-RAS) is the model used by the Department
of Natural Resources (DNR), Federal Emergency Management Agency (FEMA) and the U.S.
Army Coxps of Engineers (COE) for river modeling evaluations. It is not MAC's model.
,,
�
�
�
'
�
�
�
'
• The model was calibraYed using actual data gaYhered in the field during the 2001 flood event.
• Barr Engineering is the MAC's hydraulic modeling consultant on this project and has been a
consultant hired by the City of St. Paul over the years on similar projects.
• This same model was used by the DNR and COE to evaluate City of St. Paul projects such as
the Harriet Tsland Improvements, Raspberry Island Improvements, Shepard/Wamer Road
Improvements, Wabasha Bridge upgrade and St Paul's Upper Landing project, to mention a
few.
AGENCY APPROVALS (3)
• The following agencies are responsible for evaluating river hydraulics. They a11 have issued
letters to the MAC with comments and acceptance of the Mississippi River hydraulic
modeling submitted for the proposed project. This was based on their independent review of
the information submitted by MAC.
1. U.S. Army Corps of Engineers, 7uly 22, 2002
2. Minnesota Department of Natural Resources, August 12, 2002,
3. Federal Emergency Management Agency, June 14, 2005,
' Updated 03/28/06 Page 8 of 19
�
�
'
'
LI
�
�
�
t
3. PROJECT HYDRAiJLICS, cont
NO IMPACTS FROM FLOODWAY CHANGES
06-363
• Structures upstream of tt�e airport will experience no increase in water levels for a 100-year
flood as a result of this project. The compensatory excavation will widen a portion of the
river channel to offset the effects of the auport flood protection.
• Compensatory excavation is a routine strategy utilized by the COE and DNR over the yeats
to offset changes in the flood plain, i.e. South Fork Zumbro River, Rochester MN, 1987.
• There are no backwater affects on the railroad yard/east over-bank azeas caused by the airport
flood protection.
BENEFITS FOR LESS THAN 100-YEAR EVENTS
Due to the enhancements the project will make in the Mississippi River channel, there will be
reduced flood impacts to some upstream properties during lesser floods below the 100-year
frequency.
,
VELOCITY
,
t
IJ
'
,
'
�
�
�
• The m�imum 100-year flood river velocity increase, according to the HEGRAS model, is a
modest 0.5 feet per second (fps) inerease along a short portion of the east bank from 3.6 fps
to 4.1 fps.
• In comparison, the velocity at the St. Paul Pioneer Press building wiYh or without the airport
floodwali in place is 5.1 fps with a 100-year event.
• The airport proj ect actually reduces velocities at the east bank during the more frequent flood
events that aze below the 100-year flood elevation.
• According to the COE, the segment of the east bank sheet pile across from the airport
contains underwater wing dams which direct flow into the center of the channel and away
from the east bank. The COE installed these to increase scour and reduce the amount of
required maintenance in this portion of the river channel.
• The computer model likely overstates the velocity along the east bank as it does not account
for fhe submerged wing dams.
Updated 03/28/06 Page 9 of 19
'
�
�
3. PROJECT I3YDRAULICS, cont
� �
� �
06-363
FREEBOt�RD
� • The proposed pro}ect has been designed with the minimum amount of levee height required
to protect the airport against the 100-year (1 %) flood event, based on FEMA's criteria
� outlined in the Code of Federal Regulations.
, • Freeboard is a factor of safety intended to compensate for the many ui�laiown factors that
could contribute to flood height, such as wave action, stream obstruction, lock and dam
operarion, and the hydrologic affect of urbanization in the watershed.
t • Freeboard is not included in the calculation of the design event since it is only there to
provide a factor of safety.
' • A 2-foot freeboard is proposed for this project. MAC will comply with FEMA, the COE and
the DNR requirements in establishing the final freeboatd height.
'
,
,
'
�
'
�
�
�
�
� Updated 03J28/06 Page 10 of 19
�
�
� 4. COMPENSATORY EXCAVATION
' COMPENSATORY EXCAVATION
Ob-363
• Compensatory Excavation involves "shaving" material from the west bank of the river (not
' the bottom) along the southeast edge of the airport to provide increased carrying capacity for
the channel.
1
C
'�I
�,
'
�
�
�
,�
C
'
�
'
• The additional channel width accommodates the water from the airport such that no upstream
impacts occur when the airport flood protection is in place.
• Approximately 165,000 cubic yards of material will be removed and properly disposed of in
accordance with permits by a contractor experienced in this work.
• The U.S. Army Corps of Engineers (COE) removes 10 times this amount of sediment from
the river channel during a typical season of channel dredging.
CONSTRUCTION MONTI'ORING / DISPOSAL OF EXCAVATED MATERTAT,
• Agency permits will regulate the construction methods according to established standards.
• The contractor will develop and submit for approval a Testing and Disposal Plan prior to
commencing the excavation.
Based on extensive soiis informarion gathered to date, it is unlikely that contaminated soils
will be encountered in the compensatory excavation area. Additional samples are being
gathered in early April and wili be used by the MPCA to foxxnulate final permit requirements.
If contaminated soils are discovered, they will be reported and disposed of in accordance
with agency requirements.
TiJRBIDITY / SILT CURTAIN
Construction Documents will require the contractor to install and maintain a Flotarion Silt
Curtain suitable for river channel flow for the entire duzation of the compensatory excauafion
work. This type of protection is standard for work conducted in waterways.
The silt curtain is an accepted method used to contain the excauation "plume" witlun the
work area.
' Updated 03/28/06 Page 11 of 19
_
r
�
r
'
�
�
'
'
'
�
'
�
'
�
�
i
1
I
4. COMPENSATORY EXCAVATION, cont
SENSTTIVITY TO SEDIMENT
� �
• A sensitivity modeling analysis was done on the proposed compensatory excavarion area
which indicates it can tolerate a luge amount (up to 8 feet) of siltarion/sediment before
causing negative unpacts to the flood protection hydraulics.
• Many factors affect how much sediment the river carries in any given season, such as
development in the upstreun watershed and precipitarion/runoff quanrity and frequency.
The compensatory excauation area will be monitored in accordance with permit requirements
to understand how the azea reacts to the river hydraulics. Frequency of monitoring may be
adjusted subsequently with the approval of the regulatory agencies based on hands-on
experience.
CIIANNEL MAINTENANCE
• The COE and DNR have reached verbal agreement on a compensatory excavation
maintenance program to be implemented and paid for by the MAC. It will include
soundings and cross sectioning of the compensatory excavation azea to monitor for silt
accumulation.
• MAC will be responsible far removing silt and sediment from the compensatory excavation
portion of the river channel when needed.
• Based on the sensitiviry analysis, the COE has stated they believe, "... that frequent
maintenance dredging will not be required."
• The edge of riprap, which lies along the compensatory excavation, will be planted with
vegetarion acceptable to the City and the other regulatory agencies.
� Updated 03/28/06 Page 12 of 19
St Paul Downtown Airport
Proposed Grading Cross Sections
Showing Excavation A and Below Normal Water Level
—�.•__ _._ ' ., __ � '{�';�
.. ...,«. . R.. .u. Q 1) '�`��� ���1•3
. . � � f Q Q `a� A ,�
P *wv e � � "
me �e v�«�i�... r,sa�..i � =i
I .._ g c � . � _. .:., g..
a
;oo ___ __ _"_'_____________� ;oa : .
� P e�o�a -�— —
s . .o . � - , eso �
Ee� � 68� � � ' . �
xorm.i W.iterliw 6Hl('.�
6>U �
]0 .
� o0 0 �oo zoo aw <oo soo �o� �
...,t� � _ .. . ..._.. --.-,-R . '�. . .. �
, �. . . . . . _
y B_B
� WY+Ea .�, -�
200'LT OrJ�ir' J !�LU 169](' �� s�
G
>00 � K `
_ )DO �
. 590 Vroposvtl G+ounJ� t 690 '
•O� _ �
: 68U Narni�Wateilivc�fi87f� I -68P h � .
� ��� � �� ` �1
OO 300 c0p i0� 600 l�0 800 900�
�,.�:�%_ �__�.`.��... . � � .�.�__ _. ;�*:i'.�;.+'._-'�t:_, �.. � ; , . B
' C'C . �n �?.
' Pral�oaetl
wYE OrG��. YH�9FWala�LCVC164]1'.
\. � EFSt'�9Gra�na\ __ ___ �00
` G9� P�o�a�eq Grountl ti90
'.. }
�. 660 Nai�a Wa�rr4vc 68�! - 1 �' �� � 68�
6�0 Glp
�'100 200 300 400 5U0 4 11 0....���.
�. . �..___ 1a'Y ..SV.*A .�.�� ..
D—D `
� �,o�
/' °°
F!10 . P P. G tl� � "9� .
0����na�Y L ll I
' 680 . Na �[ciLivi 68'/l' 1 � ��j��-' ti80
610 . �. . . l ". e'!0
� 300 2p11 10O 0 f00 200 0� <00
♦ �. y "_. . . . _ . . ..
..._- �� rt� •=:t�, °� �z�
�:�
�- �:
I
N
p h
��c
�
�i
o x
"� ` ±r
$�*^
�� � ,�j
L.. �}
�� �
«
�r
0
(
� I
/�10
5
r
� O
� y 53 �
d,r'
f �' �
t �
.. . ` :� � 2
i-
II
. ` �� N
N
i� �
Q ;' .
�
� :- } ��q:f .. .
� 1' .}
b• �(
� �`
�� ��� � � . � D
. .. "��f:%'.N -.s'Fa.�y:.�y�.01v'l.�
V V - > O �
'
'
C'
�
L
L '
�
5. NO RESULTING AIRPORT EXPANSION
LIMITED DEVELOPMENT POTENTIAL
• The purpose and need of the floodwall is to protect existing infrastructure, not to eacpand it.
• The Airport use is naturally limited by the lack of developable acreage at the facility, whether
the perimeter dike project is completed or not.
• The proposed project has no impact on the hangar storage space or capacity for additional
based aircraft. Of the remaining azeas available, there is space for about a dozen hangars,
only half of which would be in the area now troubled by flooding (see attached graphic).
' • The St. Paul Downtown Airport (STP) has only about one-sixth the acreage of the
Minneapolis-St. Paul International Airport, and neazly all STP's developable property is
already fully urilized.
,
AIRCRAFT OPERATIONS
�
�
u
�
• The floodwall will have no impact on the Airport's size and chazacter.
• Aircraft operations at STP have decreased by neariy 60,000 annual landings and takeoffs
since 1990. The number fluctuates both up and down annually driven by the state of the
economy.
• The latest general decreasing trend stems from the economic downtum experienced in recent
years, regulatory restrictions on general aviation aircraft imposed following 9-11, and
termination of a federal program that paid for military veterans to receive pilot training.
� • In 2005, there were approximately 130,000 operations (landings and takeoffs) at STP. The
long term comprehensive plan (LTCP) prepared by MAC in 1992 forecasted operations to be
at 226,000 by the year 2010. Given these recent downward trends, that number will certainly
, not be reached. The draft update to the LTCP prepared in 2000 had revised forecasts,
showing an increase in operations to 192,000 by the year 2020. This number, even if
reached, does not exceed previous operations at the airport in the 1990's. Since both of these
� forecasts were prepared prior to 9-11, MAC is anticipating a new update to the LTCP and
forecasts for STP would be started in 2007.
� • Similar to the past, it is expected aircraft operations by both based aircraft and itinerant
flights will eventually increase again, but wiil be influenced by economic factors, and will
not be dependent on the construction of a floodwall.
�
� Updated 03/28/06 Page 13 of 19
'
1
�
'
t
�
'
'
,
�
�
,
'
'
'
'
,
'
5. NO RESULTING AIIiPORT EXPANSION, cont.
RUNWAY LENGTH
. . . . :�
Ob-3b3
• Upon completion of the project, the longest runway, 14-32, at STP will actually be 202 feet
shorter than it is today (6,7ll to 6,509 feet). By comparison, the shortest runway at
Minneapolis-St. Paul International Airport is 8,000 feet.
• Runway 14-32 cannot be expanded to the north due to conflicts with the railroad property
and airspace conflicts with buildings and barges.
• Aircraft cannot operate on the EMAS arresting bed.
NO LARGE-SCALE CARGO OPERATIONS
• For a typical lazge-scale cazgo plane to take off fully loaded, a runway of at least 8,000 feet is
needed, far more than is auailable at STP.
• UPS and FedEx distribution centers and sorting equipment aze located at the Minneapolis —
St. Paul International Aixport. These companies have invested millions of dollars in
equipment at MSP. It would be impractical and counterproductive to fly cargo into STP,
truck it to MSP for sorting, and huck it back to STP For carriage to its destinarion.
• FedEx does have a number of single-engine super cazgo masters which could use STP even
today like they service numerous other short-hop destinations.
� Updated 03/28/06 Page 14 of 19
� ���.s. � � 1 ' . .
S . �.WNTO�N[� ' ,
�,.
� � . �� � � �: AIRPORT B #f AREA-� `�
"":. �� �,� a �� ,,. _ � r� �: �;
�'� ,� � ��: ~ \'f�...._ .---." • i �k
,��, „ -=�� � - c � .,� e. ,� � r' ,.f
rK �. �� : ��� °'�
a ` .`� � ' '� � �, '- �",.. .
� a - �,,. '��� �<., , ,n
� 3r' '� _ , ; ",� ,.
,•-
� M /
� s�s .�r� "'�' ��r- �ii � r' �; -. .
�.� �. �' �� � ..-•�-� • � 'i4i � ,.,i % '� �+,`��
_• y a 1 ���� � �
�4':. � �� '�-- '.r��"` - � 'i%%%%%;; �i�, %ii�° y "``\ � A �,,,��:
�,; �` .� - .�,... ,. m-^�-�,.,�/p/ %//� � � e,, � .
��� �� ` Y �'� � ' �+ ///' � /Q !"'/ �///jj�/�'� • ��'L,�� �.
+• , s •' c.s..,,�.,sr ��i �/� /� h
F '� � b � � fi / x {� �.
h � V Y � ,//� � � ',�YA\ � .� .
^:: � i /`! \y\y�
4 �`�( tk .� 1 �y W
F `M1� f U_ / l � S A ���
� '�� t �' ������ , e "� ;% � �
� � �� f � i :i� i: . ° , ���/T� �c x �.:
.,:& / � ti ( '% y �� -+
� "� Y v+"' � �� � ... � % �, * 1' , � � a.. •, t,. �i �
//�
y ° '" aa �� �+^_.. �J�ie:+& l. �% t ai��//�l1 �' �\a.
' �a � �� �j�' /�% �'�'�` � �`�j%%%�: � `�`
,�� . w1 , � ' ,�7 % ' �� y `� 1 � '� '�'/��',..�` �:
„ � '^ %/ ; �; �'ti „'�,�' \'�
��l � �sl� �✓ ,; � ,�, �, p �r� �� �
��- �.��i � <al i�r � : _ .!"i' �` _ � �t �
' i �� >, � `� i �
�� � �
�` �� �'�_ � � ,: �.
�� , p � �j � �:�� �
� :. �'� �` < . 'yi�, f ;, ��' s � ;
t . ` "� l�� �l/li� '�b v
r " ,y � �., �� '�I i f/i'� �,�^'� � . �.:.. �
. �"+�. "",«. --.m i., Jh ��� y � g. y. 4 . '�
. M �
y p i v
s 'y s i � � Q � / j /}/ %�/� °�'� �� �
♦ w�
� .e"S r �,'Y �;. '*r � �%d f�/� � F/ � .
. s Ya � aW ,. � , � �j�\ ���. � � � �
r�� Y $ � � /��/ � ..�. � _ �
x� �
/ �� �$}; �
_ �� / �j��T S + �ly,. �: X Y��
.�-�,� f \ !4 ;, W �i�� /�/ , ���� .� �
.. �� � ..':� Y� �� -\ ^!�•'%/`j/'%�"'1'�f5°. ��" Y £� , `d
.. � � f` t � Y '%////� . � � � °s�q
, . « �` ��;' �``` ' I. =
_ ...x., � ���c �' w � `�.��
... s. �tw�� . �
:
'� � 't��: .' �-,� �. ' � — ��....
..,
e . , •.� _ , 9► ' ' _.:, _
, . ,
'� � �:�
„
�/ � ��
� j jj� HANGAR AND RAMP AREAS i!� . K� .�ti'' � .�`��,\ �*a� y `�� �-
. ��,. ° 1 �. ;.��..-.
y p ! R q .
l . `<
M UNDEVELOPED HANOAR AREAS �f ; �. ,,,. . + --���
- (Below 100 Year Flood Elevationl �,�� , �t#, ��
.
.'' � , � �--'-�—' ,
� � �
,
�.Q
.. � ;
_ � � .. . .. . . . .:. , t , � ,,. , �� � �
... , _ c,. . ,...- . . , ..� . : . .
. . . ., ._ _ . . .., kr .. ,. ..
, .: . .. . , �. - .
. . - Y.... ., ' . . . ' ^-. ...' i.. s ` +.: �1'. . ..�. . . .;
, . . .. �� - . "
. ... . .�.. . . .� . _ .. .� .`..... � �� .. .:Y-s �.\�s'd._
�
�
�
�
'
,
�
'
'
'
,
�
'
'
'
,
'
�
�
�7
� �
� �
� O
Q Q�
� �7
� N
-�--� �
� �
LJ Q�
�
� O
Q- �
y � L
U� i
Q
�
�
�
�
�
+
06-363
�
0
N
�
O
O
N
O
O
N
N
O
N
P
Q
0
N
O
O
N
�
�
�
W
6�
t3�
�
�
�
CO
6�
6�
�
�.[7
6
�
�
M
6
N
�
�
6�
6�
O
6)
6J
�
�
�
�
�
6�
�
L
�
�
O O O O O O O O O O O
O O O O O O O O O O
O O�O C�O � N d W G '�'V N
N � � �� �- r
suoi}eaaa 0 ������! tl
'
�
�
'
�
'
O6-3b�
6. COMMUNITY CONCERNS & ENVI�ONMENT
All of the items included in ttris secrion were discussed in a series of ineetings convened by Mr.
Crregory Page of the St. Paul River&ont Corporation to discuss the project elements,
environxnental issues, and permitting status. Attendees included representatives from the U.S.
Army Coips of Engineers, the Department of Natural Resources, the Miuuesota Pollution
Control Agency, the National Pazk Service, the Friends of the Mississippi River, Ms. Anne Hunt
from the Mayor's Office, City of St. Paul Pubiic Works, and Tom Dimond (advocate citizen).
AESTHETICS
' • Considerable effort is being made to ensure the appearance of the sheet pile wali does not
detract from its surroundings. The sheet pile will have a zinc-oxide, earth tone coating
similar to the type used on the Eaton Street floodwall.
�
'
• Existing irees and vegetation will be substanrially preserved and will largely obscure the
sheet pile wall from view (see attached renderings). MAC will plant additional vegetarion on
the walI to enhance tha aesthetics.
• Since the meetings with Mr. Page, MAC has revised the alignment for approximately 2,000
� feet of the perimeter dike sheet pile wall and Bayfield Street to further maacimize the amount
of existing vegefation to be saved (see attached g�aphic).
' • MAC is committed to and has previously offered to meet with representatives from the City,
permitfing agencies, and interested parties to receive input on the revegetation plan. Since
the sheet pite wall portion of the project will not be conshucted until the summer of 2007,
' there is rime to receive comments and suggestions from these groups regazding the type of
vegetation to be planted as an enhancement to the existing vegetation that will remain.
�
'
C
'
'
�
l_J
..�
The environxnental reviews completed for the projects indicate no potential for impacts to
any bird species or communities. In addition, MAC will conduct further investigation this
spring to coiifinn there are no threatened ar endangered species of plants or wildlife in the
project area.
The compensatory excavarion is key to there being no increased flood impacts upstream of
the airport, including the east overbank backwater areas, during a 100-yeaz flood. Therefore,
habitat areas for the Great Blue Heron and the Great Egret rookery will be unaffected.
• The majority of existing trees and vegetation along the airport river bank will be maintained
in the areas where permanent sheet pile is to be instailed.
Updated 03/28/Ob Page 15 of 19
Ob-363
6. COMMUNITY CONCERNS AND ENVIIiONMENT, cont`
CONTAMINATED SOILS/WATER OUALTTY
• The attached map from the Minnesota Pollurion Control Agency (MPCA) identifies known
sites of environmental interest at and near the St. Paul Downtown Airport. The closest site is
over one-half mile away from the compensatory excavaUon.
• Soil borings taken in the area proposed for compensatory excavarion did not indicate any
contaminates above regulatory limits. Additional borings in the river and on the shoreline in
the area of compensatory excavation aze underway and the results will be reviewed by the
MPCA as part offhe project permif application for excavated soii disposal.
• MAC will conduct a testing progzam during construction in the compensatory excavation
azea. Disposal of any material found to have contaminates will be reported and handled
appropriately in accordance with all permits and regulatory requirements.
• Duting compensatory excavation operations, a silt curtain suitable for river flow will be
suspended in the river cl�awiel to provide a controlled area of containment for suspended
sediments. This type of sediment conTrol is typical for river dredging operations Yo prevent a
plume of material from escaping the work area.
MCTSSELS
• The environmental review process identified the slight potential that the Higginseye-pearly
mussel (L. higginsi) may inhabit the azea of the river within the compensatory excavation.
This mussel is on both the federally endangered and Minnesota endangered lists.
• The previous Mussel Survey conducted by the Ecological Services Division of the DNR
' show that L. higginsi were not found in the vicuuty of STP or in the adjacent pools surveyed.
It is not anticipated to find the L. higginsi or other mussels in this reach of the river because
of the poor water quality and unstable degraded habitat.
'
�
�
'
'
• Nevertheless, tlte MAC is committed to surveying the compensatory excavation area for
mussel populations as soon as the DNR issues a permit to do so. The DNR will do the
survey.
• If populations exist and require relocation, MAC will secure a permit from the DNR and
complete the mussel relocarion �rior to commencing construction.
MTSSISSII'PI NATIONAL RIVBR and RECREATIONAL AREA (MNRRAI
• The airport projects aze not inconsistent with the goals and policies of the MNRRA
comprehensive plan.
' Updated 03/28/06 Page 16 of 19
�
��
�
�I
�
,
�I
'
�
,
Ob-363
6. COMIVIUNITY CONCERNS AND ENVIRONMENT,;�ont
MISSIS3IPPI NATIONAL RIVER and RECREATIONAL AREA (MNRRA, cont.
„
�
• The MNRRA comprehensive plan recognizes economic activities and commercial use of the
river corridor. In fact, it states that airports pre-existed the establishment of the MNRRA and
are generally recognized as important contributors to the Twin City economy.
• The proj ects will actualiy enhance the diverse values of the corridor by improving the current
erosion problems along the river bank at the airport where the compensatory excavarion will
occur, and by maintaining most of the existing vegetarion and trees in the area of sheet pile
wall installation.
• The City of St. Paul Comprehensive Mississippi River Corridor Plan allows and encourages
the use of vegetation, soil bio-vegetation, and native plantings to enhance the look of the
river corridor. These techniques aze being incorporated into this project.
• The best views of the airport from the river exist at the southem end of the airfield. These
views will be maintained and even enhanced by our vegetation plan since this is the azea of
temporary floodwall. On1y during flood events will tlus area be walled off, and it is during
those same times when use of the river halts.
• The City of St. Paul Comprehensive Mississippi River Corridar Plan (3-14-01) includes
' initiatives to have a full length trail along both sides of the river. It notes specifically that the
trail in the area of the airport and Pigs Eye Lake is not planned to be directly adjacent to the
river bank.
■ I
'
• In October 2002, a small group including St. Paul Parks and the St. Paul Riverfront
Corporation, among others, idenfified a trail route around the airport that all parties believed
was feasible and is waiting on funding.
' NOISE
,
�J
�
i
{
• The 65 DNL noise contour, established by the FAA as the recognized threshold of
significance for noise impact, lies completely within the St. Paul Downtown Airport (STP)
boundary and noise compatible land use (commerciaUindusirial) even for the most aggressive
airport operations forecasts contained in the Airport's Long Term Comprehensive Plan.
• Single-event noise issues are independent of the flood protection project.
• From 2000 to 2005, total annual noise complaints at STP ranged from 9 to 103 with over
one-third of the complaints being reported from one residence.
' Updated 03/28/06 Page 17 of 19
!
�
�
�
'
'
�
'
Ob-3�3
6. COMM[JNITI' CONCERNS AND ENVIRONMENT, cont
NQTSE, cont.
• For that same period, the numbet of individuals submitting those noise complaints ranged
from 7 to 28.
• MAC has implemented and maintains several noise abatement initiarives as are laid out in the
STP Noise Abatement Plan and at www.macnoise.com/stp.
• The Noise Abatement Plan inciudes a runway/corridor use plan, traffic pattern rules,
nighttime prohibitions of maintenance runups, and &xed wing training in addition to other
items.
� • The November 2001 Dayton's BlnfF study fourid that aircraft noise events had very little
effect on the overall noise environment in the area. Community, or non-aircraft noise,
dominated the noise environment on a daily basis as measured at the monitoring sites.
tJ
�
�
''�
'
I_1
• Aircraft operators at STP have indicated construction of a floodwal] would not lead to
changes in the type of aircraft they use, which also supports the validity of the 2001 study.
PROPERTY VALUES
• The flood protection project has no effect on airport growth, and therefore, has no effect on
property values.
That being said, according to the Ramsey County tas assessor office, residenrial properties in
the azea in close proximity to the St. Paul Downtown Airport increased in property value
on average 7.6% between 2004 and 2005, 11.9% between 2003 and 2004, and 16.0%
between 2Q02 and 2003 (see the attacked table). This includes the West Side, Dayton's
Blnff, Payne-Phalen and West Seventh neighborhoods. Residenrial properties include single-
family, duplexes, triplexes, condominiums and townhomes.
• The Ramsey County tax assessor office documented that residential properties in the City of
' St. Paui at lazge increased in properfy value on auerage 7. i% between 2004 and 2005,
11.3% betwaen 2003 and 2004, and 12.9% between 2002 and 2003.
�
�
�
'
• The Ramsey County ta�c assessor office indicates residential pzoperties in Rasnsey Counry
increased in property value on average 7.5% between 2004 and 2005, 10.1 °/a between 2003
and 2004, and 8.2% between 2002 and 2003.
• Properties surrounding STP are appreciating at a rate higher than that of the rest of the City
and County and fherefore, do not appear to be affected by airporE operations.
Updated 03/28/06 Page 18 of 19
Ob-363
6. CONIMUNITY CONCERNS AND ENVIRONMENT, cont
RIPRAP / VEGETATION
The riprap river banks proposed along the compensatory excavation azea witl have vegetation
(native grasses) acceptable to the City and other regulatory agencies. Unlike a dam where
certain vegetation can be hannful to the levee structure, this annored river bank is not
required to be kept free of plants.
The vegetation will help to anchor the riprap. In addirion, the riprap and vegetation will help
maintain the river bank and re-establish its natural look.
1L�/ylYil\�ITy
• There aze no wefland impacts resulting from the proposed project.
The project was revised during preliminary design to ensure wetlands are not impacted. The
lack of ixnpacts to wetlands is documented in the recently approved Environmental
Assessment dated January 26, 2006.
Prior to the construction of Runway 14-32 in the late 1980's, the southern end of the airport
was wetland. The filling of this wetland for runway and building azea construction was
permitted and completed in the late 1980's. Only remnant wetlands remaan on the west side
of the airport neaz the bazge channel. That wetland complex is not impacted by the proposed
project.
' Updated 03/28/06 Page 19 of 19
�'� �,~
b�
i``
� �,+
� �
�+ �
L �
Q. �
L '�
3 �
o Q
_ �
C �
��
=a
�
a �
N �
s
�
'==-
�i
/�/
/�
C'
i
�
\
h�
��
o� �
o � _...:
rv�
�- ri:
__ __ _ � _
r� !
�
„+ �,�,;
.r��:�
C
k�
. ' � 5� i'�
. �,yv � � w ,� „
�
�^� . „
. � � - 2xo � ' ���G ��'� ���
o Ft
� � � `... 'W
. �
_ �, i . z +' " et
� i .�`" �' � ';n
.. ... . � � , ti ` f
°� O� � �
i
' � � , . .�+' ��
��� 2 �^ .
,�d�. F " y' `
� �, ;::
���� � , , n � � . . .
q 'r
P xQ .�.� ' � � .
�rr ` � �e ' 'vk�t . �
�a� ��.
r e��,� �,b9`N . .
� � � ��� e a� .� y � [ ; y
�rtt w ' 1 � ��N'� � .
y y GM�! ��, 7 .
/� / �
.� C
�
r � `
r � ' �, ' �d. � . j . .
`' u ,
, ,.
� f r ;,
p � , i
� ., d�` . � � . . ..
,,.;
- �; f
� ��`�
/ a p V W'
Jx �
�, ,„
� �,
�, ,, �
, ,
���,. Y � s �,�„
+� , � �
r r r
�� , , a �'�'
�
� ' '�'
.� �+
r A,� � �
,� � . � � � � ,
� ,,,
�" ,, ' / r
�� � 4 ���� '
k � ;r '
�'
xY , �r�,�„ . .
���+� � ��
,� ,�,
�` `°
t , r ; �
, ,
�'� , � r � 1
, ry��° r�
F 1 z d �r�
' � � �`$ ��� _
w� ^���?�� ��
�1
�� � d� �
y�,�a5� r�t� , �rSi� .. .. ,,.�^` � '�� �,ir'.
� � � r h �� .� . . _ __.w._.�� .i� �?� . . . . _ _ _.
Va�{ w:��,.��i .�4'tr � .
,M
, K
�� � v �
_��
��
xaa p0 �' � `
.e� y
+'� T � ..�^ y '�:,
ti �
. {h�. 1. 1.1� y 1
�N ��.
i f�
��S,
� � � `� �
+ ; _; �
�
�A
s
,
�• �-
��� r �
�
,
,� �
� � T;L _
i � �
� �
l�
I �l�n
N + �I
� �' '�
..,,�.. _ �� ,;
n ,��
� f '�
r �
t ��� � ^ „�r'
i
'�' (
x � , � �� � �
� � � ,:
f m �
�I�
. 'd � / �' � � , .
I ` '
l ('
�i
.,
��{� �
r ✓
��
t a �
r ���� � �
, - �
I
� �
, .,
;
I '1 .
__� � o
� "°
� � _�
.
_ �
` s .
._... . � �, .
.:r } . . � ' .' . .
Ob-363
RENDERINGS OF SHEET PILE WALL
ALONG BAYFIELD STREET
REVISED TO REFLECT THE NEW SHEET PILE
ALIGHNMENT
VIEWS FROM MOUNDS VIEW PARK AND CHILDS
ROAD
REVISED 3/28/06
�
t8"�� k, 4�riw," a`w—�: a�"� st"� � ,� ' z F r& §1 Yv �' �. �c '� .Sr?,S+fl" 1 4- " w - "F" x � r ra �, �� h e.�rv��µe �� kl
� "2zx k v r � =�'ka �, � m� �y �,d Z. :v^� �?'a� dw �'n� � i � m . � � = aa N4
� �
��� �
,s?aa�� � � Rw#,.- ^�.ibac'e ui - iY „� �� ` � .t:.' , r � e.. - ^4 +� .. �,� a�,s d
a
`�,. T ,�'� �eg� i `->.,�+n,:.$�.d "5� roR - > � "u��t2�`bA°:+�`,*�
� ��
w a. � �. s�°^ � �F
, ' ,d . �' 's�" ` � .:�� y
n 'r
.. '.[.r [ m 6 _�2,J' . ,. ' ` ' � w � �'
. ' - " ' .' ' ' , -
. '_ �. . ` � •'�
ay
�-'
y
�'
,
, .sY'n'.. ._.. � m . ��_. � ,... . . ,.n so-., e_ _...�. ,_ "' _ _ .. ... . .. .... . . .. r. .. .a_ ., . "'M . � . . ' . . __ .
� � . , _ . . .. . � < it _ , t �, r.?: .
i -
�• � .. - .. . . . r+:�- .1. '�.� ca f� �'. ' Pi or�`
��' � � . . \ . . . i �.v�. W a ,
�- ` ,
. ." , ,, " . . �.� .
. . � : � .. � .: � ` .
. . . .. . . • . rt '
. b- e 9
. . . � �. . .. . .
, ' . `-.. . ' ', ' `� . C`.:, . .�.' a `- a� � . i
' - � . - ' � �. r . �. � - "y' . `' �.�.
. - � , -. - � � c..�:
. r y
. � _ � -. '- . .. - •.� �
. � , ' � . �� J y .
. . , _ . . � . :�'
� - - _ . v> .'
, . . . � . . . ,'•;/_
_�d
� . � . =�"' _.
. � � - � ,. '° =
, � ����" � i.� . „�,�:
... � � ��� ��,:�," . � '�
�"� ' n.��
c J ' �.
. � '. : � "� uu}�, . .1 " � e. : ,'
, y , �
-� •.- � '� . \ � \ + .,:
, r
. _ $ - �s.e'Y,�. .`. " lG�L� ' ' �
. s_ � ��._ � �'e
� . . � �v� � ..� h . � � \ .' . .
` 4 ��. ' > `v �R � l �� J ( ��� r •_
. :. ' , y . _ . ..
. , .. � .' , ' ' � .
� � � ���
. . v
� �
• �
� � . . . .. . . , ..
� y . ...-.._...w � . ,�.. m-«... .
_.'
n
.. °. , �e .�_,.. ..w ....:. . . ....., , � . .'�. . .w. ... _a.,.v � `. . . _ „ . ,..
. . ` ,. - , . , t . .. . .�� .. ' . .
. � . , . , . __ ... �
, " _ � _
�� . � —e _r� .'.' "�;;w;.c�'"' �- xy„"��'" ,-�.��.,.,__:,�_, �--� � ,� . "' "'f''
�
-- ' � 5..2,�,.
,: , .. .� ... . .
.. ._ .. ,�.... _,., '�'.,�� v�.:_^ .v ::�y � �--tL, -..�-_ _
,, . u _
� . .....- .r�- ,._ ,. �
.... ��:- ��� � ; . _- S,S� ". : . � , .,. �. . � ,� .,., � � n ° �:.: C : ;i .. r��c '"'�*t* �'�^:��x`"r aR�`",. .� w,':: 4 r !* 'Y `i .x.: e a y ,..; .'..�,--m�±f.^ u'+e'�.�._.
� ' . : � . . � ,• :
.... , • �., u C . s ... ; _ ;n„y„✓�° Y' J �+m Y �.M. �. .S'. ..v�v A£... . . -+ ? `� _
* � '..�,* : �.-. ...... ,.. , - ., :a. cuti:':�`� , s:v �� ,..•:�- �:.w.k� u��.fi..kar���{+a@M"*2�M^� 1��:?'s ti,.,s.m5w �,ie.l,. jw!.`. h�^^.-n�.._.
' , y � �/T _.nC , ` � . . .; i 3 $�„., ::. 3�.�"LU� Ao-r P.._
�. , , ._: , ,' . � . , � s .
k ... . � < I, . . .... � '. .. , .TC��+Ye �. " 2 � x �{�t � 4?.
y� _
-�+ ^:
v..
` ' �
o :
-�.,..:�"'v. " ���,..,_�._ ,..- .�.a-e.:;. ; ' . .�.' ;: . ..
.. . �"" . - Q ° , .
` r�
- . . _ • w� FIR..__'.%ic'.-- -: ,�u� _�""
� � _ �.,.. . - . .n �.,.,,�_ .
� .. ._ � . . .. � „ ;„ ,r
�, _ �.. . ... , , - . � ,; , , -
v -
� a . , , '.;, ' _ � ' �.
.,_ . . . :.. . , . _' "
t . . . � . . , , . .
... :,, .� . �:. .. � . ... .� . .. . ...:,� '
::MI-A-
� ! . � � . „ . . . � � _ ." _ .
.; � { . ,y, y` �� T j " T .
j A f � '}, ��� 4 � t, �
�. Z 'J ' , iv"^inp � . 9 �'X�i`^fTl� Y`"�Y 1 : .
. .� � [ C N' . lm �� '. �f F Q � }-uf a�.�f g .. . .
F � q ^
V
' �.rr�.�, r �� 5 �� ��w4 �°' . � .
��.'-` ^a \ °� . � a �*•g " ' .
s,�a e �.�z'�? j � ,
,. - ._ - . : i-� t ��. ` � �. x� �Y.r..x,t��t``'*,�' .�"•cs �'�`�` . t _
_
„ ..
� .�.. ._ : . . ' �,: . . . � , `. ' . _ �"9. - hN . . .
,�
` .. . ..' . _ • " : :.• �,�� ' .�! . .a .
�.
�:. � .i � . `.
_ � ..:. . - ` ...� .:�� : . .::.. .'_ .. 'I ..'< . � .. .
. ..-- . ... __ � . .:'. '. '. -..�,: '. ..- - �. .�.::
� - . . . _ . . . _... ,.._ . . -
� � � �
. �. .. - . . <. �. , , . , . ' , . . .
� . . -: � ' . ' :
..
.,
. . .. ` { � -� :�. . .-. -'. . .. - . . - - . .
\ . ..
- -. ..�� ..- . i . l
..� . . � . . . . .. _
. . .. �P . .�.. . . . _
r'
. .. _ � � -. - � .�. .
� . _ ..�� . .... . .?�'.. . . , v . . . , � _ .ti' _. _
. . . . . ' ... " �.. . .� .: � � ..o .... .: � . � _
.. . . ; . t i��... e ;s . . ._ ' '- �- _
� -. . .` ... . �` .. �
'. . . . � _ . �.` :.: :. :. - � .. _ . . _ .. .
- ' :� � .: .:: . . � ., � - .. . . . . _
.
. �
.��. . .� . � . �..... .: � ...�, �. . . � . ... . . . .�
. .. ._
..
r
._. - . ..: . ��. .' \�w'�. � . i �'- .- . .: ' r �� " . . . . � . . - . .
.. � . .. � . . . . . � , , �
.. . � . .. .. �. . .. . . . .
.. . :_ . :: ^ n � � �:� �
.. .. . . . . . � .. . . .
�.�i � .. .-�. . .. .. .
1 �iy` • •.. ' .l' .L.� � . . ' _ . .- . F- vy . . � . . . - .. .
, -. . . � \ v: ' ..: . � t . .
� � . � .
F� t � ,. 4/-�:� �� . . ' - _ -. . . ...
t :-�^ .. � : . . � . . ., , .
t �i � �.��F. /(�:� �� ' 1 - _ ^ . .rv� � � � . � - . . .. . .. .
! l "' .'�.X �d'j�j'V� ��". . ... �� . i . . . . - . - ' ' . . _ _ .
-S y.\ � / . � ._. .. . � .. . . . ' .
/ � i 1� 1 �� / j\ .� . � . _ .. .. .
/ f �<"�. I�/ .t.\ '. � \ � . � , i. ' � . . - _
r ' 1 4 _ /� 1� � a .�
c �� � � f �i } ��1 �' �'' kY Yl � y � ,c� if� � - . " . - _. � . . - � . .
., 'y � 3 e � � �/� �7 F i � � H i A ' . _ _ . ' -�
/ � . � . .'_ . - ,
i �> > �,�{ l� � f v �� I s, �/ � �., �r . . , �. . ... . . . .
.. . �� � r . i � �, � � Y -. %.�- � � _: fi/� � � � � _ � � i �i'� . . .. . - ., . , " - - ' . . . .
— 3� 1 : � .. . , . , . .
. .1 t,�i� � � T � '�^. f ; 2''t � .%l` �Z\ r �. + �` KC i ��' � V� ,� � `. � ry E ��;�� . � - . � .
_.:' �� � � i ,� � ,� � � _.� ��J� � il / . !'r�/i / � . ._':' i �L ' � - _ � - � . . - t .
'� � � � .�- y 7 � .1.:_ . i a '; � � i ! y � ` . � `,l � . . � _ . ... _ Gi . � � : ,�� � � - :
"'ti,�. � u ��� i/ _:'c- i i � � � { � !� r ; . , � � ��r � � ' � � r � � - _ . . i:��. .
,
�, ,, � . . ...
-�- � � / �' - �E'� , , � . � ' - � ' ` �
�it �� 1 r � a �% � /T :�� �'<.' t �✓ ;� �. - � , � � " '' ��_ � ' ' ' _ � . . �. � _ ��
j = � - - ._— '`C ��, r � i � �V'� ,. i � � . . � - _� � (:�i:. .. .: . . .
'i� -'- � �� r � . � ��� � . � - . - . . .� . . ,
�� � �. / . _"i.% � � � � � � 4 ��'A+.,� . -�� / �.. r " ' '. .'� 1 �'� � . ' . -.�, � - . � � . ` � ' �,
� � l r- `- � � - � .+� �t;�.� . � i � � .. . - ✓ � �.� !�� ti 1 l � \ * �-.
; � :< __ , , .. , � Y �, � � f � � � � - ;� � .. � � � � � � i � f _ . . - ' t 1 � 1 � ��� j it , �: � �, �. -,-'� %�i` �, , ..- � � . �
_. � . ., I , ,. � � 4 , �, i /
i k '" . . � � . . ..� _
, � � � � f i\ _,. �X� < z3.- _ . . ' ' � � L�? �g �V� ; . i i � 1 1� � � � V �
�
" �. ._ _. � � .
„ {
- - ,17tii /� r. �.�� _— � p 1.. � /�:<� ��: 'f'�i,'s� � � ��.f��A���'�� ! /��(�� .'�
:F: 4:,
, . . ..,
^^°t:i
- _ �_::.-.�%:;
\
� ` _�
� B
��1
�✓�3��-�� .�
��M` �
1 '
' � pR t3� r �l X] i ] � y` .
/. �83..'I (: .� ��
/
` '
��
�`''� �' � _
: � � � �`�,.. �[
� k �l� C�
♦ � � / Y , �y��� r �� '�
� �'�i{�� Y ' s � x
M��"' �IF:L �r+' '� �
?� �` 'y� /' jc°`n �.. L .
� [.� tu. � � �T2�� 4. �.
� `� t` �/ f. �,d+ Y�. ,b r��!'.'�`K fi
� � ° � C �Y4 � +`�.. c1� �
r5 / i
1 '�- .
� $ � ;
-s � l . s ,r �' ,, r s <
�s � ? l,� .y� � � .,�-::
/ t ��/ �� .:..A3�1.
<
,_ ��� F � a f 6.
�� � 8 � � / .+� �� , Y ;tl K �.
l' �
/ � f /
�� w
> �::,] y
_ d
.. :�� ,3'�, ` " S i .
Y � � ..
r �� .
�� � >� 1
. {
� an
7 p � — p � /vr
1:_ �� '� �$�v��t� l.�.w � A SG""�'t.
�'�
�
(,'.: �.
�. ..':�
�e '
���� E
t��
��_ d�
a r
.�
�
1
'
�
,
�
�
�
,
,
�
�
t
'
,
,
�
,
'
Y
Q �
�
U
�
N
O
m
N
N
Q
T
C
�
O
U
a
d
N
�
�
N
U
7
O
�
�
�oRSEr s� w�tirrrEx cLr :.. '
Mr...GaryW�� .
Novcmher 13; 2p02
Page 2
06-363
•. Y
. ;
�pproxlmately four feet above tbe �port's primaty runwa ,
P�imaneh[ly installed psing earthen be Y Mosf of rhe dika would be
o€sand6ags to be placed across thE en�i of r SzCe1 P �� gs � ` P of tIie djke w
runwa s 27 31 outd consjyt
'rhe proposed dike � bcen considered and i�j�eted b M du� flood svents.
cletermination that such a dike u,o,�[d creata �oodin y A'� ln tF�e p�t based on che
� an � basis ofnowly devoio ed g� v io 1 ation o£khc state's f7ovdway critcria_
reveCSed qts pasition and concluded P modeling prepazed by $an En '
should also be noted that the absence of ilie proposed dike will satisf ���� �� has
adequately assess the va]idjt of e 'aodcl in tha �qW does no �} ��� t�• Tt
Y th results and the ituo impact of the praject on the floodplain.
The project wiiT also involve the destruction of a portion of a protccted DNR wefiland.
The watlsnd is in the �`win Cities corridor o
f the Mississipp; jZ1V �,�,h�n �yetlaufl a�ea �s scar,�e_ '
rL Z
Overvietiy oTl,egm! Reqqprements
�h� �inilesota En�ronman,4a1 poli�y,� ��p�� Tequires stats agencios to
environmental impact of ihcir a�tions. Min�,. Stat, §� j�p I 2002 .I
"YO force ag�nei.es to m ��" ��
bCfore xeaching their daci ions�'�No Power Line, �� v��s of Cnvzra � � It is designec3
Cou�cil, 262 N. W.2d 312, 3z7 Mi��rota � iro�men al1 erations
zbquized " w ��n• 1977), An �n�imnmantat 7mpact Statement� g ttl'
C l�ere �ere is a potential for significanE (� ) is
majorgovernmental aotipn ,_,,�� M�� Stat. �� effecis resuIiing 7from any
�AW or an EIS is required, the proj ect m�y no �o���easu�d. Za �Z002 .'
cnvironmental roview and no � ) IIl any case where an
process is co�ploted. Minx�. Stat. § 116D: 4, subd. 2b (20o2)u��til the
�oard �e ��Iations governing EAWs and
�Q��' �� �QB has estab[ished broac3 iSs are issued by �h� �nvj�o��f� Quality
governr,ient act�o,a ia sign3ficant enough to re �teria �'or dotercnining whet$� �e Proposed
R 44�0,1000, 4¢I0.2000 20p2 . 4�� thc p�p�tion of an EAW or an Eig, Minn.
44 10.4300, q 410.44pp 2 p 02 w In ccrtain cascs, a,� EAW or an EIS is mandato
( ), ltilo in othez ���s it is discretion iY Minn.12.
govemnler�t agency on its own in;tiative, M��, R 44I O.I100, sub� � c � b� ordered by a
petition. 11�i�. g, 4 q10.1100, 4410.2000.
p 3, o� in_response to a citizei�
� •
� C.
f
D.
� ��+e aec(ons coyeted by �pA inc}ude •'projeets w��o�ly e=p8rtialJy eonducrea, p r�
regulatad, or aPP�"ed bygovemcpental uni.ts, includiag tt�e g�dcral governnwht"� ��sisie tmx �
� � d, xnced �
Minn. Su�. � 116p.04> subd.. �
� .iy
DOASEY bt I�YHITI3EY LLP
Mr. GaYy War�en
Novatxtbcr 13, 2002
Pxge 3
o � - I .V �
�
,
(-
The EQB has issued regutations listing cha infocmatiou wluch it cansiders "the basic fa�ts
necessar�' to deterrnino whether aa EIS is requixed: Minn. Stat, § 11�6.04, subd. la(c} {2002)_
A� gA1�V is uscd to detemune whethcx an BLS is �equiied. Minn. Stat: §] 1dD.Q4, subd. Ia
(20Q2). Accordingly, t�e regulations pruvide that ai► EAW must address at least the foliowing
major categofles of information:
. idartifi�adon includizig projee2 nam�, grojeet proposer, a�d project locaYion;
• procedural details imcIuding identifiaation of the RGU, BAW contact pezson, and
�xisauctions for intorested persons wishing tQ submit comxnents;
. deseTLptiQn of the project, the ptupose of che pTOject, methods oFconstruci�on,
qnantificatiozx of physical chaYacterisdcs and impacts, projact site descri�lion, and
land t�se and physieai fcatures o£the surrounding area; -
� resouTCe pmtaclion measuTes that have been incqrporafed inCa t1�e pYOject de&ign;
. major issues sectians identifying potenfiaj environtnental impacts and issues that
may requite furthe�c investigationbefnie �lie pxAject is co�ntttenced;
• Imown goveramentat approvals, reviews, or financin,g required, a�pli ed for; or
anticipattd and tha status of any applications madq including permit conditiosu
that may �,avebeen ordered ar are being eonsidcred; and
. i.f the proj ect wiil be cazried out 6y a governmental anit, abriof explanaY�on of the
need for tha project and an identi5cation of those who wiIl beneftt from t1�e
q.
r
ptoject. �
IvIixin. R, 441d-1200 (2002) L'zkewise, the EQB has isSUad an EAW form �Q�taining 31
questions to solicit tlte "basic facts°' for environmental rcyiew' The Raspotisble Govecnment
Unit (RGLn is required to provide suf5czent i,nformation for each of the questions to pennit a
?'Ihe $pW Pam�tequlres info�natlon on the follow��g4p�ror ectcCt�ip�d appiovals requircd, land se c� � hon,
pinjeetlocacion,pxojactdesnription,pmjectr�gr7 P – — –
__�pes�fis6, vaildllfe.and ceulogitally sensiTlve ra§ources, pk�yeicnl im�atu ou wa nY tttource�s, �ace �ui
rcIazed ►and use managemenc district, wa�c surface use, �rosian and eedimentnrio wRkr i s� e ��� e �
tuaoff, wator qusGt�': weatawaters, geologic usaerds and saii conditions, solid wastas; h�zardougwaste3,
p�g� ha�fjc, gtenooury sourct air e�nissiars, udois, no1Se and d�u[, nearhy ce�ouzcu, visual impaet5, �
° compari6ility widt pinna and land usc xcgulations, impact on inY�astucruYe and publ[C Scrrices, cumulative �
impacu, othar gotential enYizonmeqCl impacts, �nd summury af 39sucs. ,
�. . -
_ _-. -�. -.-: -- �--...:,_:�._.�.:�._._:-���--
:,
O6-3b3
DOR$EY bc WXITN£Y LLP
Mt: Gary Wazren
November �3, 2002
Page 4
reasoued ciee�sion regFtrding whether "thore is potential for siF3nifieattt environmental effects, '
Minti. Stat. § 116.04, subd Za (2002).
Once the 8AW is appropriately developed, the RGtJ must flefecmine whetlter an $IS is
required. The eriteria used for determining whether chcre is a potential for sig�cant
anvironmental efi'ects are set fonh in che regulations as follows:
•. che cype, extent, and revexsibility of environmental effeccs;
• the cumulative potential effects oFrelated or ancicipated future projects;
�
• the extent to which tl�a environmental ef£eces are subject 4o mitigation by ongoing
public iegulatoty authority; and
� the extcnt to which environmcntal e�'c�ts can be anticipated 2nd con�olled as a
result of other available onvironmentai studies undcrtaken by public ageu�,cies ar
the project pxoposer, including ather EISs.
Minn. it. �i410.1700 subp: 7(2402). In order to conclude that an EIS is not nccessary, far thia
project the EA.W must pmvido "sufficxenf infoimation' to support a negafivc declatation. In the
Mar[er of�lmertcan Iron and Supply Company's Proposed ,Nfelaf Shredding Faciliry et. al. v.
Sraee ofMinnesora, et. ul-, 604 N.W.2d I40, 149 (Minn, Ct. App. 2000), Su�ci�nt infonnauon
is defined as "[s]ubstantial cvidence [wh'ich is] relevant evidence that `a reasonable mind migt�c
acaept as adequate to support a�onelusion,"' Id. A negative dcclaration wiil be hetd to be
aYbitrary "if it entirely failed to consider an important aspect of the ptoblem [orJ iF it offered an
explanation for the deciszors thaf zuns .caunter to the cvidencc• ." Trout Unlimited, Inc. v. •
�nnesvra Deparmtenr ofAgricukure, 528 N,W.2d 903, 907 (Minn. C�. Ap�. ] 995) revlew
denied (Apr. 27, 1995)_ MEPA requiTCS agai�cies Yo take a"hazd look" at the enviTOnmental
consequences of their proposcd actions. Minneaota Center for Environmental Advomoy v.
Minaesora Pollutioa ControlAgency, 644 N.W.23 457, 468 (Minn. 20D2). Wheie an EAW
indicat�s that a project may harni t}�a environment, but tfie agency issues a negative deolaration,
the ageney "makes a mockery oEthe �AW as s decisionmaking tool." Trout Unlimited Inc:.
supra at 909.
If thc RCrU detertriines tlie inforntarion necessary f6r� �easoned decisj,on sbout theneed
� for an ET$ is lacking but �ould Be reasonably o8tained, the RGU must eitli�r require an EIS or
postpone tl�e decision on t�.e need for an �IS in order to obtain the necessaty information_ Minn_
�. 4410.1700 subp. 2a (2002). �
� �
0+�-3��3�. `:..
['lORSITY Sc WH[TNEy LLp . '
Mr. Gary Watren
Novembcr 13, 2p02
Fago 5
I-astly, alkhotighmanyptojects present apoten[ial fnr siguifiea�t �vironmenfat ef£ects, _
an ETS is not �quired wherE t}�� e �'�� �e subjaet 4o rturigatio� - See Mlnnesata Genter for "
Environmental�dvocrzcy v Minnesotq Pollution Cantrol A.gerzcy, 6�{4 N,l�r,2d 457, 468 (Minn,
200Z), �'herefote, the extent to which the cnvirot�}x�enial effects are subject to mitigaGon i8 a key
questian in matt�zs of e�srimnn�entaj rey��,,
IIZ. An EIS is ZZ�qufred bue to the Pot�pfial fnr �'�poding and Wetland besttucHon
A. The poEepEial for Iilooding
Tf oozlstructed, the dilte may chaiu�el waters during floods an,d xaise the high water IeveLs
especially'upsReacu fi'om Holman Field. To mitigate against tltcse potential impacts dtuing
�7oods, N�AC rcIies oxt its engineereng n,todel arid 25SOCiaKed G2nk �xcaVation�. The cozifidcnCe
placed in these strucfurea is based on the results ofBarr �ngiueering's analyais, This analysis,
howeve,r, appears to bo ineompiete.
It is undisputed that tha pzoposed dike creates a signlficant risk o#'flooding. The
prnposed flood contcol project has been wnsidcred and rejeeted prevkously by MAC, because it
would not mcet the state's �loodway criteria. fiow��r, o � basis of a newIy developed,�od�i
prepared by Barr Hngineering, MAC has reversed its po$irion and conciuded thaY the proposal
vrill safisfy the state requircinr,ttts, T,n doing so, if has failed to.consideC the comments oh the
modeling provided by the Axmy Cozps of Engineexs, which call into qexestiop the Bazr Repori,
In a tetter dated Julq 22, 2002, the St. Patll pistrict o� tht Artny Corps.o£Engineecs
(Cocps) raisod qucslions regarding the va]idity of the p�oposed anajyyis, '�ith segptct to the
cah'bration changes uscd in tlze model, the Corps uoted thaC tt�e "changes start at cross sec6on 51,
whiclx is substantially do�vnsfrean� of the Sk Pau1 city liva[" Letterfmm J. Badlen, Sr. Paul
17istrict of the tirmy Corps ofEngineers, to T, tLfcDonald, .8arr ��eglne�ring Camparty (July 22,
24�2). Tha Corps axplained that 13arr failed to use data regatding the upstream sections that was
develop�d i.n 1949 and its use "would likely.result in base flood pro�los differeni than what was
submitted " Id at 1. The Cozps also Taised speciftc guestions tclatiitg to the cati$rarion results
for sectio� 69. Id, at i. Accoidingly, the Corps indicated chat tltese calcuIations should also be
� icwed using the pzoper data. Crl. at t.
�.
7'he Corps also questiohed the charactorization-oFthcproposaCa " gradingln t'�e vicinity
ofcrpss sections S�and 8fi through 90" Id, at 1. As the Corps explajned, `°[a] ravicw ofthe
ctoss section tnodifiealions indiCates the `gcadit�g' is actually ri�ht channel bank excavatiomtt�at r
is relaUv�ly significant at cross sections 86, 87, and 88. ,,. It is likely that this oxcavation wou]d • G
- equize a Coips p"etmit" IcL at 1, t�,Iso, the Corps explaiiled ihat `tnessures m:uat be taken to
:nsure �e banl� doas not erode:' Id, at 2. •
��
� `
�
� �-
�oR55Y St W7 LLp
Ivfr. craiy Vwat
IVovembeY I3, 2002
Page 6
�b-363
:.
Lastly, tho Coxps aloo noted disctepancies regarding the data oxi the top elova�yo of ihe
diI�e and stated the data fzom the madel is.dependeut it� patt on the cha�inel bank being excavated
and the dike havizlg an elevation no higher th2n 7Qg.Q� "7f afthet of these elements is change3,
the modeling mtut ba r�odified to i�ycludc ihe ch&nges ana ih� i�p�t reevaIuated," ,jd � 2
Ratlzet'thait addressing tho signi�cant issues raised 6y che Coxps, ti�e EAW simply and
erroneously asserts; "T}ia DTTK anc� � C�E have reviewed the revisod model a�d concur wit�
its assessment of the effects of the prpposed proj ect (0,63-fqot maximum increa�e)." T'tify ;
posifion cicarly nms counter to the facE�, The Corps cleaT�ly spccified thst there Was additiorial
work tv be dor��,
Ot1 the hasis o�the aboye, �ieTe is rio substanlial evidence supporting tlib affec{ivoncss of
the proposcd mitigation rneasures. 'Iherefore, an ET3 is requircd, _
8• The Proposal for Weflauds Dcstructioa
Under cliepxopostd pzoject, the MAC will fill a porti6n of the exlsting 20-acl'e �yotIand.
�'his aetion will presait a potcnciai far significant environmcntal effecfs, sa theprojcct reqnires
an EIS. See, Minn, R 4q�10.9400, subp, 2U. The EAW also fails to consider compiiance evith ihe
Mississippi Nationai River and R,ccrea�ion Are$ Comptehensive Managcmont plan as.rsqnired
bY �� �QB regulations, atid is therefoFa insufficie¢t to support a na,gative declaration.
Th� �1AC propoeas to fdl a portion of DNIt wetlands No. 62-3 near tFtm southem
bouztdary of the aiiport, '['�� ��ti�r dCSCrib�s the proposat as follows:
The propased project witi �lt about 0.85 acres of the
approximateIy 2o pj� �yctland No. 62-3. This is a type 3-4
wctla�d at the soutiiem houndary o£the Aatpor� west of Runway
14-32. The amomlt of replacement acreage wiJt be provided in
accordance with th� bNR and COH permit requirements, xhis
wetland comprised appmxiznately 86 acras in 1979. 7he
construction o�thc Runway 14-32 Now Building Area 4n the .
l 980's filled approximataly 66 acres, � lias beerz repizced
elstwhete in the Metro Area.
--- -- ----- 1�t1C; �rivironmen�l �4ssessntent Wpr7rsheet.• Flood 1'rolection, St. ,Faut Do� Airport --
(Xolmarr Fietd) at 9 (Oct. 2002).
� Ic is iu�disputed that the project pr�sents a potentia] foY si�ifzcaht environmental effetts,
and tha only issuc is whetha the ��arm is subjeet to r[utigation. MAC contends that 6y
�onlplying With existittg regulations, and creating weeland elsowliere in th.e area, the harm v� be
� 'II': CY wALY6Zi
November t3, 2002
Page 7
--�
.. ,-�-_-:- �-.___ _ _
_- .. :�.
I?OFZSEY ti, k L�,p
i
0 � - 3.b3
mitigatect. I�awcver, wctlands in t�t M�ssissi i
2gaenst publia policy, Ther�far cre �'p ��'cr eorzider are scazcc and dc �-
Twi� Cides corridor af the Miss ssi a�„ Wctlsnd elsewhcre ' �� ��e� is
PP or. �"�i 12 not mitigatd th� harm to the
Zn. I98$, Congzcss Es�blished tho jyjississippi Nation2I 12iyer
part of the national paxk syste�ri, `<Lt]o pYOtect, preserve znd enh and Reczeation flrea as a
waters and Iand of the Mississippi 2?iYer Cortidor wifhin the Sa.intpaul-���caat values ofthc
Matropqlitan Area" I6 II S.C. § 460zz. Congress estabtished the Nlinneapolis
Coorciivating Comr�aission to develap a compreltens'tus plan tn G Mo sissippi �iiver .
16 U.S,C. § 460zz-2. 1'ursuant to t2re law, the Comtnission has issued the�ll�ssissi
Itivcr and P�Pos�s of the law.
Recreation Atea Cornpre�ensive Mahageutent Plan laa . F?Pi Nationa1
�SO Tnangffe�ent, thc plan caiis for "rigorous°� protectiorc of wet� as� The�pl� n& �
specircallyprovidcs: � ,
F2oodplains ai�d tvctlands are listed as sensitive rasources in this
Pian and ate a hig}i pri�rify �or nrotection in the �umdoY.
�ery impottant areas ��reducinQ rhp a d w ,.� F F — T�aY�e
rn.aintaining weter ualit � " '� r noodr
visuai varisE q Y, Pmvidingwildlife habifa�, pitsetvirig
Y° �d �za�ntgining bioIogicai diversity, e should
be reserved residre and iac ed in ccotri r. They yyi�l be
protectad and e��ycetl by it�cteased educatiozt effolts, open sgace
acquisition, przservation incehtives, voIun[aryprp��s, and
rigomns implanientation of existing statc and federal Iaw and
executive otdeas. The Natiohal Park Suvice will'workC wiih other
agenoies with lpgd �ponsibilities in t}us yrea, i��Yuding the Corps •
o£Enginoore, the U.S. Fish and Wildlife Service gnyuoxtmcAt�j
Froteciion AgcncX and Minnesota D
Resources to emphasize resoutce protection and coord�ate theqr
activities,
p�a� Nanu"al Resource Management at 5 c� hasis added ,
is a`-`big}� priority forp:otection in� the com"dor." Tho plan oatls f r v�v tiands f��� d
ccstored, and irzczeased in the cozzidor°' and explains wetlands servc to rcduee "thc ��,���
1 a� a E$�� be p ep�� Ld?s clear that creating wetlands elsewl�eie WiII hot mitiParr�-Ft,a-wh.-..._
I�i addirion, che $AW is p��sc deftcient aiid daes not supp the proposed action.
�e �Q�'s EAVir guidelines s�ecificalIy xequire information on comptiance �,,�t� m�
, lana:
�
$
�+
�
�.
CoN r
��
��
I.;'
f 'I
�
I.
M`;
��
i' � +
i:
�;
�' ;
f
�
MT. Gary WatieR
Novem6er.i 3, 20Q2
Page 8
I}iscuss whether the gTOject is subje�t to any official govexnitiental
managemen�t plens adopted foz tho area. .:. If the proj oct is .
subject to a plap; the EAW" should identify ita r�quirements
zelBVant to the project awd disouss how the project com�lies with
thc pla� 'The RGU should consult with the govcrnment unit
iesponsible for.tha implementation of tho plan regarding grovisions
that rolate to �hc project and abouk the consistency of the project
with the plan. Bmphasis in tltc �AW should he givGn to any
conflicts or ineompatiUilicies between the pzojcet and pian
proviszon,s that relatz to.the enviinnmanf or use of natural
zesources.
$QB, EAW Guidelinns;.PreparingEnvironmentalA.rsessmenr Worksheeu at 13 (Feb. 2000).
� . .
� The LAW in this casc comp]etely fails to corr�ply �yieh the guidelines; it marely states:
"[Cjiriat design and construction of the proposed pmj ec[ would te consistent with ... the
�. Iviississippi NationalRiver and Recroation area Plan_" MAC, �nvironmehtul iLssessment
` Worksheet; Flood Protecttan, St. Pa�t Downiown Airport (Holman ,�'Feld) at I 1(October 2002).
' Tlie $A.W does not idet�tify the zoquirementa of the plan or discuss whol'her tfie proj cet compiies
with the Plan, _ Mareaver, there is no ind'tcation MAC discussed eompliance wit� the Plan. with
othu agen.cies. Finally, the EA�J is cempl�tely void oPany discussion (much less th� required
• emphasis) regard'ing thc obvious conflicts or incompatihilides between the project and pian
grovisions. ' �
An EFS is reqt�imd to address the environmental impacts associated with tha pzoposed
des�uction of wctlands.
�
IY'. 'Che-EAW Fails ta Consider t6� Tncreased Use of Fio(man �Yeld
The:EAW.aiso fa'tls to consjdcr the 7nct�ased use a�d �af�e at the aizport followzng the
co�npletion of the project. Without informatio� ahbut future use, M�IC does not have sufFcient
informaLion to make a determination regard�ng soma pf thc most si,gnificant environztiental
eFfects: Under thest circumstances, a negat�ve d�eIaration based on tho $AW wpuId be
arbitzary, capricious and_an abuse of discretion.. "
___ __.- — Tk�e-onviroumontal-review-prooess is, ics very nacure; fonvard=looking. - T�puipose��s
to review the rezsonably anlicipated consequencas of the proposed action before they occur. If �
the dike is consuucted, Holman Fiald will be more attraotive to potenrial cusloniezs sinea it may
provide a stzanger measure of flood protaction 'I'he EA�V, ho�vever, did �tot take into account
the li�Cely inerease in airport use when it idantified and asscsscd environmental inipacts. �
� �
DQ�SEY Sc Wk1ITNEY T.LP �� b:3 ;'
�
COE
DOR5$Y & WHCTN�X ��P
Mr. Gaty Vlarren
Nove��,her 13, 2002
Page 9
� .a �
The BQB's $AW regulatioz�s list the inform2tion �•,hich is conszdered "the basic facts
riecessary" to determine whether ap, $IS is required_ Minn. Sta#, § 116.�4 subd__ Ia(c) (200�):
As discttssed above, the regqlations oall foi a reviaw of a wide tange ofis�ues, �any of wtricii �
aauid be impseted by incr�ased use o.f the airpor[, The Eq'VV essumes t�� ,F,i21 ba no increasa
in airpo�-t use foilowing the compjok ot� pmject. I'his a��umprion is,complqtoly
nntvamnted, pari{calarly in light of $nlman Field's�rolo as a reliever air�o� �� p���
groposals ta limxt the vse of othet relievez ai�por[s: Tjie BAW run,s countclt� to the zyidence, ancl
atty rellaitce thereon is arbitrary, cttpricious or an abusc o�diseret�ot�,
t'. The Ecouncnic A,z�alysis Runs Coanter to Yhe �vfidc+tice
Tltc cost benefit at�aiysis provid�d in, the �AW is incomg�aCe and misleading,
The EAW sfate.s "[t]he economic bencfits incltido protec[ing d�e substantial privaze and ..
public investcnent made ak fIalman �ield during the past 76 yaais; ' IUfAC, Enviranmental
.4ssessrrtenz Workskee[: Flood I'rotecttoti, SG Pau! Downtown Airport (Holman fileldJ at 3
(Octobez• 2002). The eoats, h,owever, ctearly au[weigh Fhc bene�its, According to an attachment
f° �� EtL�rV, che proposal will cost apptoximaCely $2S mijlion. 1vf�,C� pPatBeting Xobscan Fiefd
froFn ,Flooding: $enefit�ng the Com�iruntiy While Mlr+imizingAdverse Coxseyuenoes jor
Neighbors at 12 (7u�c 2002). 7'here has been a f(otsd approximat�ly every seven yeyrs on
average in �ho lase thuEy y�ais--�floods have occurted in � 965,1969, 1993, 1997, �d 2001. Id, a@
1. _ The report provides the fallowing x.�fonnalion on the oosis of floods�
Costs associated with the �tooding are enoni�,ous. Tha IV1AC°s
typiea]_ cleanup epsts immediatCly after 3 flood are apgroximateIy
$300,Q00 to $400,Q60. T7�ese cleanup costs do not include repairs
resulting from dazriage that shows up �ueh later. •
��
cou'r.
�.
Id_ at 12. No add;taonal informagon is gmvided on costs. 1�oneeheless, even assumi�g t�e co62s
par f(ood event are $1 million and a£Iood oCCU�ted evary fpur years, iC woul$ tat�e 100 years to
recoup the $25 rnilHon i�ives�nent, even under theSe vcry conseivative assumptions.
This Bxpenditure must be b2lanced against zeeent Cestimony by MAC indicating that cuts
need to bc mada aemss the MA,C systarz}. According to a 7eccnt ac{icle in ttie Star �`ribtinc� 7eff
�iaztlioI, MAC's �xeculiuo DireetoT has racantly stated_the,airline-industry"�s-in-tcmFslc
co�ldition" and thersis g nced to make signiFicant reducti�ns in expenses, j]2n V�ias�oe� Jt„
Rirporr CharlerTerminalMay Close, Sfai' Tribune, Novembcr 9, 2002, at B�i. Z']xe article •
explains: "Airkon.g Harniol's proposals, closing the X8 month-old �Ttu�phrey Tetznizial during _
:nonths u%hen chartcr activity ie tow—=May to October—zs a strong possibility." Id. Iiamicl a]so
said MA,C may nccd to raise parking fees for employoes, cln�e its coi� fero�cc center, and lay oiT '
�
..,
�'
�
�
�-: .
j
bORSEy 6,. W�I'I'NEl'.T.[.P
Mr. Gary Wazren
November 13, 2002
Page IO
��
O b=.3_b3
F
empioyeos. fd. '�o'contemplato ezpondzng. �25 million far a dii�e to address a situation Ehat has
b�en S�°�n t° flceur, on average, tvery sev�n years whilo_ considsrable cuts ai�C b�ing Tnade . 1 �
clsowhere xs contrary to gaod public policy. Thezofore, based on the availahla infomratio�, . ��
MAC's assertion that the bcnefits outweigh thc costs of the pmpasal is not supported by the �
recor�L
Cnt�clusion
l�oi the reaspn3 stated herein, MAC should issue a poaitive declatation with respect Io the
nsed fnr an EIS, bccause fhere is $ pottntial5ignificat�t en'vironmetital effeets presentod b.y the
proposal arid otlier effoots not ovaluated in the EAW. '�he pmpCT cotuse of actioa.i& to prepare
��IS. Moreovar; ev� �'flxe defects noted above could be curcd by additional sriidy and �[.,
revisions to tha $AW, �AC may not issue a negative declaratfqn uhfil such addifional work is
oompleted and interesCed parsons have laad a� apportunity to review and comment on the
modi�ect BAW.
P
'Z'T:tjb
E
T2es�ectfully subinitYed,
� ", ;�'� /�—_
Thor�as Tinkham
a
P
��
Tom Dimond
21 i9 Skyway Drive
Saim Pau�,. MN SSI 19
651-735-6667
Februaty 17, 2006
,f . -_ _ ,� '
�
Those who are concemed about government pork, fleecing the taxpayers or degradation of
the 14fississippi River Cnticat Area, should be concerned about the p;oposed airport dike.
♦ 14fAC is not using actual casts and aetual floods. Lising the aetual number of
floods and actuat cosk, tfie cost beneft ratio drops from 1.21 in the EA to less than 50
cents benefit for each dollar invested. This does not include the environmental cost.
♦ MAC's Cost Beaefif A�nalysis {CBA) lists the cvst at $22.4 million. 'The actuat cost
is $28_5 miltion.
♦ In the site plan applicafion MA.0 uses the CBA costs, which they know or shoutd
kuow, are false.
♦ MAC does not base tfie benefits on actvat fIoods.
♦ MAC inflated benefits by claiming 3 times more floods than actual. MAC uses 9
floods (100 year or less nrtensity) over 50 years to calculate benefits. Over 50 yeazs,
thhere have been only 3 floods o€thaY intensity.
♦ FAA AIP funding requires benefits to exceed the cost. The dike does not meet that
requirement.
♦ F1oad records show that 2 ofthe last 5 400ds woutd have topped the dike. Tfiat is a
40 °/a failure rate.
♦ Northwest Airlines stated in a letter that expending money on the dike is contracy
to good pubfic poticy and MAC's assertions that the benefrts outweigh the costs of the
proposat is not supported by tfie facts.
Between the Draft EA in 7une of 2005 and the Fina1 EA in 7anuary 2006 tfie benefits
magically increased. No basis for the change is provided.
Flood preparation benefits wee�tt fram $359,351 to $ 410,9I2
Betay 1>enefrts weut from $17,21I a day to $24,96I
Tenant beaefits we� from $3.1 million to $3.8 million
Ground transportation benefits weut from $216,49'7 to $317,419
�
�
�
�
l `_!
t r�
;�
06-36�
♦ The Cost Benefit is based on Holman Field operations increasing from 134,377 to
256,280. ,
♦ The CBA modei has not heen adjusted for the reduetion of aireraft used by
Northwest incIuding tfie practice of reducing fIights to increase load factors_
♦ Zoning Code prohibits the dike.
♦ Sec_68.601 allows variances to modify permitted uses but profiibits variances that_
have the effect of allowing prohibited uses.
♦ Zoning Code requires at least 50 feet setback from ordinary high water (OI�.
MAC is proposing as Iitt1e as zero setback.
♦ A 9 feet ta11- mile long steel wa11 along Bayfietd Sfreet would eliminxEe views of
and access to the river.
�
Are we willing to allow the raikoad to build walls between the Science Museum and the
River to protect from floods? Are we rvilling to allow walls blocking views from Bruce
Vento Nature Sanctuary? Na commuaity wide dikes have been buitt since the adaption of the
Critical Area and MNRRA. Lf we open the door to mare dikes, where will we draw the tine?
MAC Chair Vicki Tigwell letter dated Febnxary 8, 2066 states: No, the floodwall will not
have a noticeable impact on aviation noise around the airport. Aircraft 6perations have
decreased hy nearly 60,040 annuat Iandings and takeoffs per year siuce I990. Tfie chart she
inc2uded shows aperations dectining.
♦�The CBA used by MAC to justify Federal funds says that operations wilt nearly
double from 134,377 to 256,280.
♦ The FONSI is conditioned on St. Paut changing tfie Zoning.
♦ The FONSI is conditioned on any requirements established in the site plan review.
♦ The maps provided by MAC sfiow the proposed coEnpensatory excavation is not on
airport properly.
�
��
Ob-363
Tom Dimond
2119 Skyway Drive
Saint Paul; MI�I 55114
651-735-6b67
February 10, ZOQ6
RE: SaiFrt Paul Airport Dike
To use FAA AIP funds a project is required to have at least a totat discoumed benefit that
�ceeds tota! discouuEed cost. The eost beuaftt anatysis dated November 4, ZQOS fias a
cost benefit of 1:30. There aze some serious shortcamsn_a�c_ in that calculation_
In practice, FAA interprefs capacity grQjects to include those involving new constcuetion
or reeanstiuucfion of airgoit infrastructure i�eaded to accvmmodate or facilitate airport
traffic. Tfie EA page 2 Sec.I.lstates that the purpose o€tfie dike is to redu� dawage and
to re8nce the impact that �Ioad events have on tixe cagaeity af the ll�f�naeapotis-Sf. Paut
Internationat Airport (MSP} aIId the Nationat Airspaee System
Airport capacity projeets meeting a dollar threshold of $5 million or more in AIP
discretionary grants over the life of the projeet, and all airport capaeity grajects
requesting LOIs must be skown to have totat diseouaEed benefits tfkat exceed total
discoiEnted costs. FAA le#ter �aated February 7, 20�6 groposes $S mi(lion iu AIP
discretionary grattts for the dike st�ttchtre itseIf.
Table 8 lists the eost ofthe dike as $22.4 uullian instead of $28_5 mill�on.
Tab1e 1 lisfs O&M as $32,836 a year. Presumably tlus ineludes the cost of maintenance
dred� Can maintenaaee, ineludina dredging, be done €oF an averaae $32,836 far 50
years? The Minnesotz DNR Ietter dated Augnst 4, 2005 staxed: The EA does not describe
a monitoring pIan to ass�re that the storage remains over time. Tfie EA atso does IIot
provide ana]gsis of frequency of excavation to mainfain �Ete storage. The I}NK wilt
rec�uire tfiis information prior to issuing a Public Wafers Work gennit. The EA response
states: A xnonitoring plau witl be deveIoped in caordination with the DNIt Bivision of
LVaters. �4f�4C will €und any reqaired maintenance efforfs for the eampeusatory
excavation azea. Withou� a plan, what is the O&M based on and is it reatistic?
�
�
Table 3 bases fload costs on tenant input but pravides no docvmentation to sugport the
aetual ctaims_ EA response 84 states tfiat the tenant cosfs in tfie Iulg 2005 draft EA were
$3.1 but have been revised to $3_8 million ia the 7anuary ZQ06 EA Agaia there is no
docuu�emation to supportthese aumbers_
1 �
��
O6-3b3
�
Table 3 in t£ie Draft EA lists VFAC flood preparaTion, damage and cleanug at $359,351.
T'ne Final EA lists the cost af �410,912. Tfiere is no documentatio� ta support this.
Table 3 in the I?raft EA tists delay costs to air2ines at $17,ZI1 per day. The Final EA lists_
the cosE at $24,961 per day. There is no dacumentation ta sugport this.
Tab1e 3 in the Draft EA tists ground transgortatioa costs at $216,497. The Final EA lists
the cost at $317,4I4. Tiiere is na docume�ation to support this.
Table 1 on page 5 Iists tlte 5 floods of record_ Tabfe l lists the duration af floads as 31,
31, 35, 35 and 78 d�ys. Iv1AC staYes in response 81 that 84 days is the eorrect figure to
use as duration of ftoods. Eighty percent of the floods listed in the EA had a duration of
3S days or Iess.
Table 4 bases preverned itood damage on the assumption that no future IIood will exceed
the 1 Q� yeac flood tevet and the dike Rrill nat be tc�gped. Two af the fve floods or forty
gercent cited in the EA as justificarion for the dike would have topped the dike_ Even if
one of the floods togped tfie dike, it would reduce the projected benefits.
When forty percent ofthe ftoods in tke past fifty years have exeeeded the design of the
proposed dike, is it reasonable to assume, that in the ne�rt 50 years floods will never
� exceed the design?
A pasitive cost benefit ratio is not supported by the infarmation provided.
�
2
�
�
, 1 . . _ ', .�
Sectiou I: INTROBi7CTION
1.1 Purpose of Guidance: The puxpose af this doc�ent is to provide clear and thorouah
guidance to anpart sponsors on the conduct ofproject tevel benefit-cost anatys'ss (BCA) foi
cagacfij-related airport projects. Ft wi2t faeititate the productian af consistent, thqi and
compazab2e anatyses tS�at qu be u�d by the Federal t�,viatiou Adminis�atian (F�A} in its
consideration of airport projects for discretionary fcmding vnder tfie t�itport Improvement
Progr�m (AtP}. t4�ort sponsors shoutd confomz to tfie generat reg��irements of this guidance
for al1 BCAs subniitted ta FAA. However, aicpoFt sponsors are encoucage$ to malce use of -
inaovative methods far quautifyiug benefits and easts wfiere these me�tzods can be shown to
yietd super[oF measures of pmjeet merit.
1.2 Backgruund. On October 3I, 1994, FAA simultaaeotasly published'Policy Regatding
Revisian af Selection Criteria for Discretionazy tLicpoct Iv2provemesrt iTrograut C`rcaut Awatds
and "Poticy for Letter of Intent Approvals Under The Airpoit Impcovenient grogiavt" m tfie
Federal Re 'Ig ster. 'I'�ese policies estahlish the requireme�tt far BCA to demanstratethe merit o£ .
�aBa���Y P�.teets farwhich airport simnsors are seek'sng AiF diseretionary fimds. I�€ praecice,
FAA interprets capacity projects to ineTude those involving new construction or reconstmcrion of
auporE infrastnxcture intended to accommodate or facilitate auport traffc_ The FAtI policy
requiriug B�A dc�es ncz� agpt�r to grojeets unctertaken saIe2Y, � P���Y, for tfie abjeetives of
safetl', securi�', confom�anee with FAA standazds, or envunnmentat mi4igaticrn. The selectton .
criteria potiey for c�iscretionary gants was issued 'm fmal fort� in October 2944 and mocFified on
Iune 24, 1497, in tha Federat Register Notiee'ToHcy aad Ciuidance Regardiug Benefit Cost
Anatysis for Aixport Capaeity Projects Requesting Discretionazy Augort Improveme� Program
Grant Awards and Letfecs of Ix�tent." This modifieatian established doltar threshelds above
wliieh SCA was �quired, t�amsferred the responsibtTily for �eomgtisl� the BCA frc�a ttte
FAA tatlxe aaport sponsor, issued BCA guidance, aad Feguesteci commeuts oet rhe t1u'esfiolds,
the guidanee, and Ft1A foreeasts of ogeratians a¢d enptanemeuts. 'Phe fmaI poliey on the
apPlication af BCp. to Letter of Intenf (�OI} apglica�oas was issaed on Deeember I5, 1999.
�Port G�P�t�Y P�.l� meeting a dollar t2�reshotd of $5 m7liog ar maFe iu AIP diseretionary
granfs a`rer tfie tife of the projeet and all aitport eapacity gro�ects Eec�uesting E.OFs musf he shown
to have totat discaimted benefifs that exceed totat discouufed costs. Frojectx for reconst�uctian
or rehab�itation of criticat airfield stractures may be exe�gt from BCA requirements on a case=
by-case basis. Aupart sFsoasors requesteng an exemptian mvst applp to ttie FAE1 wluch will
consider the essentiat need of tlfe pro}ect, its tincing, and whether tfie estinzated cost is ceasovabte
aac�typieat
�
�
� �
�
Ob-363
�
79
:�
�
Responses to Climb the Wind Institute Comments
the dike saves 84 days.
See Response 80 below and General 12esponse 2. -
There is no requirement Eor a cost-benefit analysis in a.National Envitonmentat Po&cy Act
(NEPA) document_ unlass it is" relevant to the choice of altematives (Council on
Environmentai Quality Regulation 1502.23). That is not the case for eithez of the projects
proposed in the EA. Therefore, no cost-benefit analysis was included in the EA. However,
the FAA rec,}�5ires that a benefit-cost anatysis (BCA) of projects.reQuesting $5 million or
more of F� discretionary funds show that the benefits of the project exceed the costs.
MAC has prepazed the FAA-required BCA subsequent to issuance of the Draft EA and
submitted it to FAA for review and approvai. The calculated Benefits-to-Costs r�tio is 1.21
over a 5E}-xea� evaluation pe�iod f2��-Za$7)• Gontaet Bridge� Rief at (612) 725-83'Il for
a copy of the draft �CA. Also see Response 82 belaw.
The EA delay costs based on 84 days aze conect — STP would tie elosed 46 dags (EA
Tabie 2) withouE ttie dike and sub-d�ain project. The sub-drain project saves 12 days and
g2. `The 4Q% of. the f� statem�nt is misleading and inaccurate. R�hile it is tLUe that of the past
5 events, 40% of them have been greater than a 100-year event, a 100-yeaz flaod typically
oceuts once in a hundted years. Tfierefore, tQ assume the pioposed dike will not prevent
airpo�f closure 40°Iv of the time is incorrect
83. See Resgonse 80=
g4. The cited cqsYs in tlie Draft EA have b�en revised in this Final EA. Cost& ta the tenants in.
the 200}. fPooc� were appxo,�imaielg $3�.&� mil�ion�_instead�o'$3.� miltio�, which wouYc� be
apptaximately $4.4 million in 20Q8 (due to inflation� in revise� Table �. Th� $6 O8g
figuze included lost. zevenue, wliereas the $31 mi2lion dick not. Th� "effeets a� Iost
revenue include Iost fuel sates, renta� revenue, uiaintenanee. revenue, etc. Lost tevenue
casts are e�eluded in this FiRal �A. See alsa ResgpnSe 35. _,
g5. Graund transportation costs aze measured for visitors ta the area whose primaFy destination
is downtown St. Paul. Nearly ali of the aircraft firinging those �risitors would utilize MSP,
as it is the next ctosest �pozt to downtown St. Paul that has ninway lengtt� eapable of
handling aizcraft of that size. Beeause each of thousands of auto trips eannot be modeled, it
was determined that downtown St Paul was the most appropriate point to measure the
difference in fravel diseance.
..
�
�
See Response 80.
See Responses 80 and 84.
See Respcznses 80 and 82.
��
�
!._ ,,
The additional traffic at MSP due to the diversion of STP-based aircrafr and itinerant operations
results in inereased ground and air traffic cantroi demand aY M5P, which in tum resulfs ia
National i�viation System delays. Delays at MSP were modeled during fhe Rimway 17/35
piannuig effort ("Dual Track" grogram}. This modeling has been applied to quantify the impact
on operarions at ivfSP resulting from STP diversions during clasure of STP. Delay is
exponenfialIy related to increased operations and in yeazs beyond 2020, this impact to operations
has an unacceptahle impact on MSP. `
Tn order to estin�ate what the MSP delay costs would be if STP continues fo be closed as a result
of flood events, the yeaz 200& is used as a sample. In 2008, MSP is e�cpected to handle 1,623
operations per day. This results in appro�cimately 6.8 minntes of delay per operation on the
airfield (according to HNT'B anatysis and Figure 17 of tfie MSP Capacity Enhancement PIan).
Sfiould a flood event'occur at STP in 2008, au estimated 95 daily STP operations would be
diverte�i to MSP. 'Fhis would increase the daily operations at MSP for that impacted period
(dependent upon flood duration at STP) to approximately 1,718. This increases tlte average
delay finm 6.8 to 9.5 minutes per operation. "Phis is at a cost to the airiines of $67.10/delay-
minute (Figure 17 of the MSP Capacity Enhancement Plan}. Tfiis equates to an additional delay
cost at MSP of $17,211 per day [69.10(9.5-6.8j95]. The overalt total benefit (or avoided cost) o£
a perimeter dike in place in 2008 for a 1.5% flood equal to Yhe 2001 flood would be
approximately �8.1 million, wfiicfi incIudes costs to MAC and tenants, operation delay costs to
airlines at MSP, and additional ground transportation wsts by affected STP travelers, as shown
in Tabte 3. " •
�'
Table 3: Estimafed Cost of 1.5% F'tood af STP in 2008
� Item Estimated Cost in 2008
� MAC flood r aration, damage and cleanup 359,351
Flood prepazation, damage and cleanup costs, and lost
� revenue to STP lease holders and tenants 6,089,042
!ditionat MSP delay
$17.2111
Source: Survey
to
ation costs by STP tra
Tota!
; holders and tenants;
1,445,724
In addition, fhe proposed perimeter dike project would reduce pavement rehabilitation and
replacement costs. Runway and taxiway pavements aze e�ected to have a full rehabilifation
cyele approximately once every twenty yeazs_ At STP, with the completion of the sub-drain
project, the pavement life cycle will be approximately once every eighteen yeazs. The benefit of
the perimefer dike itself in preveniing ali but surface runo£f submergence effects would be an
increase of two years in the pavement life cycle, wtuch would bring the pavement ]ife cycIe back
to approximateiy once every twenty years.
Draft Environmental Assersment —St. Paull?owntown Airport Perimeter Dike & RSA Improvements Project
9
��
�
��
�
Ob-3b3
�
delay from 6.$ to 9.9 minutes per operation_ This is at a cost to the airlines of $67.10/delay-
miriutie (Figure 17 - of the MSP Capacity Enhancement Plan, a�djuseed to incorporate cnrreat
comznercial'aircraft operaung costs). This equates to an additional delay cosE at NISP of $24,961
per day [67.I0(9:9-6:8}12�}: The overall total benefit (or avoided cost) of a.perimeter dike in
place�in 2008 for a 2.5%o flood- equat to the -2001 flood would be approximately �7.2 million,
which inclndes costs to MAC and teriants, operarion delay costs to airlines at iVISP, and
additionat gound transportation costs by affected STP ttavelers, as shown in Table 3.
<.,r:
STP lease
Tabie 3: Estimated Cost of 1.5% k`lood at STP in 2008
Item
nage and cleanup costs
relocation, damage and cleanup costs to
and tenants.
costs to airlines (84
�
@ $24,961 er da ) .
AdditionaS groundtransportation costs by S`I'P travelers
($31.49 er o eration @ 120 o erations/da for 84 da s)
Total
Source: Survey of STP lease holders and tenants; I�I'PB analYsis
in 2008 Doliars
4,369,561
2,096,724
317,419
7,194,616
In addition, the proposed perimeter dike project would reduce pavement rehabilitation and
replacement costs. Runway and ta:ciway pavements are expected to have a fuil rehabifitation
cycle approximately once every twenty years. At STP, with the completion of the sub-drain
project, the pavement life cycle will be approximately once every eighteen years. The benefit of
the perimeter dike itself in preventing atl _but surface runoff submergence effects would be an
increase of twa years in the pavement ]ife cycle, whiCh would bring the paveinent life cycle back
to approximately once every twenty yeazs.
RUNV�rA,y SAFE'ry AREA INII'ROVEMENTS PItOJECT
STP's runways have different RSA standards dependent upon the type of aircraft they are
expected to serve. These standards are based on the Aitport Reference Code (1�RC) which is
based on approach speed and wing span. The two types of runways at SZ7' are classiFied as B-II
and D-III. Table 4 describes the approach speed and wing span of aircraft .using these types of
runways.
Table.4: AirporE Reference Code (ARC) Standards for STP Runways
Aircraft Approach Speed Wing Span
Cate o
g-II 91 to 121 knots 49 feet u to, but not including, 79 feet
_� , D_p� 141 to 1661mots 79 feet u to, but not includin , I18 feet �
Source: PAA AC 150l5300 CAG 8
_ The existing RSA and FAA standards for RSA width and length beyond runway end for each
runway at S'I`P is shown in Table 5.
Final SnvironmentaI AssessmenY— St. Paut Downtown$ irpon Perimeter Dike & RSA Improvemexts Project
�
��°��'�
'Fom llimoud
2I I4 Skywap Drive
Saint Paul, Nlri 55219
65I-735-6fi67
Febnzary 9, 2Qd6
RE: Saint Eaut Airport Dike -
To use �E4A ATl' fiinds a praject is required to have at
atotat c�iscounted benefi� fhat
cl�QUem$eE 4 �04�tias �..
��
I� �ract.ii��� ���et� eagaci� grp�eet�t� in�lu�`g t�i4�� mv4�i�s�neF�t` cc>ustmction
�r reccisss�si��4o�t gfa'siga�i�f"ras�ci�t�einte�ide.�tc� aeeo�nodaf� or faeili� aiFpott
tra�e Ttre EP. page 2 Sec_1 _Istatea �aatthe p�se ofth� ct�e is to redi�e dan?a�e and
to redeice the impaet th� f�6ads eve�rts I�ve on it�e ca�ae�ty ofttie Min�eago�is-S�: Fau1
Irnern�avt� ��f�'������
. . ,�. .. � .. . �
Aiigart c,a�zaci�t p�Qjec�s meetiug a d�tfta�tiu€s�td o€�r�`uul�an or inore in AII'
- ._._ : :__. :..F ` - , s-�-----°--_....:�__...
- ,- �:
� dil�� s��'�t���� •< � .: s „ .
'Fatile��ts���eas�o��tti�c��a����asill�4�t�sfea�Q€�&_�,�IYt��: .: _
TaFtle' �s€� Ofie� as �3�,°3� a`y�: �a�fg t�s-viefii�ie�ttie e�`a€`maui�eriance
reqtiiiettei's
sta€e�s t1 i�i+
�3��� it�"�
�
�
�eriti�
�• :
ons�
o€
�rAV{VSUelv,rc�c.w.�>-.P��.v�.��.�t . _ . ... i. . ". .' .._ .
Tahle � bases 4aoct eQS�,s:a�t tenan� in�u� �ZU� �vr�c�� n� d�cn�i.�ata�€o�fe� s�pport the
ac�uaf cta�in� �t��es�dvsg �4 �a_�t��� fenan� e2s� u��� In�� �445 d�af€,�Rrer�.
$3_ I but P�a�e Been revised to $3.$ m�€izo�t ixe �Tie �aauaiy Z006 EA Again tlaere is na �
docutnen�a�iai�fa� s�p�€ii�tt?.ese i�ui "ntiers�
���
Ob-363
� Table 3 in the Draft�A Iists MAC €tood preparation, damage a�d cleanng at �359,351.
The Final EA Iists the cost at $4I6,912. t
Table 3 in the Braf� EA lists detay costs ta airfines at �17,2I 1 per day. "Fhe Finat EA lists
tlte cost at �24,961 per day.
Tab1e 3 in the Braft EA lists ground transportation eosts at $Z 16,497. The Final EA lists
the cost at $317,419.
Tabte I on page 5 lists the 5 floods of recard. Tab2e 1 IisCS the dura�ion af floods as 31,
31, 35, 35 and 78 days. MtIC states in respoase SI that &4 days is the eorreet ftgure to
use as duratian of fIoods.
Tab1e 4 bases prevented, flooh damage on the assumption that no future flood wilt exceed
the I0� year ftoad 2evel and the d�ce wit} not be togged. Two of the five ffoods or forty
percent cited in fhe EA as justificafion for flie dike would have topped the dike_ Even if
one of the floads togped the dike it would reduce the projeeted benefits_
VJhen foriy percent of the floods in the past fi8y years have exceeded the design of the
proposed dike is it reasonabte to assume, that in the nea 50 years floofls witl never
�ceed the design?
l�
� ;
��
��-363
�ra� ���ond
2I 19 Skyway Drive
Sasnt PauF, MN 55119
652-735-6667
�eliruary 6,-2006
FIRM is a Flood Insurattce Rate iV1ap. CLOMK is a Conditionat Letter of Map Revision
(insurance map). L(3MR is a I.etfer of Map Revision (insarance maP}- Insurance rate
maps are a cuasideratiag but certainty nat the onfg consideratiou whea establishing
zoning protections for tfie Critical Area.
The CLOMR Tetter dated June 14, 2005 states tfiat FEMA is commentucg oa the grojects
proposed imgace on the �Eaod Insurance F.ate Map. This is a reeiew of propased f�ood
insurance rates, not a recom»tendcztion or etrviroranental review of the proposed project
FEMA rec}uires that to pazticipate in the flood insEUance ptogram, communitie"s must at
least adQpt �MA miaimum staudards if those protectians are not cutren�ty in pIace.
FEMA Part 60 subpart A states tE�at any IIoodptain managemeirt zegulations adopfed by a
commnnity whieh are inore rest�ictive than ttze criteria set forth in �s part are
encour�ed and shal2 take precedence_
The eurte� Saurt Paul Zoning Code exceeds the minimums in the CI.OMR. As stated.in
the CLf3I�1R the more restrietive eriteria take precedence. l�to map revision is required.
FEMA does not require communities to reduce tfieir criteria.
Any suggesfion that Saint Paul is required by FEMA to reduce river carridor
protections to permit flee grn[u"�rited d�e is faefuai[y inacearate. It is absurd ta
suggesE that Saint Paut does not have tfie fega[ aufhorify to enforce fhe pmtecfions
enacted under the Criticai Area Aet Because of insarance rate maps.
The Coruprekensive Plau 4.2.4 states tkax the City will coufinue tu enfarce ttce 56 foot
shareline setback for strudu�es. 'The 50 foot setback is part of tlie Zon'vag Code approved
uncFer Criticat Elrea and MN�tRA Tier 2 status.
Zanireg Code reqgires at Ieast 50 feet set6ack from ordinary* Ligh �vater QHW.
MAC ig prapasing as Iitt[e as zero setback,
MAC argues gou should use past floods to justify the large expendit�ue of taxpayer
dollars but not to caleulafe it's suecess.
Saint Paul flaod records show t1►at the proposed dike design �ouId have failed 40
percent af the tinte. T�uo of five floods have exeeeded thel0a gear IIoc�d design_
�
�
��
�
06-36�
�
Norfhwest Airtines IetEer stated ta contemgiate egpending �25 m�llion for a dike to
address a situatiuu that has been shawu to occur, on average, every seveu years
while cousiderabte cnfs are being made elsewhere is contrary to good public palicp.
Therefare, based "on the avaflabie iufttrma#ion, MAC`s assertiou that the beuefits
outweigh �he cos�s of tha progosaI is not sugparted bp. the reeard.
The Metiopolitan Council stated the EA is largely sitent on the pote�stial tfiat wilI exist
far the Mississippi Iiiver water quality d€gradatian as a resah of the proposed dredging.
The MPCA states they befieve the proposed consfiuction couid encounter contaminated
fill and that PoFyaromatic Hydrocarbons and m�tals have been found dEUing previous
investigations.
The FJnited States EnvironmentaF Prutection Agencg stated t�e docament was given
a cursory review, but other wor�toad priorities grectuded a detailed review ancI
commenf. MPCA staff for See. 4Q1 review has beea eIiminafed. MPCA expressed
their intent to wave review. Federal and State cutbactcs of fnnding for
eovironmentai review have effective[g Iett it ag tv the Cifg. The CiEy sho�td not
approve the site ptan before poHutian cantrot and QoIIution preventian plans are
devetoged and the public has had a ehance ta review and comment on those pians.
The I�Iinnesota D1VR paints aut tfiat H'ig�in's Eye Fearfy Me�ssels, a Fecleralty and State
� listecf endangered species atong with other state-listed mussels may inhabrt this stretch of
the river.
'The EA responds that n�ussels are uot abnudant becanse of Ioss of habitat via
riverfront devetopmenf, dredging and industriat activifg:l'Iteu' proposaE i4 Fnore
deveiupment and dredging.
Page 29 of the EA states th�t they did a site visrt in December 2062, to loak for the
e�ustence of rare plarns and animals.
Hard to imagine whg theg did noE find rare plants and animals daring 17ecember in
1Llinr�esata. Snow, I�ii�ernation and migratian eouI� ha�e faetored in.
If you have any questions abaut the validif.y of the EA t�un to gage 34 �Tisual impacts.
The E�i says that views to the rive� fram Ba�efd Street shou[d not be signi�cantly
affecfed. AcfuaIIp the viegr te fhe river wilt be eomglefely eliminafecE hp a sfeel wall.
Table 7 page 14 fails to list that Saim Paul Zoni�g Code woutd ha�re ta be changed ta
permit consin�ction.
� The Difce is grohibited under Sec.6&.214(h} of fhe 3aint Paui ZaIIing Code.
2
i �
�
To� n�ofla
2t 19 Skywap Brive
Saint Paut, MN SSI19
65I-735-6667
Febrctary 2, Zdd6
Ob-363
When the City Attomey was asked if the dike was prohibrted, there was same conflictiug
information_ 'Fhe City Attaineg cQrreefly stated: tse dike is protu�rted by the 3aint Paul
zoning code. Incorrectly, it was inferred tha� it was a eircular argument because FEMA
required �he City to adopt th� uunimum standard estahlished iu a LO14fR �at would:
allow the dike. FII4S� clear2y stattes in their regutations and the CF.£1Mti � mc�re
res(rietive community criteria take precedence over the minimum NFIP criteria. FEMA
does nc�t supersede Yhe City when gstabtishing zonsng districts.
There is agceement fSmt the dike is prohibited hg the wning r�ode.
�ee. 68.21� Standards for coaditiasal use.t inthe HCl FSooFlwap Dis[rict
(fi} Stntcfarai w�dss for f2ood confrol fi�af wiII change fhe coiuse, cnaent or cross-section af
p=otecced weUands, or pnblie waters sUallbe subject tatfie �govisions of Mmnesoia Stafutes,
CBapter 103_G. Com�nilv-wic� skucfnrat wodss for 8bod eonfcol mten�F toremave areas fiom
the x�salatotvfloodplaia sha3t notbe alfowe@inthefioodwav.
Sec. b8.f0� EsfaLtisismegf:
Cd? Wii�t these �stcicts aII uses not allawed a�pefmitted vses or as ne�nitEeduses subjeeEto
s�ecia2 cond'ctians shaIf be aFCd areherebc �o3u'bited. Leg� nouconforming sfinekues ar uses
existing ou tfie effective date of tUis ctra�er or amendmentthereto willbe permixtedta continua as
provided in sectioa 62.102 and seetioa 65.906.
There is not ageeme�t, that the City has no choice but to adapt the �MA minimum
standards.
FE1�fA Park 60 SubgarC ?,(d� states a� commnnitg viap exceed the minimum
standards and any IIoodplain mauageriieirt reg�tations sdopte� by a eommunity
which ace mvre restrieti�re t6an the criteria set forth in this part are encouraged
and shatt tage precedenc�_ .
The City is regvired to protect at a Eninimum, the area. FEMA designates as the
minimum necessaty. FIIvfA alsa encourages additional protec�ion. An area Iarger
than the minimum can be designated far protection based oa a uuutber v€faetors.
Nat�ual resouree protectio� accommodating fi�re growth ugstrea� and
praviding foc unknown faetors are some oftfie reasonsto proteet more €han the
minimum reqt�irecL
There is not agreement, that ttie zoning cade requires tfie use afFEMA minimtFn2
standards_
s�. 6s.xa�. E�c��� .
(a) This chapter suau appty ta att tauds witfii� F2xe ciE� s�mt an the rivercox�aor oveEfay zonrog
dishrict ma� as t�eucg Iaxted wiflvn fhe bbundaries of ihe RCI River Comdor Ftoodway I3istrict, }(,
��
�
�
��
0�-3b3
� RC2 Rivez �oiridor Ffood Friuge Bi�tcict, RC3 IZiver Corridor Utban E3pen Space Bistrict and
RC� River �mdorUFhan Bivexsified I?iskiet
(b) The rivar cosidor over2ay zoning di�trid maPs accomPan9�g tfi�s �er corridor code, togetfier
witfi all mafters attactxed thereto, azeheieby a�ptedby reference and made a part af this code as
ff the ma$ezs �d "mfarmation set forth therein lvere fully descn� hertia. 'Fhe attached ntaterial
shatl mcIu3e:
(lj The flood incm-ance stady for the citY P�Paz� bY tiee Federal Emergency Management
AgeIlCy (F'EMA}, dafed Ap�it Z, 2003; and
(2) The Ffood Insurauce Rafe Map dated A� 2, 2t}63.
(c) 'fhe RCI �toodway I7isfricf shal2 inclu� those azeas designated as IIoodcvay and Zone AE
without a floodway designacian an the F1ood Tns�sance, Rate Map_ The FtC2 F1ood Fimge District
shalt inelude tFFOSe areas designafed as Zone AE and outsicte of fhe IIoodway on the F1ood
Insurance Itate Map.
This shows that the eurreat RCI district is based an FEMA minimum standaz'ds.
Unless this section is revised the prcrgased dike is prohi6ifecS under these
standards. Ifthis secrioa is revised, the City Council is aot precTuded from
adogting more restrictive criteria. As stated above, FEI� enc°urages
eommunities ta set more restrietive cri€eria.
There is not agreement, that tke City aiust change it's zoning maps if a LOMR is issued.
� FEMA requires a map revision if �tre minimufns are not met. �EM2� does not
require a community to raduce }uotections to the minimum. Since the minimums
under the LOMR are atreadg protected under eurren4 zaning; na revision is
rec}u�red.
In school you are required, as a m'snimum, to get a C• Teachers encaurage you to do
better. �F14FA atsc� encourages us ta da betfzr. It is just faetualty incor€ect �ttaf �EMA
requires the Ciry to reduce profsctious to get down to the m;n;mum.
�
� �
.
�
1 . - :'
Shefdon Johnson
Stafe Regresentaiive
oESt��t s7e
Ramsey Courtty
August 4, 2D05
Bridget Rief
iVIetropolifan Airports Commission
6040 28�' Ave S
Mznneapolis, MN 55450
6I2-72S-8371
Fax-612-'794-4407
Re: Draft Enviroiunental Assessment
NTin�esota
HOUS� O�
Representatives
Received
au� a 5 2005 `
Airport Development
The proposed dike is toeated in the state designated Mississippi River Criiical Area and
the Mississippi Nafional River and RecTeational Area. The Mississippi River Corridor
Pian calis for protecting and enhancing the nai�u�al and scenic vatues of the river. The
plan also calls for protecting and enhancing access to the river and views to and from the
river. The proposed Perimeier Dike at Holman FieId is not in keeping with these efforts.
The issue of the viewshed is especially relevant given the amount of work and-money
that has gone into estab3ishing the Bruce Vento I�fatuie Sancrisary ansl tlie Sam Morgan
Trail (directly across from the proposed sheet pIle dike), as well as the view from
Mounds Pazk *
.'�W':
�
�
�
Sincerely,
����.
Sheldon 7olu�son
State Representafive
�, . .
������
Kafhy Laniry
City Eouncil President
City of St. Paul
229 Sta4e Office Bulding.l W Constifufion Ave.. St. Pauf.
� 4 Email: cepsheldoajohnson�fiouse.leg.state:mrt.us
a�
�� �
730-49t7
296-4201
296-0165
Faac
..• _�S�?i'rys.
.�.', ,��'�
-�-
IN REPLY REFER 70:
L8024{MISS)-ZB
August 4, 2005
e IATIONAL PARK SERUICE
Mississippi Nationai Ri�er and Recreadon Area
121 E. Kellogg Blvd., Sfe. I05 '
St. Paul, Minnesota 55161-1256
Bridget Rief
Met[opolitan Airports Coznmission
6U40 28�' Avenue Sautfi
Minneapolis, MN 55450
Deaz Ms. Rief:
Recefv�d
AU� 0 5 pap�
Airpo� Developmerit
06-3�3
Our o�ce has reviewed the Draft Environmental Assessment (EA) for the proposed Perimefer
Dike and Runway Safefy Area ImprovemenEs Project a# the St. Paul Downtotivn Aiiport (HaIman
� Field). Holman Field is located entirely within the Mississippi National River and Recrearion
Area (MNRRA}, a unif of the National Pazk System. The MNRRA was established by Congress
in 1988 to protect and enhance the nationally'significant historicai, iecreational, sceniq cultura�,
natural, econoxnic, and scientific resource's of the Fiver corridor.' Tfie National Pazk Servioe is the
primazy advocate for national interests in fhe comdor and has mandated review responsibilities for
federally funded or permitfed activities. The visions and policies of fhe MNitRA Comprehensive
Nlanagement Plan (CMP)• provide guidance for Narional Pazk Service review af khis and other
federal actions in the eorzidor.
General Comments
We recognize thaf the St. Paul Downtown Airport has played ari important role iri Saint Paul's
history and cantinues to make a significant confiibution to tlie zccrnomy of tfie Twin Cities. We
also realize the inconvenience and hardship experienoed byairport users, the airporf itself, and
the regional airports system, when major ffooding forces its closure.
While we understand the desire to pro
major flood evenis, we mast also note
service at Holman
�.
W�i�`fii�it'npi'eaienta�iori'of t7iese`goa�§ is'di.ffibult to achi�ve in the context of aiiport "-
operational neuts, be'st ef£o�ts'sHould b'e made to'ma�timiie the integraHon of MNTZRA CMP
goals in this planning'effort. :
i3nited States Department of the Interior
� �
�
Figure K
�
future growth and development with restaration
programs that reconnect and restore remnant natural
2.3 The Gity will continue to support the efforts of
organizations such as Great River Greening eo restore
native grasses, shrubs and trees alang the riverfront
structures. In addition, the City
will support efforts to restore the shoreline to a more
natural character within 100 feet of the river to faciti-
Trail 6etween Wamer Road tate wiidiife. movement, and to improve the aesthetic appearance of the
and the Mississippi River floodwall. Such efforts must be compatible with current channel design
and flood cantmt management, and exceptions are made for marinas,
and 'other uses requiring river access. Redevelopment should include
removal of urtused docking facilities (i.e., at the Koch-Tvlobit site).
4.2.5 In all new developments, threatened artd andangered wIldlife
habitats shall be protected from alteraII�ns which wauld endanger their ���
survival.
4.2.6 The City will integrate its plans c�tith the work of the DNR's Metro
Greenways and Natural Areas Collaborative. This metro area coIlahora-
tive has identified high quality native liabitat remnants which could 6e
linked into regional greenways, providing continuoas habitat corridors to
support native plant and wildlife species. Many poteritial greenway
opportunities exist in trie East Metro azea, including Saint Paul.
Figure L
Ben Thompson's vision of
c •The Great River PaFi�
22 � City of Sain[ Pau1
'': e20 4668 � � 09:26:04 a.m. Ot-03-2006 `474
�
06-363
� As-built p2ans, ceTtified hy a registered pmfessionat engineer, ofall proposed groject elements
• Commnnity at7mowiedgment of the map revisian request
• A copy of the pu6lic uotice distn6uted by yonc cammunity sta[ing i[s intent to revise the regulazory
floodway, or a statement by your coussaunity that it Las notified all affected propeify ownets aud
affected adjacent jvrisdictions
A$er recei4ing appmpriate docameatation to sflow fhat t6e prolecY has been compleRed, REMA will initiate
a revision to the FRthi and FIS zeport. Because the BFFs would c2iange as a resuit ofthe project, a 9U-day .
appeal period would be initiated, duting which commnnity of�ficials and interested persons may appeal tfie
revised SFEs based on Scien'hfic or techuical data.
This CLOMR is based
co�unity is responsi
required tiy Fedeaal or
Imowledge oP locat coi
tkeNFIA. Your
State,
on
the�.
� If yon have any questious re�azding floalplaiu management iegularions for your couun¢nity or the NFIP in .
general,pteasecontacttheGonsu[tal'sonCoordinadonAfficer(CCO)foryourcroromunity.Informationon .
thc CCO for your community maybe obtained by calliug the Diiectoi; Fedael Fnsncance and 1vlifigation
7 Biyision ofFEMA in Chicago, Illinois, at (312) 408&5529. If}rou have any queshons regazding this
. CTAMR, please caU ousMap Assistance Center, toll free at 1-87? FEMA MAP (i-877-336-261?)-
Sincerety,
`,�,r,.. � 7y�n�.,� �
V IJ
7oim F; Magnotti III, Project Engineec'
Aaratcl Identification Section
MitigatsonDivision
Emeigency Prepareclnass
and 12esponse D'uecioiate
�
EncLosuns .
cc_ Mr. Gaty Watrea, P.E.
Director, Aicside Dcvelopzn�t
_ Metropolitan Aitports Commission
Ms. Susan Kimbedy
Director
Ilepartment of PIanaing and
Economic Deyelopment
City of St Paul
For_ Doug Bellomo, P.E., Chief
Hazazd Identificahon Seciioa
MitigAtion Divisian
EmexgencY PreParedness
and Respoase D"uectora£e
Ms. MolIey Shodeen
Mehv Region
MinncsotaDepaRment ofNahualResouTCes
�
Mr OSbazgfii (OUi) Sivm, P.E.
NfinnesotaDepadment ofNamial
Resonices— Waters
Mr Thomas E, MacDonald, P.E.
Senior Engiaeer
Bazr Engineermg Company
��
Tom Dimond
2119 Skyway Drive
Saisrt Paul, MN 55I19
651-735-6667 .
7anuary 24, 2006
RE: Holman Field Dike
1 . � :
The Dike is proLibited under Sec. 68.214(fi) of the Saint Paat Zouing Cod�
Sec.68.601 states although variances may be used to modi£y pemussible methods
of IIood protection, no variance shatt have the effect of aliowing in any district
uses prolu�ited in that disFsict. .
Sec.61.601(e) requires a finding that the variance would not allow a use that is
not permitted noi would it alter or change the zoning district classification of
tfie 1�B�Y- '
Sec.68.102(d) states that all uses no� allowed as permitted uses or as pemutted
uses subject to speciai conditions shall be and aze hereby prohibited.
Finding 5 is in error. Structural works for flood eantrol such as levees, dikes and
floodwaIls are uses under Sec.68213(fl. The propose@ dike is prolu`brted under
3ec.68214{h}.
Finding 5 is in error. They can not meet tfie requirement that the variance wilt not
alter or chauge the zoning wfien the vanauce is condi6aned on a rezoning. The
stxted inten� is tb after the ffoodway.
Nafural r�souree proteciion
Sec:68.601 states the burden o£proof shalt rest with tlie applicant to demonstrate
canclnsively no adverse affect ta the nat�uat environmeirt.
Coacents abo2tt pollution, water quality, habitat pt'otection and endaugered
species have been raised by the MPCA,I�II3 DNR, Me6ropotitau Counci3,
National Park Service and individuals. The MAC says they will address ttiose
cancerns later after the permits have been approved: The zoning code requires
tkem to address tttose issues.up frorn. Soil barings, mussel survey and vegetation
restorakian pTans are some of the items that shoutd be included in the site plan
review.
�
�
�
��
�
�
06-.�6�
Views to the river �
Currently this stretch of river along Bayfield Street provides public access to the
river as called for in tfie Ivlississippi River Corridor Pla�. People can walk, jog,
fisk and 6ird watch along this stretcfi of river. The proposed 3 feet tatt - mite
long steel wall wauld biock all aceess and views of the river.
Views from the river
From the river some views are obstiucted by buildings. With the continuous wall
the openings woutd be lost, blocking views tliroughout this section. In Minnesota
vegetaiion can onlp help hide a steel wall half of the year.
40 percent failnre rate
The MAC cites the impacts of actual floods to just,ify the dike. Using actnat
floods the proposed dike would have failed 40 percent of the time. MAC then
argues you should use theoretical not actual floods to calculate failure rate.
Inconvenience of using other airports during a t�ood
Alt the users chose to locate ifl tfie floodplain. They were aware of 400ds. Ftaod
protection far individual sfractares is al[owed but users oQt not to do so.
?
If a downtown airport is such an important factor m Tocating corporate
headquarters why don't the facts support the argumern? Minneapolis does not
haue a downtown airport but corporate headquarters locate in Minneapolis. 3M
was headquartered in Saint Paul but moved to Maplewood where there is no
airport. Corporate headquarters aze hardTy rushing to be near auports in South
Saurt Paul, Lake Elmo and Anoka.
This is the otd slippery slope issue. The argument to aitow the airport or any other use in
the flood plain is that it will have little effect on the floodplain. Then they argue they
should not be inconvenienced by floods.
� �-
�
Tom Dimond
2119 Skyway.Drive_
Saint Pau}, A'Il�i 55119
651-735-6667
January t7, 2006
I2E: Holman Field Airport Dike
06����
The Metropolitan Airports Commission is trying to put the cart before the horse. They
waut site plan approval and permits issued to s�art amsiruction before they seek cfianges
to tke Critical Area Reguiations.
Sec,61.402.C.(2) requires the Plmming Commission ta fmd that the sife plan is consistent
with applicable Ordz�ces of the City of Saint Paul.
MN Stalute116.G.12 subd.3. states if plans and regulations for au area of Critical
Concern have become effective under the provisions o€ section 116G.07. the local unit of
govemment shall permit development onty in accardanee with those plans and
regulations.
The Dike is prohibited under Sec. 68.2f4(h} of tLe Saint Paut Zoning Code.
Sec. 61.402.G (I) requires the Pdanning Eommission to fmd that the site pkm is
consistent with the City's adopted Comprehensive Plan.
A 9 feet tall steel wall on the river side of Bayfield Stzeet would completely block views
and access to the river. Imagine a 9 feet tall walt along the riverside ofMississippi River
Boulevard or Shepard Road.
'Flie Mississippi River Corridor Ptan 4.2.4 and 6.2 calls for preserviug and
improving eaisting views to the river and enforciag tfie 50 feet setback.
Sec. 61.60i. �'ariances.
'£he board af zoning appeals sfiall have the power to grant variances from the strict
enforcemeut of the provisions of tYus code upon a finding that:
(a) The property in question crnmot be put to a reasonable use under the stricf proviszons
of the code;
�
�
�
The airport has operated since the 1920's and will cvntinue to operate with or
without the dike.
�
,� t � -
�
�
�
(c} The proposed variance is in keeping with the spirit and intent of the code, and is
consistent with t&e health, safety, comfort, morals and welfare of the inhabitants of the
city,
The Code prohibits community-wide structural works intended to remove areas
from the regutatory floodplain.
(e) The variance, if grantec� would not permit atry use that is not permitted under the
provisions of the cade for the property in the district where the affected land is locatec�
nor would it alter or change the zoning district classification of the property;
The stated intent of the variances is to atter or change the zoning district
classiTication of the property.
Sec. 68.6�1. Vaeiances.
(a) Applications Por vaziance to the provisions of this chapter may be filed as provided in
section 61.600. The burden of proof shaII rest witL tfie applicant ta demonsfrate
concInsively that such variance will not resutt in a hazard to life or property and
will not adverselg affect the safety, use or stability of a public way, slope or drainage
channel, or the naturat environment; such proof may include soils, geology and
hydrotogy reports wluch shall be signect by registered professionat engineers.
Variances sHalt be consistent wrth the genera! purposes of the standards
conta'rned in this chapter and state law and the intent of applicable state and
national laws and programs. Although variances may be used to modify permissible
methods of flood protection, no variance sfia1l have the effect of atlowing in any
district uses prohibited in that district, permit a lower degree of flood pratection than
the flood protection elevation for the particular area, or pernut a lesser degree of flood
protection than required by state law.
Egecutive Order 79-19 states that fhe Mississippi River Critical Area is to preserve
and enhance its naturat, aesthetic, cultural and historic vatues. The destruction of
habitat, ioss of natural shoreline, the loss of views and access from Ba�eld Street
aiong with negative visua( impacts from the river created by a 9 feet tall steel wall,
are but a few of the impacts that are not cousistent with local, state aad federat river
corridor standards.
MAC has not demonstrated conclusively that the dike can not be setback 50 feet, how
they intend to deal with pollution and water quality, impacts on endangered species
including the Baid Eagte and Higgin's Eye Pearly Musset including a survey and their
plan for maintaining the compensatory excavation. The EA is largely silent with the
promise they will survey and develop plans later.
��
06°3b3
Tom Dimond
2119 Skyway Drive
Saint Paul, NIlV_ 55119
651-735-6667
7anuary 7, 2006
RE: Holsrian FieTd Auport Dike ZOQS-7386-TJF,
The propo§ed dike is tocated in the State designaxed Ivfississipgi River Critical Area and the
1V�ississippi National River and Recr�atioual Area. The 1Vfississippi also has Federal National
Rivers Inventory (NRT} designation, The Mississippi River Corridor Plan-catls,for proteeting
and enhancing the natural aud scenic values o€the river. The Plan also catls £or protectin� and
enharicing access to the river and views to and from the tiver. Tkie gropo "secl dilce is aot
consisteirt with Saint PanI's River Corridor Plan. The dike is specificalty prolu`bited.
��
At the heart of river restoration efforts is preserving shorelines in their natural state and
resto�ring shorelines. The Saiut Paul City Council and Planning Commission revised the
Zoning Code to prohibit the practice of building floodwatls urtended to remove areas of
shoreline from the floodway. Newspaper reports indicate that Saurt Pau1 City Council
Members and L,egislators strongly support the effort to save the shorelix�e from further
encroackment aud 8o not support the aiiport dike. �
$ec. 68.214 (h} states that community-wide stractura! woc�s for tlood con4iol intended
to remove areas from the regutatory floodplain shaIl not tie allowed in the flaodway. The
8/5/200� ema� stating tliat the CLOMR revises e�zistiug floodplain mapping from �RCl} to .
(R�2) is not correct. Zoning district and Critical Area regulation changes must be made bp tfie
Ciiy Council. The June I4, 2005 P'IIVIA Iefter ctearip sfafes tLat tC►e ELOMR is based on
"minimum" criferia and more restrietive community criteria take precedence over tfie
minimum NFIL' criteria. Sec_ 62.I00 stafes fliat wlienever any provision ofthis code imposes
more stringentrequirements, tegulations, restrictions or limitafions than are imposed or
required by provisions o� any other law or ordivance, ttien tfie provisions of this code shatl
govern
Executive Order 79-19 states that the Mississippi River Criticai Area is to preserve and
enhance its natwal, aestketic, cultural and historic values_ Tke destruction of habitaE, loss of
naiural slioretine, the Toss of river views and access from Bayfietd Street along with negative
visual imgacts from the river creafed by a 9 feet tall steel wall, aze buY a few of the impaets
thal are not aonsistent with loca}, state and federal river corridor standards.
�
The cost benefit ratio is onTy 1_21 _ Consiste� with tfie principles of casE benefit analysis costs
and benefits are (discowrted) convertecl to presem vaIue terms. Tfie discowrted cost is $24.'7 "
million and discounted benefit is $29.8 million over a 50-year period. Costs exceed benefits �
until the year 2033. The 1VIAC CIP adopted Becember 2005 sets tfle 2006-2007 dike oosts at ��
�
Ob-3b3
�
u
�
�28. Smilion: "Fhisis up from the $22.4 million in the draft cost benefit analysis. The updated
costs have probably moved this projecY eyen closer to a breakeven or negative cost bene£'it.
The cost benefrt ratio is low and based on inflated benefits and discounted costs. For
example, the benefits are inflated by using airport delay costs based on otd numbers before
Northwest filed for bankn.iptcy and dramaticatly reduced the number of operation at MSP.
The August 4, 2065 MN DNR letter points out that the EA does not provide a monitoring plan
or an anaIysis of frequency of excavation to maintain the compensatory excavation. �tfiout
an excavation maintenance plan and analysis to support the plan there is not a sound basis for
cost benefit analysis.
'£he report states that the airport is the priniary reliever auport for MSP. In fact, Holman
Field ranks last in takeoffs and laudings ainong the xhree airports established as 'Tier E
reliever airports. Holman raiaks last in aircraft based among all reliever airports.
The EA states that only 7 aircraft based at Holinan Field need a runway longer than 5,000
feet. Anoka and Flying Cloud have 5, 000 feet nxnways planned. The Floodwall reduces tlie
runway to 5,509 feet as a non-precision inshument runway. R!ith only a 10% increase in
length, Anaka and Flying Clond can provide the same length as a precision instrument
runway. A safer and lower cost alternative. The EA states, that option is not pursued
because it is prohibited. The Dike is also prohibited. Either proposal requires a change of the
law.
Sec: 68.402(b)(1)b. requires the placement of all structures at least 50 feet from the ordinary
higfi water mark. This wouid require moving the floodwall to the inside of Bayfield Street.
This would also retain pubTic access along the river.
Sec. 68,402(b)(2j No commercial or industrial development shall be permitted on slopes
greater than 12 perce�. Development includes excavation. The shoreline proposed for
excavation exceeds I2 percent.
Sec. 68.402(c)(7) No rehabilitation slopes shall be steeper than eighteen (18) percent. The
proposed dike and shoreland exceed 18 percent.
Sec. 68402(c)(S) Dredging of shoreland ar wetland shall be altowed only when it wilt not
have adverse effect on the wetland. The proposai would remove vegetation and not replace it.
Ongoing dredging would be required to maintain the altered depth. This would have an
adverse effect. �
Sec. 68.403(d) Naturat vegetation shall be restored after any cozrstruction project_ Trees and
bushes have been along this riverbank for years and there is no reason they can not be
restored. The shoreland along the Mississippi River is the most importaut flyway in North
America The Endangered American Bald Eagle nests and feeds along tlus section of the river.
'Fhey have a nest onthe opposite shore from the proposed project.
��
1 �-- ,�,:
��A5EY d� W}�iTNEY LLP
Ivli. Crary Vy&rTOn
Nove��icr ]3, 2602
Page 6
<_
�. �
Lastly, the Colps aIsv nateii disczepancieg regarding tlie data exi �e top eIevauan of the
dike and stated Ehe data from tjie madel is,depondent in patt on the chapnel bauk being eXcavated
and the dike haviz,g a�, elevation no highec tt 7os.0_ =� I£either of theso elements is changeii,
rhe modeling m�ut be modifed to include the chang�s and th� impact reevaIuated;' rd � 2,
Ratt►e�'than addressing tize significant issucs raised by che Coxps, the EAW sunply and
ecroncously asscrts; "T'jia bNR �� � Cr}� have reviewod fhe revised model attd otin�ur ��
its assessment o£thc effects of the proposed pi�oject (0.03=foot maximum increase)." T'�iis ,
posifion cltarly runs counter to the facts. T'he Cotps cleariy spccified that there was additional
work to be don0.
On the basis o�the above, �hore is no substantiaj svidence supporting tlie cffectivencss of
tha proposcd mitigation meesures. Therefore, an ETS is requiral, . �
B• The Proposal #or Weflands Dcstructian
e propose pro�ect, the MAC w�ii fi112 portion of tfi.e existing Zp_acl� wetland.
't'his action will present a potcntial for sigznficant anvironmental effects, sa ihe p�-o��� requires
an BIS. See, Minn, R 4q�10.9400, subp, 20. The EAW also fails to considercomptiance with the
Mzssissippi National River stut R,ecrea�io� �e$ Comprehensivc Managemenc Pian as required
by [he EQB regulations, atid is t�erofom insufficient to support a ne,gative declaratian.
C
�
Under th d �
'I'h� MAC propoaes to fill a portion of DNR �vettands No. 62-3 near the southem
bouztdazy of the airport. 'Z'Ite �AW doscrib�s i;hepropo5al as follows:
The praposedproject wili fil! about 0.85 acres of the
aPpmximately 2a DNIt weHaxed No. 62-3. This is a type 3-4
wetland at the southem boundary o�the Ai�po� H of Rwnway
1432_ 'The &moculf of replacement acreage will be providad in
acwridance with the bNR aud COH permit requirem�nts. '�'his
weEland comprised a�pmxittiately 86 acres iri 1g7g. 't
consavction af the Runway I4-32 Now Buitding Area in the .
] 980's filled approximataly 65 aores, whiclz has heen replaeed
elsewher.e in the 1VXetra Area
----- I�LA�, �isvironment.al �4ssessntent �Yprksheet: Flood l'rolection, St. Pnu1 Dotivn7own Airport .�
(Holman Field) at 9 (Oct. 2002). �
�.
Zc is tnzdisputed that the project presents a potential for si�jnificant environmental effects, .
and tha only issuc is whether the I�ar[n is subject to mitigaTion MAC contends that by
complyirtg with oxistiqg regulations, and creatiag wettand elsewfiere in tht area, the halm witl be
�
iur. �a� w�.�
November l3, 2002 °
Pgge 7
--�
DORSEY & WHI"CNEY LI.p
Ob=3{,3
mitigatc� I , wetlands in tht Ivi�ssissi i
���insf pubiic polic ,�y PP �iver eorridor are sca �d
xwin Cities corrido of the 14Iass I 55�ai�R�i� wetlan@ elsewhcre wiij not miti ato't�h �� them is
PP er. $ � harm to the
� 1 9$$. Congress esfablished tho Mississip�i NationallLiver a�d Recreatioa � � a
pan oFthe national paik Sy9tec�. ����]o prot
wa� ��d � o��e Mississippi 1Ziver C mdor withinithe Sai�tPau15��� v
Metrop�>litan A.rra" 16 U.S. alues ofthc
C Ca C. § 460zy. Congress establishcd the Miss�� A ��� 1 �
8 mrraission to @evelap a eomprehengiva plan to carry ouc the purposes of the �aw,
1 � U'�'C• § 460zz-2• Ausuant to [he law, fhe Commissioa has issued the Mississi
Rivcr and Rec2'eation tltea Comprel]ehsive Management Plarl
resource manageruent, the plan calls for "rigorous" protection of wetlands. The pIa�.t Nationa�
(Plan). Vu'ith respeet to na�j
specifically providcs:
� �'loodplains and v, at�e listed as sensitive resourees in this
plan and aro a hi riorit or rotection in t orrid . Thay ate
�rry important azeas" o redqc' g the adv �P FF
snaintaining watar ualit � � of filnn�t,,,..
viswal variet �d q Y' Pr°ridu'g "v'idiife habitat, pns��
Y, rriaintaining biological diversity, he shouid
be reserved res(6re and inc sed in c cozri r. 'I'hey will be
proteCtad and enhanced by i�tcreased education offorts, open space
acquisition, preservation incontives, voluntaryprp�ams, an@
rigorous imp of exis[ing state 2nd #'ederal l��y an d
executive orde�. �� National Park $en will wox� with ocher
ageuoies with Iogd �ponsibilities in this area, including the Corps
o£Enginect�s, the TJ.g, pish anc3 Wildlifc Setvice, �n�o��ntal
Protection Agency, and Minnesota Departm�t of Naturat
Rcsources to emphasize resource protection and cooTdinato their
activitics.
Pla� Natura! Resource Management at 5 em hasis added), Under t31e p�an� Wo�j�d protection
is a`.`higkl priority forprntection i � P ,�
:cstored, �hd irzcroased in the cozzi pr"cand �xplains e la ds serya to��duag f�h��
��� n��?�? � be pr P��d is cicar tllat creaking wetlands elsewhete �i(j hot mitiQatr�-rtiA-h�...,_
�QR' addirion, eho EAW is_ofh,ezwise de�cient and do�s not support the proposed action_
s EAW guidelines s�ecificalIy zequirc information on compliance with mar�a
s;
, $etnent
�•
�oN7
��
� . .
Mr. Gary Warren
Novemtier t3, 2002
I'age 8
DO�gEY Ss Wki(TNEY I,LF
-'. .� . �� � .:
Discuss whether the project is subjeFt to any official governitiental
managemen,t plens adopted for tho area, .:. If the proj ect is .
subjoct to a plan, the EAW should iden6fy its r�uirewents
relavant to tha project and discuss how the project complies Wit$
the plab The RGU should consult with the government unit
xesponsible for.tha implemantation of the plan regazding provisions
that relate to the project and about the consistez►cy of the project
with the pian. Emphasis in flto �AW should be giv�n to aziy
confiicts or incompatihilities.between the pioject aztd pian
provisions that relatz to.the environmant or use of natural
zesovrces. �
EQB, BAWGscidelines;.PrepartngEnvironmentalA.rsessmenr Worksheeu at 13 (Fnb. 2000).
The EAirJ �n this casv compJetely fai ls to co�ply With the guidelinos; it merely states:
"[fjivat design and construction of thc proposed pmject would be consistent with .., the
-. Mississippi National River and Recrcation arca plan:" MAC, Envfronmerital Assessmerit
Worksheet: Flood Proiection, St. Pau! Downtown Airpot (f�oTman Fietd) at I 1(October 2002):
The EAW does nnt idetzrify the zaluirertients ofthe plan or discuss whother the projcct complies
with tha Pian. Moreover, there is no indication MAC discussed eqmpliance with the Plan, with
otha agen�ies. Rinally, the EAW is compl�tely void of any discussion (mucTt less th� required
emphasis) rEgatding tho obvious conflicts or incompatiUilities behveen the projeet and plan
grovisions. �
An ELS is required to address the enviroiunental impacts associated With the proposed
desffuctian of wetlands. -
IV. "fhe EAW Fails to Consider t6c Tncreased Use of Holmau Fteld
The:EAW also fails to considcr the increased use aqd tr�c at the aitport following the
mmpletion of the gro�ject. Without infomiation aUout future use, M�C dnas not have aufficient
information Yo make a detemiinativn regard�rig sama pf thc most significaat environ�ental
effects. Under thest cireuznstances, a nCgative deelaration 6ased on the �AW would be
arbirzaty, capricious and an abuse of discration. . "
3 +`
�
_ _ _ __ _ __ _ _ — - — ThFenviroumehta�review-process is, hy its�ery ttature; fonvai=d=loolung. - T�puiposeis
to review the reasonably an6cipated consequencas of the proposed action before Yhey occur. If �
the dike is consisucted, �Tolman Field will be �ore attractave to patential custoiriers sinee it may �
provide a stronger measure of flood protection The EA�V, hoWever, did pot take izlto account �
ihe likCly inerease in airport use when it identified and assesscd environmental ircipacts. �•
��
�
�
s
06-3b3
�
riORSEY & WH�THBX LLP
Ivlr. Gary Warren
Nove��ber T 3, 2002
Page 4
'Phe fiQH's �AW regulations list the informarion w}uch is considered ``the basic facts
necessary" to dcter�ninc whether an EIS is required- Minn, gtat, § 116.04, subd.. Ia(c) (200,2)
A.s disct�ssed above, the regulations oall for a raview of a wjde tange nf xs�ues, n�any of wirich
eouid be impaeted by increased. use of the airpoxt, The E.q'4y essumes t��n �11 be na increasa
in airport use following the coinpjotion of cheproject. I'his assuuipnon is completcly
unwaCtanted, parilculazly In light of T�n]man Field's�rolc as a reliever airpoxt, and pend'ulg
proposals ta limit the use of other relievez airpor[s_ The EAW run,s countci� to the evidet�ce, artd
azty reliaitce thereon is azbitrary, capricious or an abusc of discretion,
t'. The Ecouocnic A.nalys➢s Runs Coanter to the �vfdonee
Tbe cost benef i arraIysis provid�d in the �AW is incomplafe and �
Z'ho .EAW states "[t]ha econoxnic benefits inc�tide proteoting �l�c substatitial priyaze �a .
blic invesiment made ak Holman �ield during the p�t 76 yeats," 1ySAC, Environmental
essncent T$orksh�ef: FTood proLectton, St. P�zulDorvntown Airport (Flolman Pleld� at 3
October 20p2). T}te eoets, }�owever, clearly oufweigh tht benefits, According to an attachment
to the ���y, C11e proposai will cost apptoximately $25 miliion. MAC, P,oieeting Xalman Fieid
from Flooding: ���f�� the Com�nunity Wlrile MlnimizingAdverse Consequenoes jor
Neighbors at 12 (June 2002). There has been a f�QOd approximately every seyen years on
average i� ch� last thitty years— #joods have occurred in 1965, 1969, 1993, 1997, �d Zp01. rd, ag
1. The report providea the following zz�formatiori on [he co&ts of flaods�
Coets associatod with the �tooding are eaorm,ous. Tha MAC°s
typica] cleanup cpsts immedisicly after a �lood are approximateIy
$300,000 to $4pp,ppp, T7�ese cleanug costs do not include repairs
resulting from daznage that sl�aws up muah later. �
Id at 12. No additzonal information is gmvided an costs. Nonetheless, even assuming the oosts
per flood e�vent are $1 million and a£lood occutted every four years, i[ would ta[�e I0� years to
recoup the $Z$ million iz�vesknent, even under these very conservative assumptions.
7'his expendi ture mttst ba balanced against reeent testimony by MAC indica[ing that cuts
need to bc mada aemss the MA,C systerz�. According to a rccont ac{icle in the Star �`ribup�, 7eff
F7a�nioI, MAC's Execuliyc D'ueetoY has receutly stat_ed.d�e.airline-iadustry"asin-tcmblc ----- ----�
condition" and is a nced to make signifcant reductions in expenses, ban Wazeoe; 7r„
Ri orr Gharler 2'erntihal May Close, Star Tri6une, Novomb�r 9, 2002, aE k�-1, T1ze article •
rn�. "A�ong Iiamiel's pmposals, clnsing the 1,8 month-old �Tur�phrey Terminat during .
ths �z%hen chartcr activity ie Iow—Tviay to October—zs a strong possihility. Id. Ij�dzniel also
;aid IvjA,(, �a n �� � taise parking #ees for employoes, closo its con ferozlcc center, and lay of�'
� .
cou `r.
1�.
��
_ . -. ,
�
�
bORSE'Y 6,, W�ITNEY T.�p.
m,
Mr. Gary Warren
November 13, 2002
Page 14
f, �
,
, -
�
empibyeos. ld To•contemplato exponding.$25 million far a di$e to address a situation thai has
heeu shp�vn to occur, nn average, every seven yeazs whilo considCrablc cuLs 3t'c b�itig Ynade - ��
e3sewhere zs conh�aryto goodpublic poI[cy Therofore; bascd onthe availahla iuformatio�, �°C
MAC's assertion that the banefits outweigh the costs of the pmposal is not supported by the
reCOrcL
y
Cnnclusion
1� or the reasons sra2ed h<xein, MAC should ies�e a poeitive declaration with respect xo #he
need far au $I$, bccause there. is a pottntial significat�t enviiqt►mrsital effecTs pYesantod by the
proposai a�id otlier ef£oots nat avaluated in the EAW. '�he pmpor course of action is to prepare
an EI�. .Moreovar; eve�, ff tixe defects noted above coutd be cured by additional study and (...
revisions to tha $AV✓, �fAC may not issue a negative doclaration unfil such additional wnrk is
completed and interested persons have had azt opporttinjt�T tq review and comznent on the
modifiecl EAW.
"�'T:tjb
xtes�eetfiilly subi2utted,
���,.y��... � .��---.__—�-
Tho�as Tinkham
e
�
� � .
a
��
06-363
Tom Dimond
2119 Skyway Arive
Saint Paul, MI�T 55119
651-735-6667
Febntazy 17, 2006
Those who are concerned about government pork, fleecing the taipayers or degradation of
the Mississippi River Critical Area, should be concemed about the proposed airport dike.
♦ MAC is not using actuai costs and actual floods_ Using the actual number of
floods and aohial cost, the cost benefrt ratio drops from 1.21 in the EA to less than 50
cents benefit for each dollar invested. This does not inctude the environmentat cost.
♦ MAC's Cost Benefit Analysis (CBA)lists tfie cost at $22.4 million. The actual cost
is $28.5 million_
♦ In the site plan application MAC uses the CBA costs, which they know or should
know, are false.
�
♦ MAC does not base the benefits on actuai floods.
♦ MAC inflated benefits by claiming 3 times more floods than actual. MAC uses 9
floods (100 year or less intensity) over 50 years to calculate benefits. Over 50 years,
there have been onty 3 floods of that i�ensity.
♦ FAA AIl� funding requires benefits to exceed the cost. The dike does not meet that
requiremern.
♦ Flood records show that 2 of the last 5 floods woutd have topped the dike. That is a
40 % failure rate_
♦ Northwest Airlines stated in a letter that e�cpending money on the dike is contrary
to good public policy and MAC's assertions that the benefits outweigh the costs of the
proposal is not supported by the facts.
�
Between the Draft EA in June of 2005 and the Final EA in 7anuary 2006 the benefits
magically increased. No basis for the change is provided.
Flood preparation benefits went from $359,35I to $ 410,912
DeIay benefits wenE from $17,2I1 a day to $24,962
Tenant benafits went from $3.1 million to $3.8 million
Ground transportation benefits went from $216,497 to $317,419
6
��
t,�
;
: F t
�. � . .. .� � * ,.�
♦ The Cost Benefit is based on Holman Field operations increasing from 134,377 to
256,280.
♦ The CBA model fias not been adjusted for the reduction of aircraft used by
Northwest including the practice of reducing flights to increase load factors.
♦ Zoning Code prohibits the dike.
♦ Sec.68.601 allows variances ta modify perntitted uses but prohibits variances that
have the effect of allowing prolu`bited uses.
♦ Zoning Code requires at least SQ feet setback from ordinary high water (OHR�.
MAC is proposing as little as zero setback
♦ A 9 feet tatl - mile long steel wall along Bayfield Stre� would eTiminaYe views of
and access to the river.
Are we willing to allow the railroad to build walls between the Science Museum and the
River to protect from floods? Are we willing to allow watls biocking views from Bruce
Vento Nahue Sanctuary? No community wide d�ces have been built since the adoption of the
CriticaF Area and MNRRA. If we open the door to more dikes, where will we draw the tine?
MAC Chair Vicki Tigwell letter dated Febcuary 8, 2006 states: No, the floodwall wili not
have a noticeable impact on aviation noise azound fhe airport. Aircraft operations fiave
decreased by neariy 60,Od0 annuat Iandings and takeoffs per year since t990. 'Fhe chart she
incladed shows operations declining.
♦ The CBA used by MAC to justify �ederal funds says that operations will nearly
double from 134,377 to 256,280.
♦ Tfie FQNSI is conditioned on St Paul changing the Zoning.
♦ The FONSI is conditionec� on any requirements established in the site plan review.
♦ The maps provided by MAC show the proposed compensatory �cavation is not on
�'Part P�F�Y-
�
�
�
�
�-.
%
�
Tom Dimond
2119 Skyway Drive
Saint Paut, MI�i 55119
651-735-6667
Pebtuary 10, 2006
RE: SaiFSt Paul Airport Dike
��a����3
To use FAA AIP funds a projeet is required to have at least a total discounted benefit that
exceeds total discounted cost. Tfie cost benefit ana2ysis dated November 4, 2005 has a
cost benefit of 1.30. There are some serious shortcomings in that calculation.
In practice, FAtI intecprets capacity projects to inctude those involving new construction
or reconstruction of airport infrastructure intended to acconunodate or facititate airpott
trafftc_ The EA page 2 Sec1. 2 sEates that the purpose of the d�1ce is to reduce damage. and
to reduce the impact that flood events have on the capacity oftfie Minneapotis-St. Paul
InternationaF Airport (MSP) and the National Airspace System.
� Airport capacity projects meeting a doIlar threshold of $5 million or more in AIF'
disaetionary grants over ttie life ofthe projeEt, and all airport capacity grajects
requesting LOIs must be shown to liave total discouuted benefits that exceed total
discounted casts. FAA letter dateci February �, 2t7(}6 proposes $8 millian in AIP
discretionary grants for tfie dike stFUCture itsetf.
Table 8 lists the cost ofthe d�ce as $22.4 million instead of �28.5 millioa.
�
Table 1 lists 08cM as $32,836 a year. Presumab(y ttus inctudes the cost of maiutenance
dredging. Can maintenanee, including dredging, be done €or au average $32,836 for 50
years? The Minnesota DNR letter dated August 4, 2005 stated: The EA does not describe
a manitoring plan to assure that the storage remains over time. 'Fhe EA alsa does not
provide analysis af frequency a€ excavation to maintain the starage. The BI�iR witl
require this information prior to issuing a Public Waters Work peimit. Tfie EA response
states: A monitoring plan will be developed in coordination with the DNR Bivision of
Waters. i4IAC witl fund any required maintenanee efforts for the compensatory
excauation area. Without a plan, what is the d&M based on and is it reaTistic?
Table 3 bases flood eosts an tenant input but grovides no documentation to support the
actual elaims. EA response &4 states that tfie tenant costs in the 3uTy 2005 draft EA were
$31 but have been revised to $3.8 million in the 7anuary 2QOb EA_ Again there is no
dacumentation to support these rnimbers.
� �
�J
� � � � 5 , ° �a.
Table 3 in the Draft EA lists MAC flood prepa.ratios� damage and cleanup at $359,351
The Final EA lists the cost at $410,412. There is no documentation to support tfiis_
Table 3 in the Draft EA Iists delay casts to airtines at $17,211 ger day. The Final EA lists
the cost at $24,961 per dag. There is no documentation to support this.
Table 3 in the Draft EA lists grouud transportation costs at $216,497. The Finai EA lists
the cost at $317,419. There is no dacumentatian to support this.
Tab1e 1 on page 5 Iists the 5#toads of record. Table I Iisfs the duration of fIoods as 31,
3I, 35, 35 aud 78 days_ MAC states in response &1 t.hat 84 days is the carrect figure to
use as duration of floods. Eighty percent of the floods listed in the EA had a duration of
35 days or less_
Tabte 4 bases preventec£ fiood damage on the assumption tFrat no fuhtre fIood wilt exceed
the 100 year ftooct tevel and the dike wilI not be topped. Twa of the five floods or forty
percem cited ia the EA as justificatioa for the ciike would have Yopped the dike. Even if
one of the floods togped the dike, it would reduce the projeeted benefits.
When forty perce� ofthe floads in the past fiRy years have exceeded the desiga af the
propose@ dike, is it reasonable to asszzme, that in the riext 50 years floods wilt never
exceed the design?
A positive cost benefit ratio is not supported by the i�orn�ation provided.
��
�
��
�
•�
�
�b-3��
5ection 1: Pi iTRODUCTION
1.1 Purpose of Guidance: The p�pose of this document is to provide cleaz and thorovgfi
guidance to airport sponsors on the conduct of project-level beueft-cost analysis (BCA) for
capacity-retated airport projects. It will facilitale the groduction of consistern, thorough, and
comparable analyses tt�at can be used by the Federat Aviatiau Ad� i�r*arion (FAA} in its
consideratian of airport projects for discrerionary fimding under the Airport Improvement
Program (AIP). Auport sponsors shoutd conform to the generat requirements of this guidance
for all BCAs submitted to FAA. However, auport sponsors are encouraged to make use of
iunovative methods far quantifying benefits aud costs where these methods can be sfiown to
yietfl superior measures of gmject merit.
1.2 Bacicground: On October 3I,1994, FAA simultaneously published "Po&cy Regazding
Revisioa of Setection Criteria for Discretionary Airport Improvemeat Prograui (`rrant Awards"
and "Policy for Letter of Intent Approvals Under The Airport Improvement Program" in tHe
Federal Register. These policies estabfish the requirement for BCA tca demonsuate the merit of
capacity pmjects for whicfl airport sgonsrns are seeking t�IP diseretionaty funds. In praeftce,
FAA interprets capacity projects to include those invotving new construction or reconstruction of
auport infrastruchae intended to accommodate or facilitate airport traf&c. 'Fke FAA policy
requiring BCA does not apply to projects undertaken solely, or prsncipally, for the objeetives af
safety, see�ity, confoEmance witk F�A standazds, or enviroumental mitigatiou. "ihe setection
criteria palicy for discrerionary grants was issued in ftnal frnm in October I994 and modified on
June ?tt, 1997, in the Federal Re `gister Notiee "Policy and Guidauce Regazding Benefi� Cost
Anatysis for Airport Capacity Projects Requesting Discretionary Auport Improvement Program
Gtant Awards and Letters of Intent." `Tteis madificatian esfablished doltar thresholds above
wluch BCA was zequired, teavsfefred the respon4ib"sllit�* foE �ccrmplishing the SCA from the
FAA Yo the airpart sponsor, issued BCA guidance, and requested comments on the tfiresfiolds,
the guidaztce, aud FAA forecasts of operations and enplanemenfs. The fmal policy on the
appficafion of BCA to Letter of Intent (L(}I} applications was issued on Beeember �5,1399.
AiEpozt capacity gm,}ectsmeeting a dollaz thceshold of $5 millian or more in AIP discretionary
grants over tHe Hfe of tfie ptoject aud a1t aiFport eapacity pro.jecfs requesting LOIs must be shown
to have tatal discounfed benefrts ttzat exceed tota2 discozmted costs. Projecfs for reconstmction
or rehabilitation of critical airfield struchues may be exempt from BCA requirements on a case-
by-case basis. Airport spoasors requestiag an exemption must apply to the FAA which will
consider the essentiat need of the ptoject, its timing, and wflether tfie estunated cost is reasonabte
and typicaL
� 1 �
�
�
�
Responses to Ciimb ttie Wind Institute Comments
79.
;1
��0����
See Response 80 beiow and General Response 2.
There is no requirement Eor a cost-benefit analysis in a Natianal Envizonmental Policy Act
(NEPA) document unless it is relevant to the choice of alternatives {Council on
Environmental Quality Regulation 1502.23). That is not the case for either of the projects
proposed in the EA. Therefore, no cost-benefit analysis was included in the EA. However,
the FAA rec�ires that a benefit-cost analysis (BCA) of projects•requesting $5 million or
more of FAA disczetionary funds show that the benefits of the project exceed the costs.
MAC has prepared the FAA-required BCA subsequent to issuance of the Draft EA and
submitted it to FAA for review and approval. The calculated Benefits-to-Costs ratio is 1.21
over a 50-xear evaluation period (2008-2Q57). Contact Bridget Rief at (612) 725-8371 for
a copy of ttte draft BCA. Also see Response 82 below.
81. The EA delay costs based on 84 days are correct — STP would be elosed 96 days (EA
Table 2) without the dike and sub-drain ptoject. The sub-dzain project saves 12 days and
the dike saves 84 days.
g2. 'I1ie 4d% of tl�e time statement is misleading and inaccurate. While it is Yrue that of the past
5 events, 40% of them fiave been greater than a 100-yeaz event, a lOQ-year flood typically
occuFS once in a hundzed years. Tfiezefore, to assume the proposed dike will not prevent
auport closure 40°fo of the time is incorrect.
83. See Response 8a.
&4_ The cited costs in the Araft EA have been revised in this F'inal BA. Costs to the tenants in
the 2001 flooct were appzoximately $3.� million instead of $3.1 miition, which would be
approximately $4_4 million in 2008 (dne to inflarion} in revised Tab1e 3. The $6,Q89,04Z
figure included lost revenue, whereas the $3.1 miliion did not. The "effeets" of lost
d I t fu I sates rentaI revenue, maiutenanee revenue, etc. L.ost revenue
revenue uiclu e os e ,
costs are excludecTin this Finat EA. See aiso Response 35.
85. Crround transpostation costs are measured for visitors to the area whose primary destination
is downtown St Paul. Nearly all af the aircraft bringing ttzose visitors woutd utilize MSP,
as it is the next closest airport to downtown St. Paul that has runway length capable of
handling aircraft of that size. Because each of thonsands of auto trips eannot be modeled, it
was detemuned that downtown St. Paul was the most appropriate point to measure the
difference in fravel distance.
:.
m
:�:�
See Response 80.
See Responses 80 and 84.
See Responses SO and 82.
��
'Fom Bimond
2I 19 Skyvuay Brive
Saint Paul, MN 55119
65I-735-b667
Februazy 9, 2006
RE: Saint Paut AirQort Dike -
��_����
To use F�i AII' funds a prolect is required to have at least a totat discounted benefit that
exeeeds totat diseounted cnst_ �� co� benefit anal�s�s dated Nqvember 4, ZOUS fias a
cost beue�fit of I_3E}. T`fiere are some serioiis s2iortcoEnings in that calcutation=
In pracfic� FAt� inferprets eapacit� projeet� to inciccde those ingalving,new construction
or recans�ruction of aupo� i4frastxucfure infende.� to accovimodate or facititate aitport
traffic_ The EA page Z Sec_ I_I states that the putpose of the dike is to reduce damage and
to reduce the impact tfiat ffaods events have on the capacity of t�e Mnne�polis-St. Paut
Infernational Aifpott �S�T} and t�ie Natioisat r�irspaee �gstem�
e�itgort oapacity projeces meeking a datia� thres�old af $5 million ar mare in tIFP
diseretionary g5ants oves the I�f`e o€t6e proj� and alf a.ir�or� eaP��Y Pr�1� �e9t1eSUng
LOis must be shov�m to fiave taf�at di'seouuted tienefifs tBa€ exceed. fotal, discountec� cbsts_
FAtI tette�' dat� FeF�rtiai�t 7, 2d06 propgses $S mill�on i�t A� digerehci�iazY g�.u�g fOrthe
dike str�ictur� i�et€` . . : .. ' ., . . ; ' : ,
Table Bliststfie ecis€v€th� d�e as 5���4 mitlio� znsEeac�af �28_5 mi1TiQ�
Tabte 1 Iisfs E)&14f as $3Z,&3fi a y�. Pre"s�veabTy tf�is irieludestfie eost of`maintenance
dredgin� C�a maiatena�iee inctud'ui� dre�n�6e done €a� a� averag,�,�2,83G fof SQ
yea;s? 'Fhe Iy�nnesota DNR Iette� dated tlugust 4, 2dQ5 state�£ 'Ffi� EA daes not describe
, _,
a moatEoriug p� �o assnFe t�iaf. the°storage're�iazns oveF tune: Tfie �t� atsa �oes not
piovide azsatpsis offrei�tieitc� of �zcavat[oie tc� mamfaEi�'t� storag,e'- `ftie k31� wi�
rec�e�ikce tlus information grio� to issuing a P��t� Rt`aters Wor� permit� 'I'�ie � response
staEes, t� mcrnitoring �tau witl be devetagect it� cvardFnatioa r�vith the 73NR Bivision of
Vtra�ers� �fA� vv� fiEac� asiy reqiured'mairitenane� effi�ifs fo� S�ie eompeiisafgr�
e�avatio€� are.a: R�`�iout � g3�wTia� is the d8c1Vi Uase� og anc� i"s i� realistie?
�
�
Tabte 3 bases tlood eosEs on tenant iup�it but gFavid@s na dacumentatioff tQ supgort tfle
acfuaf clatius_ � respavse 84 stafest�tlie fenant �i2sfs i� tlig 3uY� �(IQS dtaf�EA� were
ua
$3_ 1 but haue been revised to $3_8 m�ot� in the 7anuary Z006 Etl. Again there is no �
documentatiag to suppor� t�ese num�ers: �
��-��3
�
�
�
Table 3 in the Draft EA lists MAC flood preparation, damage and cleanug at $359,351.
The �inai �A fists the cost at $410,912.
Table 3 in the Draft EA lists delay costs to airfines at $17,2I 1 per day. The Final EA lists
the cost at �24,961 per day.
Table 3 in the Draft EA lists �ound transportation costs at $216,497. The Final EA Iists
the cost at $317,419.
Tab1e 1 on page 5 lists the 5 flaods of record. Table I lists the duration of floods as 3I,
31, 35, 3S and 78 days. MAC states in response SI that &4 days is the correct figure to
use as duration of floods.
Ta61e 4 bases prevented flood damage on the assumption that no future flood will exceed
the I00 year flood ievel and the dike wilt not be togped. Twa of fhe �ive fIoc�ds or forty
percent cited in the EA as justificafion for the dike would have topped the d�ce. Even if
one of the floods topped the dike it would reduce the projected benefits.
When forty percern af the floods in the gast fi8y years have exceeded the design of the
proposed dike is it reasonabte to assume, that in the next 56 years floofls will never
exceed the desigtt?
l �
�
Tom Dimond
2I 19 Skyway Drive
Saint Paut, NIN 55119
651-735-6667
Feliniary 6, 200b
, :.t , , .
FiIiM is a Ftood Insuranee Rate Map. CLOMR is a Conditional Letter of Ivlap Revision
(insurance map). LOMR is a Letter of 1Vfap Revision (insurance map}. Insurance rate
maps are a consideration but certaenly not the only consideration when estatylishiag
zoning protections for the Critical Area,
The CI,{}MR letter dated 3une 14, 2005 states that FEMA is commenting on the pro}ects
proposed 'unpact on the �taod Insurance Rate Ivfap_ This is a review of propersed tlood
insurance rates, not a recommendcrtion or enviromneretal review of the proposedproject.
FEMA reqszires that to participate in the 400d insurance program, communitie's must at
Ieast adapt FEMA miuimum standards if Ehese protections are not euzrentty in ptaee.
b'EMA part 60 subpart A states tbat any floodplaia m3n3$ement regulations adogted by a
community whieh are more resuicFive than the cdteria set forth in fhss part aze
encauraged and shalt take pr�edence.
The cuirent Sai2rt Paut Zoniug Code exceeds the minimums in the CLOMIi. As stated in
the CL�IVIR the more restcictive criteria take precedence. No mag revision 'ss requireei_
FEMA does not requae communities to reduce their criteria.
Any snggesfioa thaf Saint Paui is reqaired bp I'EMA to reduce river corridor
protections to permit the prohibited d�e is f�ctuaQy ivaceurate. It i4 absurd ta
suggest that Saint Paut does not Have ffi� Iegat authorify to enfarce the protections
enacteet uader the Criticai Area Act because of insnrance rate maps.
The Comprehensive Piau 42_4 states that the City will cosrtinue to enforce the 50 foot
shoreline setback for structures. The 50 foot setback is part afthe Zoning Code approved
under Criticai Area and MNRRA'Fier 2 status.
Zoning Code requires at teast St? feet setbaek from aedieary 6igh wate�' OHW
MAC is proposing as littte as zero setback.
MAC azgues yon should use past floods to justifp the large e�eadihue of ta�ayer
dotlazs but not fo cateutate it's success.
Saint Paul IIood records sf►ow that the propased dike desi�u wuuid have faited 40
percent af t[�e t�e. Two of five floods have exceeded thel(ltt pear flood design.
`�
�
��
06-36�
�
Northwest Airtines Tetter stated ta contemglate eapending $25 million for a dike to
address a situatiou Yfiat has been shown to occur, on average, every seven years
while considerable cuts are being made elsewhere is contrary to good public policp.
Therefare, based ou tlte avalabie infarmation, M�C's assertioa that ttie beaefts
outweigh the eosfs of the proposai is nat supporEed bg the reeord.
Tke Metropolitan Council stated the EA is largely silent on the poteatial that wi11 exist
for the Mississippi Itiver water quality degradation as a resuh ofthe progosed dredging.
Tke MPCA states they believe the proposed construction could encounter contanvnated
fill and that Polyaromatic Hydrocarbans and metals have been found dvring previous
investigations_
The Unifed States Environmental Protection Agency stated the document was given
a cursory review, but other worktoad priarities precludecl a defailed review aud
commen�. MPCA staff for Sec. 4Q1 review has been eliminated. MPCA eapressed
their intent to wave review. Federal and State cutbacks of fnnding for
environmental revievr have effectiveIp left it uQ to the City. Tite Cify shoutd nat
approve the site ptan before pottutiog confrol and poButioa prevention plans are
devetoped and the public hss had a cha¢ce to review and eomment on those plans.
� The Minnesota DNR points out that H'iggin's Eye Pearly Mussets, a Federally and State
listed endangered species along with other state-listed mc2ssels may inhabit this stretch of
the river_
The EA responds tiiat mussels are not abuudant becanse of loss o€ habitat via
riverfront devetopmeut, dredgiug and indusfria[ activify. Their praposal is more
development and. dredging.
Page 29 of the EA states thai tfiey did a site visit in December 20Q2, to look for the
existence of rare plauts aud animats.
Hard fo imagine why they did not find rare piants and animats during December in
iLliunesofa. Suow, hibernation and ruigration eauId have faetoeed in.
ff yoa haue auy questians about the validity o€the EA tum ta gage 34 Visuai imgaets.
The EA says that views to the river fram Ba�etd Street shoaId nof be signi�cantly
afTecEed. Aefually fhe vie� to the river will be completely elimanate� by a steel wall.
Table 7 page 14 faiIs to list that Sauct Pau1 Zaning Code would have to be changed to
perntit construction.
� The Dike is prohibifed under Sec.68.214(hj of the Saint PauI Zoning Code.
� �
�
Tom Dimond
2119 Skyway Drive
Saint Paut, MN SSI19
65I-735-6667
February 2, 2006
When the City Attomey was asked if the dike was prohibrted, there was some conflicting
information. The City Attomey correetly stated: t�e dike is proIu�bited hy the Saint PauI
zoning code. Incorrectiy, it was inferred that it was a circulaz argument because FEMA
required fhe City to adopt ttie ntiaimum sEandard estabTished ia a LdMIi tfiat would
allow the dike. FEMA clearly states in their reguIations and the CLf3MR t1�at more
resh community criteria take precedence over the minimum NFIP criteria. FEMA
does rnrt supersede the City when establishing wniag districts.
There is agreemeat that the dike is grohibited by the zoning cade.
Sec. 68.2I� Standazds for coaditioaal us� m the RCl Floadway I)isfrict
(h} Stmcturat works for 4aod conuol tbaf wilf cBange the coiuse, caaem or cross-section af
protecfed weflands, ar pablie watecs sbatl be subjed tathe p[ovisions of Minnesota Sh�s,
Ci�aptec 103.G. Comnnmitv wic3e stme[m�a[ wodcs for flood eontrol mten� to remove area
Sec. 68.IOL Estabfiahmenf.
(d) Witie� these disEricts aII uses not atfawed as uefmitted nses ar as neamiftedu�s subiect to
�ial conditicros shaIi be and aze fierebv vroLffiitecl Legat nonconforming stcuctuces or uses
e�stmg on the effective date of this cLapter or amendmenttheteW wiH Ue pexmittedto continue as
provided in section 62.102 and sedion 65.90t►.
There is not agreement, thxt the City has no choice but to adopt ttie �EMAminimum
standazds.
F'EMA Pazt 60 Subpart A(d� states any community may exceed Yhe minimum
standards and any tIoodplain manageme� regutations adopted by a commnnity
wlucfi are more restrictiye than the criteria set fo�th in t�is Part are encouraged
and shail take precedence.
The City is required t4 grotect at a minimum, the area FE14Ft� designates as the
minimwn necessary. FEMA also encourages additional protedion_ An area Iarger
than the minimum can be designa�ed for protection based on a number of factors.
Naftual resouree protection, accommodating firture grovath ugstream and
providing for unknow faetors are some af the reasons to protect more than the
minimum required.
�
�
There is not agreemern, that tlie zoning code requires the use of F'EMA minimum (
standards. � I �I �
Sec. 68.1Q2. Establishmefxt. �" I
(a} TLis cvapter sl�alt apptp W all Iands withiu the citg sIwwFC on tfie river corridor avesiay zcmin
district ma� as being Iocated wittun the boundaries of tfie RCI River Corridor Ftoodway l7istnct,
Ob-3��
� RC21Ziver Coiridot Ftood Fr�ge Dist�ct, RC3 River Corridor Urban Open Space 7hstnct a°d
RC4 Rivet Corridor U�iran Diveisified District �m in this river cairidor code, togethei
Cb) The river corridor overlay zoning district maps P�3 g af tbis cade as
with all mattecs atfached thereto, are kerebY a�Ptedby refe d�:nTxd he�� 1Tte affached material
if the mattezs and information set forth thereuc were fn}�y
sLal� inefude:
f t4 Prei�� bY the Federai Emergency NFanagemenf
(I} The flood ivsurence study or the ei
�ea�y, (��A}, dated ApiiF 2, 2003; and
(2} The Fiaod Fnsisaace Rate Map, dafed Apr�12, 20(13.
(c) The RCI FtoodwaY Dlstncf st� �c� �O� az� �� � 400dway and Zone AE
without a IIoodway designation on the Flood Insinance Rate Map. The RC2 Flood Fringe District
shall incluc}e ffiose areas designated as Zone AE anki outside af tfie floodway on the F1ood
Insurdnce Rate Map.
This shaws thaC the curre� RCl disttict is based on FEMA minimum standards.
Untess this seetion is revised the gmposed dike ss prohibited ander these
standards_ Iftlris secCion is revised, the City Council is not precluded from
adopting more restrictive criteria. As stated above, �MA encawages
commututies to set more restrictive cri€eria.
There is not agreement, that the City must change iYs zoning maps if a LOMR is issued.
� FEMA requires a map revision if the miniinums are nat met. FEMA does not
require a community to reduce profections to the minimnm. Since the minimums
under the L4MR are akeady protected under current wning, no revision is
required.
In school yoa a.re required, as a minimum, to geE a C_ Teachers e m C O ect that ��EMA
better_ �MA also encoutages us to do better. It is }ust factually -
requires the Ciry to reduce protections to get dawn to the minimum_
� �
�
�
o �,����
Sheldon Johnsan_
State Representative
bistrict s7a
Ramsey County
August 4, 2005
Bridget Rief
Metropolitau Airports Commission
6046 ZB�` Ave S
Minneapolis, MN 55450
612-725-$371
Fax-6!2 794-4407
Re: Draft Environmental Assessment
Minnesota
House of
Representatives
Received
AU6 � 5 ZOQ5
Airport Development
The proposed dike is loeate@ in the state desigiated Mississippi River Critical P,rea and
the Mississippi National River and Recreational Area. The Mississippi River Cotridor
Plaa ca11s for protecYing and enhancing Yhs natural and scenic values of the river. The
plan also ca11s for protecring and enhancing access to the river and views to and from the
river. The proposed Perimetez Dike at Holman Field is not in keeping wiYh these efforts.
The isscte of the triew�shed is especially relevant given the amount of work and money
that has gone into esiablishing the Bruce Ven#a Nahue Sanctuary and flie Sam Morgan
Trail (directly across from the proposed sheet pIle dike), as well as the view fxom
Mounds Pazk. '
Sec. 68.213(� of the
infent is to praiec# az
Sincereiy,
(x��e�����
Sheldon Johnson
State Representative
U.SC
� .�^"" Y L���
Kathy Lantry
CityEouncii President
City of St. Pau(
tha.
�'
3f.
�
�
: .._ � -
� �
229 State Dtfice 6uiMing.100 Consfitufion Ave.. St. raut mmneso�a o� �o:,-,<.�., � .Faac (fi51)296-4165
� at Email: repshekion.johrtsonl�hoasa.ieg.siafe.mn.us
M
�
��
; �\�rriy.
,�. _►�'-_-�,'�'.
�: ��'
`�'_—'�-
7N RFPLY REFER TO:
L8024(MISS)-2!B
August 4, 2005
NATS023AL PARK SERVICE
�ississippi National River and Recrea[ion fuea
11 i E. Kellogg Blvd., Ste. 1Q5 '
St. Paul,Minnesota 55101-1256
Bridget Rief
Metropolitan Aiiports C.ommission
6U40 28�' A�enue Soutf�
Minneapolis, MN 55450
Dear Ms. Rief:
�@CBtV�d
All� 0 5 2005
Airpor� Development
Our office has reviewed the Draft Envirorunental Assessment (EA) for the proposed Perimeter
Dike and ltunway Safety Area 3mprovements Project a# the St. Paul Downtown Airport (Holman
� Field). Holman Field is located entirely within the Mississippi 23arional River and Recreation
Area (MNRRA), a unit of the Narional Park System. The MNRRA was established hy Congress
in I 988 to protect and enhance the nationally'significant historicai, reoreational, sceniq cultural,
natural, economic, and scientific resources of the river corridor. Tl}e National Park Service is the
primary advocate for national interests in the comdor and has inandated review responsibiliries for
federally funded orpermitted activaties. The visions and policies of the MNRRA Comprehensive
Nlanagement Plan (CMP} provide guidance for Nadonal Pazk Service review of this and other
federal actions in fhe corridor.
General Comments
We recogzaze that the St. Paul Downtown Airport has played ari important role iri Saini Paul's
history and continues to make a significant contribution to tfie economy of the Twin Cities. We
atso realize the inconvenience and hardship experienced by anport users, the aitporf itself, and
the regional airports system when major flooding forces its ciosure.
While we unders#and che desire to provide reliahle air service at Hoiman
major flood events, we must also note that �
�-
�
,�.'. y
"1`e PiilT:uriplementahon o tfiese goals is difficult to ac i�ve m e context o auport
operational needs, tiest efforts shouid be made to m�imize the integration of MNRRA CMP
goals in this plaiuung effort. .
United States Department of the Interior
�
�
Figure K
7raii between Wamec Road
and the Mississippi River
Figure L
Ben Thomp�on's vision of
"The Gr�at River Park"
0��- ��;�
future growth and development with restoration �
programs that reconnect and resLOre remnant natural
communiries. �
4.2.3 The City will continue to suppart the efforts of
organizations such as Great River Greening eo restore
native grasses, shrubs and trees ainng the riverfront
downtown and elsewhere in the river conidor.
4.2.4
siructures. In addition. the City
will support efForts to restore the shoreline to a more
natural character withtn 100 feet of the river to facili-
tate wildlife movement, and to improve the aestheric appearance of the
floodwall. Such efforts must be compatible with current channel design
and flood conuol management, and exceptions are made for marinas.
and other uses requiring river access. Redevelopment should include
removal of unused docking facilities (i.e., at the Koch-Mobil site).
4.2.5 In aR new developments, threatened and endangered wildlife
habitats shaIt be protected from aiteratibns which would endanger their �
survival.
42.& The City will integrate its plans utith the work of the DNR's Metro
Greenways and NaturaI Areas Collaborative. This metro area cotlabora-
tive has identified high quality native habitat remnants which could be
linked into regional gmenways, providing continuous habitat corridors to
support native plant and wilcllife species. Many poteritial greenway
opporturuties exist in the East Meuo area. including Saint Paul.
�� r;r., nf Ca:nf Pa+.l
;e20 4668 0926:04 a m. �t-03-2006 414 "
�
��°��j
• As-bviit pI�s, certified by a iegistered professional engineer, of all proposed pmject elements
• Community ac7mowledgmenF ofthe map revision request
• A copy of the puhlic notice distnl>uted by }+our community stating its intent to ievise the iegulatory
floodway or a statement by your co�unity that it has notified ait affected Pmpecty otvners and
affected adjacenf iurisdictions
After receiving appmpriate documeufation w sfiow that the project has been completed, FEMA will iniRate
a revision to the FQ2M and FIS report Because the BFEs would cLangc as a resiilt ofthe project, a 9Q-day
appeal peciod wontd be initiated, dueing which commnnity officials and inteiested parsons may appeal tfie
xevised BFEs based on scientifie or tecImical data
This CLOMR is based on i�
co�nnity is nesponsible �i s
requa8d by Fedeml or State la
knowledge of local eondirions
SFHA. If the State,,.count}� p�
State,
communiry of�cials, based on
er Nanilards for eonshtiCtion iII the
� If you have any guestions ieg�ding floodplain management iegniations foryour commimity or the NFIP in _
gen�al, please contact the Consuitation Cooddivation 0fficer (CCO) for }vur commanity. Infom�ation on
the CCO for your community maybe obtained by callmg ihe D'uector, Fedaal Tnsntance aud Mitigation
` DiV�s'sonofb'EMAinChicago,Illinois,ati(322)4(1&5529. Tfyouhaveanyqwestiouscegazdingthis
CI.OMI2, please call ouFMap Assistance Center, toll free at 1-877-FEMA MAP (1-877d36-262'1).
Smce[ely,
���1� �
John F: Mag¢o{ti II[, Project Engineer
Hazacd Idenrification Section
Mitigadon Division
Psnergency Freparedness
aadl2espanse D'uectordte
�
EncIosures -
cc_ Mr. Gaty Wazrea, P.E.
Directo , Auside Dcvelopment
Metropolitan Aitpotts Couumssion
Ms. Snsau Kimherly
Director
Department af PIauning and
Economic Development
City of St Paul
Foc Doug Bellomo, P.E•. Chief
FTazazd Identifieation Section
MitiBation Division
Emeigem,y Prepazeciuess
and Response Directorate
lal Y 'L:SSf7
Ms, Motley Shadeen
Metro Regeon
MinnesohDepaztment ofNahuatResoarces
�
Mr. Ogbazghi (Qhi) Sium, P.E.
&5miesotaDepat�ent ofNatutal
Resovrces— Watets
Mr. Thomas � MacDonatd, P.E.
Senior Engineer
Bazr Engineeimg Comgany
� �
a�����
Tom Dimond
2119 Skycvay Drive
Saint Paul, MN 55219
651-735-6667
January 24, 2006
RE: Holman Field Dike
The D�e is prohibited under Sec. 68.214(fi) of the Saint Paat Zoaing Cod�
Sec.68.601 states although variances may be used to modify germissible methods
of fload protection, no variance shall have the effect of atlowing in any district
uses pro}vbited in that district.
Sec.61.601(e) requires a finding that the vaziance would not allow a use that is
not permitted nai would it alter or change the zoning district classification of
the property.
Sec.68.102(d) states that all uses not allowed as permitted uses or as permitted
uses subject to special conditions sha11 be and are fiereby prolubited.
Finding 5 is in error. Structural works for flood conh'oi such as tevees, dikes aud
floodwalls are uses under Sec.682I3(fl. The proposed dike is prohibited uader
Sec.68.214(h)_
Finding 5 is in error. Tf►ey can not meet the requiremern that the variance will not
alter or change tfie zoning wfien fhe variauce is condifioned ou a rezoning. The
stated inteat is to atter the floodway_
Natura[ resource profection
Sec.68.601 states the burden of proof shall rest with the applicant to demonstrate
conclusively no adverse affect to the natural environment.
Coucems about pollution, water quality, habitat grotection and endangered
species have been raised by the MI'CA, MN DNR, Metropolitan Council,
National Park Service and individuals. The MAC says they will address those
concerns later atter the permits have been approved. The zoning code requires
them to address those issues up frout_ Soil borings, musset survey and vegetation
restoration pTans are some of the items that should be included in the site plan
review.
�
`�
�
�
Ob-363
�
�
Views to the river j
Currently this stretch of river along Bayfieid Sueet provides public access to the
river as called for in the Mississippi River Corridor Plan. People can walk, jog,
fish and 6ird watcfi along this stretch of river. The proposed 9 feet tall - miFe
long steel wall would block aIl access and views of the river.
Views from the river
From the river some views are obstructed by buildings. With the continaous wall
the openings would be lost, blocking views throughout this section. In Minnesota
vegetarion can only help hide a steel wall half of the year.
4U percent failure rate
The MAC cites the impacts of actual floods to just,ify the dike. Using actua!
floods the proposed dike would have fa'sled 40 percent of the time. MAC then
argues you should use theoretical not aetual floods to calculate failure rate.
Iaconvenience of using other airports during a flood
All the users chose to locate in the floodplain. They were aware of floods. Flood
protection for individual structures is allowed but users opt not to do so.
If a downtown airport is such an important factor in locating corporate
headquarters why don't the facts support the argumern? Minneapolis does not
have a downtown airport but corporate headquarters locate in Minneapolis. 3M
was headquartered in Svnt Paul but moved to Maplewood where there is no
airport. Corporate headquazters are hardly t to be near airpozts in South
Sa'int Paul, Lake Elmo and Anoka.
Tlus is the old slippery slope issue. The argument to allow the airport or any other use in
the flood plain is that it will have little effect on the ftoodpiaia Then they argue they
should not be inconvenienced by floods.
� �1
�
� r �
Tom Dimond
2119 Skyway Drive
Saint Paul, i�IN 55119
651-735-6667
7anuary 1'7, 2006
RE: Holman Field Airport Dike
{ �
The Metrapalitan Airports Commission is trying to put the cart before the horse. They
waat site plan approval and permits issned to start covstnictian before they seek changes
to the Critical Area Regulations.
Sec.61.402.C. (2) requires the Plcmning Commission to fmd that the site plc6'e is consistent
with applicable Ordinazces of the City of SairztPaul.
MN Statute116.G.12 subd.3. states if plans and regulations for au area of Crirical
Concern have become effective undei the provisions of sectiou 116GA7. the local uniY of �
government shatl permit development onty in accardance with those ptatts and
regutarions.
The Dike is prohibited under Sec. 68.214(h) of the 5aint Yaul Zoning Code.
Sec. 61.402.0 (1) requires the Plrnerring Commission to find that the site plan is
corrsisferet with tfre City's adopted Comprehensive Plcm.
A 9 feet ta11 steel wa11 on the river side of Bayfield Street would completely block views
and access to the river. Imagine a 9 feet tall wall along the riverside of Mississippi River
Boulevard or Shepard Road
T1►e Mississippi River Corridor Plan 4.2.4 and 6Z calls for preserving and
improving eaisting views to the river and enforcing the 50 feet setbaclr.
Sec. 61.601. Variances.
The board of zoning appeals shall have the power to grant variattces from the strict
enforcemezrt of the provisions of this code upon a finding that:
(a) The praperty in question cannot be put to a reasonable use urrder the strict provisions
of the code;
The airport has operafed since the 1920's and will continue to operate with or ��
without the dike. �
06-3�3
�
�
�
(c) The proposed variance is in keeping with the spirit cmd intent of the code, and is
consistent with the health, safety, comfort, morals cr�ul welfare of the inhabifanfs of the
city;
The Code prohibits community-wide structural works intended to remove areas
from the regulatory fiaodplain.
(e) The variance> if g1'anted, would not permit arry use thut is not permitted under the
provisions of the code for the property in the district where the affected land is located,
nor would it alter or change the zoning disirict cdassifzcation of the property;
The stated iutent of the variances is to alter or change t6e zoning district
classi�cation of the proQerty.
Sec. 68.601� Variances.
(a) Applications for variance to the provisions of this chapter may be filed as provided in
section 61.600_ The burden of proof shall rest with t6e appticant to demonstrate
conclasively that suc6 variance wi11 not result in a hazard to life or property and
will not adversely affect the safety, use or stability of a public way, slope or drainage
channel, or the natural environment; such proof may include soils, geology and
hydrology reports which shall be signect by registered professionai engineers_
Variances shatl be consistent with t6e general purposes of the standards
contained in this chapter and state law and the intent of applicable state and
national laws and programs. Altkough variances may be used to modify penmissible
methods of 400d protection, no variance shall have the effect of allowing in any
district uses prohibited in thax disirict, permiC a lower degree of flood protecrion than
the flood protectian elevation for the particulaz area, or pernrit a lesser degree of flood
protection than required by state law.
Egecutive Order 79-19 states that the Mississippi River Critical Area is to presexve
and enhance its natural, aesthetic, cuttural and historic values. The destrucrion of
habitat, loss of naturai shoreline, the loss of views and access from Bayfield Street
along with negative visual isnpacts from the river created by a 9 feet tall steel wall,
are bnt a few of tfie impacts t6at are not consistent with Ioca1, state and federa[ river
corridor standards.
MAC has not demonstrated conclusively that the dike can not be setback 50 feet, how
they intend to deal with pollution and water quality, impacts on endangered species
including the Bald Eagle aad Higgin's Eye Pearly Mussel including a survey and their
plan for maimaining the compensatory excavation The EA is largely silern with the
promise they will survey and develop plans later.
��
Ob-3b3
Tom Dimond
2119 Skyway Drive
Saint Paul, MN 55119
651-735-6667
January 7, 2006
�
RE: Holman FieTd Airport Dike 2005-7386-TJF,
The proposed dike is located in the Staie designated Mississippi River Critical Area and the
Mississippi National River and Recreational Area. The Mississippi also has Federal Nationai
Rivers Inventory (NRI) designarion. The Mississippi River Corridor Plan ca11s for proteeting
and enhanciag the natural and scenic values of the river. Tfie Plan aiso calls for pmtecting and
enhancing access to the river and views to and from the river. The proposed dike is not
consisteut with Saint PauFs River Corridor Plan. The dike is specificalfy prohibited.
At the fieart of river restoration efforts is preserving shorelines in their natural state and
restoring shorelines. The Saint Paul City Council and Planning Cominission revised the
Zoning Code to protubit the practice of building floodwalls intended to remove azeas of
shorel'tne from the floodway. Newspaper reports iadicate that Saint Paul City Council �
Members and I.egislators strongiy supPort the effort to save the shoreline from fiuther
encroachment and do not support the airport dike.
Sec. 68.214 (h) states that community-wide str¢cturat warks for flood control intended
to remove areas from the regulatory floodplain shalt nat be all°Wed m the floodway. The
8/5/2005 email stating that the CLOMR revises e�risting floodplain mapping from (RCl) to
(RC2) is not correct. Zoning district and Criticat Area regutation changes must be made by the
City Council. The Jnne I4, 2005 F'�MA tetter c[eariy stxtes that the CLQMR is based ou
minimum criteria and more restrictn'e commnnity criferia take precedence over the
�. ��
minimum NFIP criteria_ Sec. 62.100 states that whenever any provision ofthis code imposes
more stringent requirements, regulations, restrictions or limitations than aze imposed or
required by provisions of any other law or ordinance, then the Provisions of tfiis eode shall
govern.
Executive Order 79-19 states that the Mississippi River Critical Area is to preserve and
enhance its natural, aesthet��, cultura! and historic values. Tke destruction of habitat, loss of
naxural shoretine, the loss of river views and access from Bayfield Stre� along with negative
visual impacts from the river created by a 9 feet tall steel w1ll, are but a few of the impacts
that are not consistent with Iocal, state and federat river comdor standards.
The cost benefit ratio is onty 1.21. Consisteut with We principles of cosE benefst anatysis costs
aud benefits are (discounted) converted to preserrt value terms. The discourned cost is $24.'7
miliion and discounted benefit is $29.8 million over a 50-year period_ Costs exceed benefits �
until the yeu 2033. The MAC CIP adopted December 2d05 sets the 2006-20Q7 dike costs at `
l�
�"l
�
�
�
06-363
$28.Smilion. This is up from the $22.4 miliion in the draft cost benefit analysis. The updated
costs have probabiy moved this project even closer to a breakeven or negative cost benefit.
The cost benefit ratio is low and based on inf4ated henefits and discounted costs. For
example, tfie benefits are inflated by using aitport delay costs based on old numbers before
Northwest filed €or banknzptcy and dramatically reduce� the number of operation at MSP.
The August 4, 2005 MN DNR letter points out tha.t the EA does not provide a monitoreng plan
or an analysis of frequency of �cavation to maintain the compensatory excavation. Without
an excavation maintenance plan and analysis to support the plan there is not a sound basis for
cost benefit analysis.
The report states that the airport is the primary reliever airport for MSP. In fact, Holman
Field ranks last in takeoffs and iandings among the three airports established as Tier I
reliever airports. Holman ranks last in aircraft based among all retiever �irports.
The EA states that only 7 aircraft based at Holman Field need a runway longer than 5,�00
feet. Anoka and Flying Cloud haue 5, 000 feet runways planned. The Floodwall reduces the
runway to 5,509 feet as a non-precision instrument tunway. With only a 10% increase in
length, Anoka and Flying Cloud can provide the same length as a grecision instrument
runway. A safer and lower cost aiternative. The EA states, that option is not pursued
because it is prohibited. The Dike is also prohibited. Either proposal requires a change ofthe
law.
Sec. 68.402(b)(l)b. requires the placement of all structures at least 50 feet from the ordinazy
high water mark. This wouid require moving the floodwall to the inside of Bayfield Street.
This woutd also retain public access along the river,
Sec. 68.402(b)(2) No commercial or industrial development shali be permitted on slopes
greater than 12 percent. Development includes excauation. The shoreline proposed for
excavation exceeds 12 percent.
Sec. 68.402(c)(7) No rehabilitation slopes shali be steeper than eighteen (18) percent. The
proposed d"ske and shoreland exceed 18 percent.
Sec. 68402(c)(8) Dredging of shoreland or wetland shall be allowed only when it witl not
have adverse effect on the wetland. The proposal would remove vegetation and not replace it.
Ongoing dredging would be required to maintain the altered depth. 'This would have an
�
adverse effect.
Sec. 68.A03(d) Natural vegetation shall be restored after any construction project. Trees and
bushes have been along this riverbank fox years and there is no reason they can not be
restored. The shoreland along the Mississippi River is the most important flyway in North
,America. The Endangered American Bald Eagle nests and feeds along this section of the river.
They have a nest on the opposite shore from the proposed project.
�
�
06-363
Sea 68.404{c)(2) Natural vegetation in shore land and bluff areas shall be preserved. �
Executive Order 79-i9 states that stiuctwe site and location shali be regulated to ensure that
riverbanks, bluffs and scenic overlooks remain in their naturai state, and to minimize
interference of views to and from the river. This calts for tocating the 9 feet tall steel wa11 on
the inland side of Bayfield Street. This would protect the view to the river from Bayfieid
Street and help ensure the natural vegetation is preserved.
The Application for Site Plan Review 06-000725 ctearly states that it is for the St Paul
Dovi+ntown Airport Perimeter Dike Project. The second pazagraph says the ptupose of this
project is to protect the aizport from flooding up to the 1% (100 year) event. As stated above
this is prohibited under Sec. 682t4(h). They are attempting to put the cart before the horse.
They want the site plan approved without the necessary regulatory chaages. MN Statute
116G.12 subd3. states if plans and regulations for an area of criticat concern have
become effeetive under the provisions of section 116G.07. the local unit of government
sha[i permit development onty in accordance wiYh those plans and regulations. To
approve the site ptan, the Piannin� Commission shalt consider and itnd that the site plan is
consiste� with applicable ordinances of the City of Saint Paui. The site plan ean not be
approved for the dike project because it is prohibited by Critical Area Regularions.
The MPCA and Metropolitan Councit have expressed eoncern about tfie potential of gollution
and water quaSity with tFris proposat. Tfie Pawieuty Administration has etiminated staffing for �
the Section 401 review. The MPCA has indicated they plan to waive many Section
401certificatioa applications with limited exceptions. The U.S. EPA stated that they did not
undertake a detaited review of ttxe document and will not be generaring comments because
worktoad priorities precfude detaited review aad comment.
The MAC is requesting site plan approval eveu though they acknowtedge it is prohibited
uuder the Zoning Code. They premise their request that if the site plan is approved and they
are issued permits to start constraction, they will come back later to request a cbange in the
Zoning Code. The Saim Paul Zoning Code does not have a provision to apgrove site ptanc
based on how the applicant might prefer the laws to be written.
The MAC must appty for and re�eive a change of the Critical Area Regutations before a
site plan cau be approved. A site gtan must be appr-oved before pernrits can be issued to start
constmetion. Any change in the Critical Area regulafions requires City Council approval and
DNR reviaw.
We keep talking about how important it is to proteet and restore the river. Is it all talk or will
aur con:munity leaders stand up and support the Critieal Area Regulations?
� y
S
�
�
�
Tom Dimona
2119 Skyway Drive
Saint Paul, MN 55119
65I-735-G657
February 19, 2006
ItE: Airport Noise - Property Values
06-363
Auport noise at Holman Field decreased in the 1990's with the phase in of Stage 3
aircraft and cfianges to the military fleet. Auport noise at Holman Field is on the rise
again. The 1992, 1998 and 2020 noise zone maps show a deerease from 1992 to 1998 and
an increase from 1998 to 2020. The maps are cornained in the 1992 and 2000 Airport
Comprehensive Plans.
The Cost Benefit Analysis (CBA) for the dike forecasts a near doubling of aircraft
operations. Aircra$ operat�ons are projected to increase from I34,377 to 256,280.
MAC letter dated February 8, 2006 listed Question 5: Will the floodwall sesult in
increased use of the airport and more noise for nearby neighbors?
MACs answer is "No". They provide a chart showing aircraft operations deereased by
60,000 takeoffs and landings per year since 1990.
MAC is telling the FAA, there is going to be a near doubling of operations when
applying for fuuding. MAC te11s the Plamiing Commission, operakions have decreased by
60,000 when applying for variances.
The 2000 Comprehensive Plan projects a shift to larger aircraft. Mu1ti engine aircraft are
projected to increase from 17% in 1998 to 24°/a in 2020. Jets are projected to increase
from 27% in 1998 to 33% in 2020.
The Zo00 Comprehensive Plan shows that by 2020 the area impacted bp 60 DNL naise
wiil inerease 248 acres. 65 DNL will inerease 141 acres. 70 DNL wiil inerease 57 acres.
75 DNL will inexease 65 acres.
Noise monitoring for the 2000 Comprehensive Plan took piace at 249 Auita Street on the
West Side and tfie comer of Clecmont and Bates in Mounds Pazk. The West Side location
recorded 60.6 ANL and the Mounds Park focarion calculated a 65.6 DNL.
Several sludies confirm thaY real estate vatues are negativety impacted by airport noise. In
1994 the consuIting firm of Booz-A11en & HamilYOn Inc. prepared a repart titled "The
Effects of Airport Noise on Housing Values". They found in two paired neighborhoods
an average 18.6 % higher property value in the quiet neighborhood. A 1996 study funded
by the State o€ Washiugton used similar metkodotagy and found that a proposed
e�ansion of Seattle-Tacoma Airport woutd cost nearby cities $500 million in property
values and $22 million in property tax revenue. In 1997 Randall Be11 found a diminution ��
in value due to airport pro�nity averaging 27.4%.
�.
�
attains a width of 4,004 feet near the
midd2e of the airpo�: The �oze
siguifccant 65 DNL contour -egteiids
about 3,000 feet off each end of Ehe
main runway, but stays ciose to the
ends of the othex runways. The higher
level contours remain on airport
properLy, very near the pavement.
Eghibit 5B presents the aircraft noise
e$posure contonrs for the forecast, 2020,
conditions at the airport. Overali, the
size of the contour set increases relative
to the current conditions due to
increased operatians. Tlie 60 DI3L
contour reaehes about 23,Q00 fee$ from
south to north and attains a width of
4,000 feet at its widest point. The more
significant 65 DNL contour egtends
about 3,600 feet north and about 4,300
feet south of the. ends of the main
runway. As in the current situation, the
higher level contours remain very near
the pavement and on airport property.
Table 5A gives the areas of the
contours.
NOISE MEASUREMENT
PROGRAM
The primary purpose of the
measurement program was two-fold: to
detect nighttime movements of aircraft
and to obtain a general sampling of
noise events around the airport. Noise
monitozing tests were canducted at
three sites, Site One was across the
river an the north side of the airport in
Indian Mounds Park, near the corner of
Clermoat Street and Bates Avenne. Site
�bvo was on the near west side of the
airport at 249 Anita Sixeet_ Site Three
was south of the airport at 314 Bircher
Street. These sites are shown on
F
0 �-363
E$hibits 5A and 5B. Each site had 24-
hour manitoring for seven days, from 3
p.m. on June 2' to 3 p.m on June 9`�',
I999.
$ecause the air traffic control tower is
closed at night, nighttime operations
statistics are scazce. It was hoped that
the monitoring program would detect
aircraft movements as noise events
(events loud enough attd long e.nough to
exceed the monitoring thresholds set on
the ec}uipment) and thus form the basis
for a nighttime operations estimate.
p
�
�
The monitor at Site One recorc2ed a
total of 1,211 events over the ?-day
period of wiueh 184 were recorded
between the hours of 10 p.m. and 7 a.m.
Notes accompanying the data indicate
that the maintenance crew was
sandblasting the nearby airport beacon
during business hours throughout the �
monitoring period. Many egceedances
were caused lay this noise source. The
airport was unshieided at tlus iocation. �
The monitox at Site 2`wo recorded 596�
total events ofwluch 99 were during the
� �n
�; ,
�;��
t�
06-3b3
aooaaoeoo°oaoov00000aoo°o°oaoaoaoaao°000aoo_oeooeo
�meememe mm�e m�mmmem.�m.��e��eee.�mmmeaemmme�eemn
NNNMNNNpNNNN y Y yNNNNNNNNMNNNNNNNyNtlHNyxNNNNNNNNyyNN
NO��WN�q'piqVa�OmO
� .- � �CC�iS.^C0b00m0m06�moi�0i0m�NRNaVtEn'pNNw'WFI[V
m ��rmm n mmwm� oemooeaeooe Q Oe0000000 oo4 00 eooee00000eoo
m 'moao'•����..����.-_�.-��..�.-..�.-..���.-���.-..����
�
�
r
�a
�
�� w
ga
e�
a�
2
O�
3
S
a
a
N
�
� g
3
�
° a
�tl
0
�
m
¢
S
�
a
�6����mm���mm�m�^mm��w�saW��m�3aa$�?��a����mW�mmmmm�
"� �=-�aa�e�ae0000aeoaeaoa<e>o 0
^_�a`mm�m^�����^�� F�^��FF�FF���F� . r � . ����F^F�'F��F'�F^
�'��."�d��^° oRBS'�m�a�w
'� ���' qdt�VryNNpi�
s
mm � no � mnn a� m nmmnnnamms'�nv ° 'ia q 'inm.�.onnnnmm�nnnm�i.�o4w.�.nmm�m� i nn
NMtSrypNtaVt � YaSapVNadVryvVN M Na SryaSNWtSt p VN [ SN[St�Vpq(�VNNWC Y YN{VN[gNNqt3[SM1N a a YfSN
m mm mmmmmmm. � m mmmmmmmmmmemmmmmmemmemmm�, ^ e^mm. ^ emm, ommnmo
�
�
� 3
o�
�E
ng
s �
-�j9
R'd
�
Q �
s5
���
_��
g ..rn.�m�ma .�a»��mm p � g,g q g g g
° �@R�.RR�RRRRRR�R 2 R. ° .R�..� ° .R�$$RR�RF.9R�R�R����R�R.�S$R�RR �
t
�
S
3
E
f
E
a
h
��
�
�
�
�-
r
z�
_� �
_-;
�i
ve �i
<r
e
�
�
LH-5(3°Jo)
l� ' �
LEG�BdD -
-.� ��, H (Helicopierj
,�-.._ -._
� �I (M'rlitary) - _
' � , J: (7et)
-s- - - - '
�- ME (Muiti-EnginePiston)
3E js'vegie Engine rision�
- �
:�:_ _-- - _ -
:V,._=::: : �-
H - 9 (4%)
Exhibit 2C
��
06-363
�
��
�
have been projected at a static OPBA
ratio of 1010.
Loeal general aviation operations aze
currently estimated at 31 percent and
itinerant operations are estimated at 69
percent of total general aviation
operations at STP. Itinerant operations
have been increased by 11.4 percent to
account for unrecorded operations at
night when the airport tra�c control
tower is closed. 1`his accounts for an
overall increase of seven percent in total
tower reported operations. -
Based on observations at the airport
and consultation with STP tower
officials, virtually ail civil local
operations are conducted by single
engine piston aircraft. These civil local
general aviation operations are
2E
Operations Forecast
,Total"' ,: ;
Gerterai+'�- �.-.G:A::' , _��`�.`?Xl
Based Aviati,ori ' OEBA Loc�
E�lYCT3ft QiIS. �..1t10' �p:
attributed largely to the Wings facility
(located on the narth side of the airgort)
conducting flight training operations. If
this facility were to relocate during the
planning period, it could be expected
that the Rcivil local general aviation
operations wo.uld decrease by neazly 15
percent. The transition to larger aircraf€'
at STP may decrease local general
aviation operations even fiuther.
Local and itinerant military aircraft
operations are projected to remain
static over the planning period, while .
air taxi operations are projected to _
increase at an average annual rate of
22 percent, consistent with trends';'
projected by the FAA. The operations �
analysis has been summarized in Table:
2E and illustrated on E�ibit 2B.
;�
Civil . ��ocai
�tinerarit iVIilitary
Op.s: Ops.
1998 � 155 ' 156,670 I 1010 I 48,494 � 108,176 ( 4,141 I 3,648
E i r r <�fi'���K� �,. - � .. �.'TY:"�.' ! 5 S, '
e � . � • < c- ��
[`Qrten.." ..��'K�l���� k _`` � .�'l�'3$. ` Sx...�.'.., Sx�.y-
E1ii'
Taxi
5,314
2005 9 161,000 1,010 50,000 111,000 4,000 3,500 6,400
2010 162 164,000 1,010 51,000 113,000 4,000 3,500 7,100
2015 168 170,000 1,010 b3,000 117,000 4,000 3,500 7,900
2020 172 174,000 1,010 54,000 120,000 4,000 3,500 8,900
k Operations-per-based-aircraft
PEAKING definitions apply to the peak pe
CHARACTERISTICS STP:
Most facility plaiining related to levels
of peak activity. The following plar,n;ng
:
• Peak Montk - The cale
month when peak air
operations occur. �
b
E• . �.
�
�
Located approximately 12 miles easc of che St Paul business
distritt wich easy access co Wisconsin, Lake Elmo Airport is
a convenient swp for many (ocal aviation enthusiasts.The
airport has two runways under 4,000 feet long and is designed
to accommodate primarily the private and recreational
flyer operating single- and twin�ngine propeller aircrafG
Lake Elmo Airport also serves the business sector with higher
perfortnance single- and twin-engine aircraft and an occasional
small jet aircraftThe facility is served by a foced base ope2inr
and an airaaft maintenance provider.
The 2010 forecast for Lake Omo Airport estimates annual
activity could reach mare than 265 6ased aircraft conducting
abouc 133,000 annual operadons.
To contact Lake dmo Airport, call 651-777-6300.
St Paul Downrnwn Airport is located jusc five minutes from
the St Paul business centef� and I S minutes from downtown
Minn�polis. Becau:e of its pro�dmity to theTwin Crcies
business disvic�s. St Pau� Dowrrcown Airport has been
developed m meet the needs of corporate aviation.The
airpott is served by an FAA air vaffic convoi tower and has
a full range of services, including several fixed 6ase operators.
It has three runways measuring 6,7� I feet, 4, I I S feet and
3,657 feet
Activity az rhe St Paui Downtown Airport is expected w
remain s�ble. By the year 2020, annual aircraft operation:
shoutd appro�dmate 174,000. About 170 aircrafr are projecced
to be based at die facility.The airporc serves a number of elite
mrporavons bued in Minnesota and also houses the Air
National Guard. Due to the proximiry of the airport to the
Mississippi River and orher indusaial developme�G growth is
restricted and future improvemenss will be limited to the
corpoate hangar space.
To cantaa St Paul Downmwn Airpott, call b51-224-4306.
: " - ' .�
k.
�£�� 3�Z
�
��-���
'The Metropolitan Council has developed forecasts of based aircraft for airports in the
Minneapolis - S� Paul meuopofitan area, including S'IP. However, these forecasts aze
based on 1983 data, and therefore do not incorporate the more recent changes in the
stcucture of the general aviation industry. The Metropolitan Council is currenfly updating
these forecasts. Since the Metropolitan Council forecasts do not incorporate the most
racent conditions, they were considered unsuitable for the STP forecasts.
The FAA has also developed a forecast for STP as part of its Minneapolis/St. Paul "Hub"
forecasts However, this forecast is based on data which aze now two years oid and also�
incorporates national forecasts of general aviation activity which aze much higher than the
FAA now projects. Consequendy, the "hub" forecast of general aviarion was also considered
unsuitable for this effort.
St. Paul Downtown Airpon is the oniy refiever airport in the Minneapolis-St. Paul
metropolitan azea classified as a transport airport by the FAA. Because its facilities are
better able to accommodate jets and lazge turboprops than other reliever airports in the
area, STP amacts aircraft from throughout the metropolitan area rather than just its
immediate neighborhood. In addition, the Metropolitan Air�orts Commission considers
ST'P to be the primary general aviation business jet reliever airport for the metropolitan
azea, and actively encourages corporate jets to locate at STP. Consequently, it was assumed
that �ven the continuaflon of the provision of adequate facilities, civil based aircraft at STP
would grow at the same rate as in the metropolitan azea
Table 2.2 presenu the unconstrained forecast of civit based aircraft at St. Paul Downtown
Airport. It was assumed that there wouid be no physicai constraints on the number of
___--
b ased aircraft, other than the ultimate wnstraint o 490 total b ased aircraft. As shown,
under these conditions, 198 civil based aircraft would be expeeted at STP by 2010. It
shbuld be noted that the civil aircraft include some aircraft that are used primarily for
general aviation air taxi purposes.
�'AA, FAA Aviation Forecasts: Minneapolis,Lt. Paui, August 1988. ��
II-7
,i . _ _
ST. PAUL DOWNTOWN AIRPORT NOISE STUDY
St. Paul, Minnesota
;;Yeport presents the results of noise measurements conducted at €our
:ions in the vicinity of St. Paul's Downtown Airport (Aolman Field),
ig the period June 19 - 21, 1989. ltiao of the sites were selected to
;sent residential areas near the airport which are most subjected to
> from arriving and departing aircraft. These sites were monitored
Cnuously over a 24-hour period. Data obtained included hourly
valent sound levels (Leq), and the statistica2 sound leve2s L20, LSO
L90. The 24 hout day-night sotmd level (Ldn) was ca2culated from the
1y Leq's. The complete data from these sites is presented in Tables 1
2. � '
�
tantaneous maximum sound levels (Imax) from individual aircraft flyovers �
e observed and recorded at two additional sites. This data is presented
Tables 3 and 4. Information on the instrumentation used and procedures
lowed is given in the appendix following the tables_
vidual maximum sound levels from departing corporate jets ranged from
- 97.5 dBA. Numerous in- and outbound commercia2 jets using
�eapolis/ St. Paul Znternational Airport (MSP) were observed to cause
mum sound levels in the range of 61 to 75 dBA_
� �l
�
HNTB No. 13120 (QUAL 4/21)
�
\ ii
TABLE 1
DATE
6/22/89
6/21/89
6/21/89
6/21/89
6/21/89
6/21/89
6/20J89
6/20/89
6j2o/s9
6/20/89
6/20/89
6/20/89
6/20/89
6/20/89
6/20/89
6/20/89
6/20/89
6/21/89
6/21/89
6/21/89
6/21/89
6/21f89
6/21/89
6/21f89
ST_ PAUL DOWNTOWN AZRPORT NOZSE STUDY
SITE #1 - HEAR ROBERT AND KING STREETS
HOUR fIOURLY SOT3ND LEVELS (dBA}
BEGINNZNG Leq L10 L50 L90
0700 56.6 57 54 51
0800 54.9 57 53 50
0900 58.9 57 54 51
1000 56.4 58 54 52
1100 56.1 58 54 51
1200 56.3 57 54 51
13�0 58.7 ?' 60 55 52
1400 60,7 ' 62 56 53
15D0 58.5 60 SS c, 52
1600 59.0 61 SS 52
1700 59.5 61 55 53
1800 58.2 60 54 52
1900 56.4 57 53 50
2000 58.7 56 51 49
2100 54.7 55 50 4&
2200 53.7 54 49 47
2300 49.9 51 48 45
0000 49.3 51 47 44
OlUO 49.5 50 46 43
0200 46.5 47 43 40
0300 43.0 44 42 40
0400 51.1 47 43 42
0500 51.2 52 48 45
�6�0 58.7 58 53 50
24 HOUR DAY-NIGHT SOUND LEVEL (Ldn) 60.2 dBA
�
SOURCE: HNTB, June, 1989
�
0�-3�3
�� J
HNTB No. 13120 (QUAL 4/28)
��-��`�
�
TABLE 2
(1)
�2)
(3),
(4)
DATE
6/20/89
6/20/84
6/20/89
6/20/89
6/20/89
6/19/89
6/14/89
6/19/89
6/19/89
6/19/89
6/19/89
b/19/89
6/19/89
6/19/89
6/19/89
6/19/89
6/19/89
6/20/89
6/20/89
6/20/89
6/20/89
6/20/89
6/20/84
6/20/89
ST. PAUL DOWNTOWN AIAPORT NOISE STUDY
SITE #2 - MOUNDS BLVD.
HOUR HOURI.Y SOUND LEVELS (dBA}
BEGINNING Leq L10 L50 L90
07Q0
OS00
0900
L000
1100
1200
23Q0
1400
1500
1600
1700
1800
1900
2000
2100
2200
2300
0000
OI00
0200
0300
0400
0500
0600
(1)
(1)
(1)
C23
(3)
60.5
66,4
60.4
64.1
60.8
64.4
70_4
61.6
56.1
57.5
56.7
61.1
58.5
56.7
56.8
SS.4
54.8
55.6
76.0
52_9
84.7
58.8
57.8
67.1
62
64
62
61
62
58
70
64
SS
60
59
58
60
S9
58
58
58
59
55
56
59
57
59
58
58
58
57
57
57
53
54
55
54
55
54
52
53
53
54
53
52
50
50
50
51
53
54
55
24 HOUR DAY-NZGHT SOUND lEVEL (Ldn) 66,4 dBA (4)
56
55
54
55
54
50
51
52
52
ST
51
49
50
50
52
50
49
48
47
47
48
49
50
53
City Iawnmower operating nearby 12:45 to 14:55 pm.
Person "singing" into microphone - in excess of 105 dBA max.
Person ^singing" into microphone - in excess of 111 dBA max.
Above hourly Leq's not used in calculation of Ldn.
SOURCE
HNTB, June, 1989
�
��
�
m: "Aliison Westtund" <Atfisan.Westlund@mapmadteam.wm>
• "dmartd` <dimondt@earthlink.net>
Cc: 'Tom Smiti� <Tont.Smitt�@tttapmodteam_corsv
Sent: Tuesday, February 2l, 20061:40 PM
Atfach: Airport Dike FEMA Febntary S8_doc
Su6fecf: RE: CLOMR 05-05-'f090ft
Mr. Dimond,
pb-363
My manager and f were able ta quickh/ took at your sfafements and provide simpte answers. We couFd provide a more formaf
response if your timeiine allows_
Atl'isan VYesf[uruf
From: dimond [mailto:dimondt@eartlifink.netj
Sent: Saturday, February 18, ZQ06 L•tS2 FM
To; Alt'son Westlund
Cce Kathy Lan6y; Sheldon Jofinsart; Mne Hunt
SubjecC: Re: CLOMR US-OS-1090R
Attached aze qaestions that should be a s'rtnple yes or no. Beeanse of time}iaes it woutd be gready appreciated i€ you could answer these
questions as eazIy as possi'ble before 3PM oa Tnesday. The other infotmation requesfed is important but not as rimely.
Tltank you
r Original Message —
From: Allison Westtund
To: dimondf earthfink.nef
Sent: Friday, February 17, 20061:37 PM
Subject: CLQMR OS-fS5-t090R
Mr. Diamond,
I have giuren my manager some background information pertaining to our iasf canversation. As soo[� as possibie, t wiq sit down
with fiim a�x! further discu�s your concems and we will get back to you with as much information we can provide.
Fhank you,
Atlison
,.: ,� .
Revisions Aualysf - Region V
Michael F3aker 3r., Znc.
FSMA Nationat Service Provider
703.960.8800 eart. 5305
�
(��� 3/310i
l,
,{ .- ' ..
Tom Dimond
2119 Skyway Drive
Sairn Paui, MN SS t 19
65I-735-6667
February 28,20(76
I would appreciate if you could answer these questions by Tuesday the 21 �` of February. I
believe they can be answered with a yes or no.
FEMA part 6� Anv communitv mav exceed the mminnimum criteria under this part by
adopfing more comprehensive flood plain mcaragement regulations utilizing the
standc�ds such as contained in subpart C of thispca� In some instcutces, comm�snity
officials may have access to irrformation or knowledge of conditions that require,
parliculcmlyforlTUnuuzsafety, higherstcu�dcmds thwz the mi�timnrn criteriasetforth in
subpartff of this pcvt. Therefor� �Plain man¢gement regulalions adopted by a
State or a community which are more reslric[ive than the criteri¢ set forth in this part
are encouraped and shall take precedence
1. The CLOMR and LOMR aze based on minimum ffoodplain managemern cciteria
establisfied undei the NFII'. Communitp adopted more resh�iiciive or comprehensive
floodplain management criteria take precedence over the minimum NFTP criteria.
Yes, either state or Local regulations that cme rnore stringent than the minimum
NFIP criteric�
2. The FIRM is a IIood insurance rate map. The FLRM is not intended to be the sole
basis for approving floodplain development, permits or floodplain managemeirt
regulations including zoning districts.
The modernizedF7oodlnsurcnace RateMaps (1%IRMs) combine what was
previausly shown on the F7RMand FdoodBauridmy and�Zoodway Map (FBF�.
The FIRMwar generaZly for insurance pr�rposes cmd the FBFMwas generally for
floodplain nrcuragemerztpmposes Forpurposes of the National FZood Insurance
Program (NI��P), this modefrrized map is the basis forfloadglain mcrrragement
and flood insurcaece requirements, however states and/or communities may haue
more restrictive ordinanees or regulations.
3. Floodplain management regulations adopted by a community that are more restrictive
aze encouraged_
Yes, more restrictive state and/or commttnity regulations are encouragec� as Zong
as they meet the minimum requirements established by the NF%IP.
��
�
�
�
�
e•_ .
� 4. Case # OS-OS-1090R is located in the State designated Mississig�i River Critical Area
and the Mississippi National River and Recreational Area (MNRRA) a unit of the
National Pazk System. � more restrictive floodplain managemem regulations
inctuding protection and enhanceme� of nahuaI resources in the Critical Area take
precedence.
We can't really comment on whether arry of these reshzciions apply, you would
have to contact the state or federal agency related fo those regulations.
5. Case # OS-OS-1090R Community adopted floodplain management regulations are
more restrictive than the minimums requested in the LOMK (a11 of the proposed
Yloodway is currently protected by floadway regalations). FEMA does not require a
community to reduce more restrictive regulations Yo the minimums in a LOMK.
We're not sure of the questior� however the floodway is provided as a tool to the
state crrrd/or community to regulate floodplain management under the NFIP.
�
�
��
�b����
Page 1 of 2
From: "dfmond" <dimondi�earthfink.nei>
Ta: "AAos"Etes, PatrielC <PMosdes�mspt�e.org>
Sertt Wednesday, February i5, Z006 8_42 Pl6f
Subjech CBA and ER
�
(f f undecstand carrect[y, the projectior� is that fhere wi{t be 9 f[flod events over the
next 50 years. Nine fiaods of'f�f} year infensiiy or iess ff�af wauid ciose fhe
airport.
To estab[ish benefits, projected days cbsure had to be catcutated. Can you
provide me with the totat days pro�ected cfasure ctsed ta calc�rtate ber�ef�fs over
50 years in the CBA? .
Why does the �BA tist the dike construction cosf as $22.4 miltian instead af
$28.5 miltfon?
The CBA [ists $32,836 as the annuaf 48�Nt. VUFtat �art of that is maint�nanc�
dr�ciging? VVhat is the c3recig�ng amc�unt �ase€� an sinc� no ptan has been �
developed yet?
EA response 84 states that the tenant casts in the Juty 2aQ5 araft EA were $3.1
million but have beert revised ta $3.8 m�ltion in the January 2006 EA_ What is the
basfs for the eF�ange?
Tabie 3 in the Qraft EA tists deEay cosfs to ai�lines at $17,21't per day. The �inaf
Ea (ists fhe cosf a� $24,96'f per day. Vi�F�at is fhe basis far the change?
Tabte 3 in the �raft EA {ists ground transpvrtatian casts at $216,497. The Fina[
EA iists ihe cosfs at $317,419. Whaf is the basis for ff�e c�tange?
Does Tabte 5 af the CBA proJect c�peratians at STP to irtcrease fra� 134,377 ta
256,�8(3? That is a near dc�ub[irtg of operations.
Can yau gef ine a copy of the Survey of Airport Tenanfs and HNTB artatysi
iisteci on Tabie 3 as ti�e basis for Table 3 0€ the CBA? i cc�u[d pick #i�err� up w a
hard capy of the WiEder Study. The eiectronie versiart claes nat open. �
�
3/3/06
� : Page 2 of 2-
�
��R� �(OU
Tarn
1•
<><><><>��><><>o<>v<><>
T�M a[k�IIOND and St1SAN DtIViQNC}
2119 Skyway Drive
St. Paul, Minnesota 55119
(h) 651-735-6667
�
�
�V �
3/3f06
J
� /",d20 4668
�
09:26:04 a.fn. 0�-03-2006
o � � � � �
• As-built plaz�s, cectified by a registesed pmfessiona! engiacer, ofall pmposed gzoject etemeQGs
• Commnnity ac�owIedgment ofthe map 7evision iequest
• A cogy of the pubiic notrce distnbuted by ynur commtmitx stating its mtcnt to revise ti�e tegulatory
floodway, or a statement by }mur commimity [hat it Las notified ail af£ected pioperty owne�and
affected adjacenf jcuisdictions
After teceiving appropriate docummfation to sfiow that the projwi has bee¢ campleted, FEMA wi11 ini@ate
a revision to the FIIZM and FIS cepM. Because the SFEs would ctiaugc as a rest�lt ofthe pmjed, a 9Qday
apPeal Period would be iaitiated, ducing which commnnity officials and intensted pexsons maY aPPeaI tfie
revised Bk'Fs based on scientific or tectcmical data.
Tl�is CIAMR is 6ased on`
co�tmity is responstble or ap�
reyuiied by Fede�al or State ]a�v
�w
�?gi�:±�i[�tablished uttder tke NFIP. Yotrr
i�� p�u'm`e��nt and far ens�uing ap necessazypeanits
State, coimiy, an$ c�mmunityo�icial�, basect on
If you have any qnestiaus n;g�din8 floodplae maaagemenf iegniarions fer your coumnmity or the NFii' in
generti, pleasecontact fhe Consuitation Coord�ation.0fficer(CCQ) faryntgwmmunity, Infomiatioa on
ttie CCO for your comia�iry mayhe obtamed 6y callmg tLe Dixector, Federal Tnsurance and Mitigation
Division of��iVIA in Chicago, Illiaoi� at (322) 408-5529. Ifyau have mmy questions regacding this
C.`LOMR, plea.re ca1[ our Map Assistance Center, toll frec, at 1-877 FEh1A MAP (I-877-336 262�-
Sincerely,
�.����;�
JohnF. Magno[ti III, FtojectEngineer
Haarid Ideu6ficatioa Section
MitigaYion Division
T�nergency Prepareclne,qs
aad ResponsE DirectoAate
EncIosutes .
cc_ Mr. Gazy Waireq P.E.
D"uector, Aixsde Devefopment
. MetropoliYan.AiiportsCommission
Ms. Snsan 1Zimbedy
Director
Depar�xe�t ofPlaoningand
Economic Development
GTty of St Paul
For poug Bellomo, P.E., Chief
Hazazd Id�tificatiou Section
Mitigatiau Division
Emergency Pzep�edness
sad Respoase Directoraee
Ms. MotleySiiadeen
Metro Regien
h�innesota Department ofNat�a[ Resoutces
Mr. Ogbazghi (Qha) Sium. P.E.
11'�nnesotaDepartment o€Natutal
Resotuces— Waters
Mr Thomas E, MacDonaid, P.E.
Senior Engineer
Bazr Engineermg Company
4 !4
�
�
�
1 ��
f
�
�
ST. PAUL DOWNTOWN AIRPORT o���� 3
PERiMETER DiKE PROJECT—BENEFIT COST ANAYLSIS
lntroduction and Study Purpose
� '�
���t�
��' ; '�`�
°�, .
:� �
St Paul Downtown Airport (STP) is located on the Mississippi River and, since 1965; the Airport has
been forced to close five times due to flooding. Most recently, S'IP was ciosed for 78 days in 2001
due to spring flooding.
The financial impact of these flood-induced closures includes not only the cost to clean-up and repair
Airport facilities and pavement, but aiso includes increased ground travel costs and increased delay
costs at MSP. When STP is closed, Airport patrons are required to use other nearbp airports, many of
which aze located further froin the patron's primuy destination. The result is an increase in overall
ground travei distances and costs. Additionally, MSP operates with delay costs and any flights that aze
diverted to MSP, because of flooding at STP, would increase this delay.
These flood-related costs could be alleviated with the construction of a dike along the Airport's east
perimeter along the 1VTississippi River. The purpose of this Benefit Cost Analysis (BCA) is to compare
the benefits and costs associated with the proposed construction of a dike at STP. The proposed dike
(the Perimeter I}ike Project) would pmtect the airport from all floods that would have an expected
annual occuirence of more than 1 percent. Potential project benefits include the mitigation of flood-
related daznages and the prevention of added aircraft delay at MSP; whereas project costs include the
projected cost to construct the dike, the estimated annual cost to operate and maintain the dike, and the
estimated cost to periodically re-stabilize the dike.
Rvle and Objectives of Benefit Cost Ana/ysis
A BCA seeks to deternune whether or not a certain output shall be produced and, if so, how best to
produce it. The BCA reqtures the examination of all costs related to the production and consumption
of an output, whether the costs are borne by the producer, the consumer, or a third party. Similarly, the
methods used in BCA require an examinaflon of all benefits resulting from the production and
consumption of the output, regardless of who realizes the benefits.
Consistent with the principles of benefit-cost analysis, benefits and costs far future years shouid be
discounted to convert them to present value terms. Senefits and costs aze discounted to account for the
fact that a dollar today can be ixnmediately invested to gain real returns, whereas a dollar ten years
from now will not have had the opporiunity to gain retluns over that ten year period. For example, at a
6.0 percent annuai real rate of retzun, $1.00 invested in 2000 will be worth $1.74 in 2010. Therefore, a
dollar in 2000 is worth $0.79 more than a dollar in 2010. Based on guidance from PAA, the discount
rate for BCAs for AIP-funded projects is 7.0 percent.
Projecf Objectives, Alternatives, and Description
Since 1965, the MAC has explored a number of options to meet its objecrive—flood prevenrion at STP
� up to the 1 percent flood event in order to provide the region with a reliable reliever airport—and these
options include:
1. No investment: no perimeter dike or interior drainage improvements.
1 FAA. Airport Benefit-Cost Analysis Guidance, December,1999, Page 3.
� ��
C.�Documenis and Settings�db7ack�Loca1 Settings\Temporazy Tutemet Files\OLK14El�tp bca faa dikeplus exc below OHW oc[ 12 2005 revisioa.dce
Paor t
y ��.,. '_�'� , 0 6- 3 b 3 .
.. �-t�� �� '�
�� � 2. Construct a new airport configuration with flood protection.
3. Provide flood pmtecdon around the current airpart configuration.
4. Comp2ete ciosure of STP and demoHtion of aiiport facilifies.
5. Provide only ittterior drainage improvemants at STP, no flood wall construction.
6. Reconsiruction of the airfield with flood protecfiou (protect primary runway).
A nvmber of studies have determined that option #1 is not acceptable givea the economic impact of the
Airport and its vital roIe in the MAC system of airports. Futther, construction of a new airport
configuration (#2) fias been deemed too costly and disntptive. Comptete closure of STP (#4) would
have documented negative impacts on the Iocat economy and on air traffic management at the nearby
airports (to wiuch STP tenants relocate}. Interior drainage impmvements, without consttuction of a
ftoad wail (#5), would resuit in operational use of the ivnways more quickly after a ftood event, but
would not prevent the t�oods themselves. Rec:ansmiction of the aufield with fload pmtection (#6) was
coasidered unfeasible in a 1999 report (E�1TB) because it would rec�uire a consideiabte capitai ouday
while still leaving maay azeas on the Aiigort vuluerabte to t�ooding.
The rema;ning option (#3), the Perimeter Dike Project, would pmtect the entire Auport from floo�s
having a greater tfian 1 percent chance of occusing in any given year and provide the region with a
reliable reliever auport. The Perittieter Dike Project (tfie Project) would consist of both permanent and
temporary dike sechons. The permanent dike sections woutd be comprised of sfleet pile components
and earthen components along tfie east perimeter of the Airport. The temporar}r dike sections vvould
only be deployed prior to an andcipated itood event and would be placed across the east ends of each
runway to seal the petmanent dike components.
I€ is anCicipated that construction of the dike would increase the stage Ievel of the 1 percent flood event
by an estimabed 0.03 feet As a result, some sort of additional mitigation will be necessary to offset
this anticigated increase in stage IeveI (set it back at zero). Three sub-altematives were considered to
achieve this goal:
a) Compensatory excavation below drdinary High Water (OIiW),
b) Compensatory excavateon above OHW, an@
c) Compensatory excavation with mitigation of nnpacted suuctures.
These altematives have been analyzed, and snb-alternative "a" has been chosen as the preferced sub-
alternative: It is ttris sub-alternative ttiat has been included in the With Project case madeled foi ttris
BCA.
BCA Assumptions
This BCA evaluaYes the benefits and costs of the proposed Perimeter Dike Project and compares them
to the Without Project aitemaiive. The Without Project case is not intended to be a"da nothing"
coutse of action in which condititons at the Airport are held static. iY is intended To represent a
reference point. against which both the ineremental costs and incremental benefits of the proposed
alternative are measured. The Without Ptoject case assumes no dike is built, but that significant
improvement is made to the interior drainage at STP. For the purpose of this study, the With Project ,
case assumes that a dike is built, and that significant improvement is made to the interior drainage at �
Z Svsne Resolution C�fereace, Briefmg Paper m�d First Diajt Screening Iever Xeport, St Pau[ Downtowrt Airpon (Xolm�m Field) Flood Contro[
Feost7�ilityStetdy. ' '
C�Documents and SettingsLdblackU.ocal Settmgs\Tempa�uy 7otanet Files\OLffi4E1sIp bca faa d�kep)ns exc below OHW at 1220051evisi�.doc
Page 2
�
�
� y �. '• ._
.:.. � '
� i �
3TP prior to construcrion of the dike. Under the Without Project case, it is asswned that STP will
experience 16 days of ffood-induced closure due to a 10 percent flood (,flood levels having a 10 percent
chance of occurring ui any given yeaz), 2� days due to a 5 percent flood, 38 days due to a 2 percent y , ,
flood, and 56 days due to a 1 percent flood.
The BCA is based on the following generai assumptions:
► The proposed Project will prevent floods at STP that have a greater than 1 percent chance of
occu�ing in any given yeaz {protect up to and including the i percent flood event) and STP will
remain operational during the 10 percent, 5 percent, 2 percent, and 1 percent floods.
► Growth in activity at the Auport is based on the most recent PAA Terminal Area Forecast (TA�
published in 7anuary 2005. The TAF growth rate was applied to the Airport's CY 2004 operaflons
levels to generate a forecast of operafions for use in this BCA. It should be noted that the TAF
only extends through 2020; therefore the activity levels beyond 2020 are extrapolated using the
TAF growth rate.
► Passenger growth at MSP is based on the High Combination 2 forecast scenario in the LTCP.
► The project evaluation period is 50 yeazs after Project completion (2008-2057).
► All dollar figures aze presented in year 2005 dollars.
Estimate of Costs
This section discusses the costs associated with the Project; including construction costs, re-
stabilization costs, and annuai operating and maintenance (O&11�.costs. Costs are presented on a year-
by-yeaz basis in year 2005 dollars over the 50-yeaz evaluation period (2008 — 2057).
As shown in Table i, the estimated coristruction cost for the Project is $22.4 million, which includes a
20% corttingency factor and engineering costs, which are estimated at 30°l0 of total construction cost.
Construction, and associated costs, is expected to occur evenly over two yeazs. Annual O&M costs
associated with the Project are expected to run about $32,836 a year. Recurnng costs required after
major flood events is expected to cost approumately $236,000. Because this expense is expected
approximately 18 pexcent of the time, the average annual recurring cost is esrimated at $42,480. When
these costs are combined, the total cost of the dike over the 50 year evaluation period is estimated at
$26.2 miilion.
Discounted costs are discussed in the summary section below.
Estimate of Benefits
A number of benefits would be associated with the construcflon of the Project and resulting flood
prevenfion. For the purpose of this analysis, project benefits were divided into four categories,
including the benefit of:
1) I.onger usefui life of Airport pavement (major rehabilitations occur less frequenfly)
� 3 These figures were 18, 28, 49, and 77 days prior to the confrmafion that the interior drainage improvements would be
comp]ete pziar to construction of the dike. FIydraulic modeling of the drainage improvements revealed estimated
reductions in closure days as a result of the improvements.
4 Per FAA BCA guidance, constant dollazs in the year of BCA development are used for these analyses.
��
C:\DOCUmenu a¢d Setfings\db7ackUacat Setti¢gs\Temporuy Iatemet F'iles\OLK14Estp bca faa dike plus exc below OHW oct 12 2005 revisioa.doc
Page 3
�
2) Prevented flood damage from 10%, S%, 2% and fioods,
3) Prevented additional ground travel costs.
�b�3�3 z -�
�=�;
y. 3
��µ �
� „
�
4) Pzevented additionat airccaft delay at MSP
5} Reduced pavement rehabilitation costs (discussed above in the cost section)
These benefits are estimated as incremenfal benefits—the difference in beaefits between the With
Project case and the Without Project case.
Table 2 displays tite costs for pavement rehabilitation under bot6 the With Prdject case and the
Without Project case. These costs are shown separately &om those in Table 1 because pavement
rehabilitation will be required pnder both scenarios; however, rehabilitation is expecYed to be more
frequent under the Without Project case due to a higher incidence of flooding, and khus an increase in
pavement deterioration .The first eolumn in Tabie 2 presents pmjected pavement rehabilita6on costs
assuming the dike is built (With Project) while the second column presents these projected costs under
the Withont Project case.
Under the With Project case, pavement rehabilitation is expected to take place every 12 years at a cost
of $4.Z48 million per rehabilitation for a total of $17.7 million over the evaluation period. When .
atmualized, these costs are estimated at $354,000 per year. In comparison, pavement rehabilitatioa is
expected to take place every 10 yeazs under the Without Project case for a total of $21.?f3 million over �
the evatuation period. The difference in pavement refiabilifation costs (incrementat benefit) between
the With Project case and the Without Pmject case is $3.54 million, or approximately $70,840
annuauy.
The next category of benefits, prevented flood damage, is specific to flood events, and represeats the
cost savings that result from preventing damage to, for eacampte, tenant aircraft and Airport pavement
Tabie 3 includes the estimate@ tenaut damages fro� a 10°l0, 5%, 2%, and 1% ftoods. As shown, the
severity of damages increases with the severity of the flood. The incremental increases ao uot follow a
set pattern, however. Tenants reported four distinct types of damages from the most recent f�ood event
– relocation, damage, clean-up, and fueUrendother. Relocation is presumed to be a fixed cost; when it
is required, it is so regardless of flood duration. The remainder of these damage types are vaziable
according to the number of days the Airport is closed. Total damages range from approximately
$1,626,966 for a 10 percent flood to $4.42 million for a 1 percent flood.
These damage estimates were then annualized by dividing the total damage amount for each flood .
level by recurrence interval ofthe flood level. For example, a 5 percent flood is expected to occur
once evary 20 years. Total damages from a 5 percent flood are estimated a# $2.186 million. These
damages are annuatized by dividing $2186 million by 20 yeazs for an annuat average of appmximately
$109,300.
The final row in Table 3 presents the average incremental annuai damages from each flood leve}.
These ate calculated in order to avoid double counting prevented flood damages. Incremental annual
damages are calculated as follows (using 2% flood as an example): [(Total damages from 2% flood
minus Totai damages from 5% flood)!SO yearsj. The incremental annuat damages in Table 3 are
shown on a year-by-year basis in Table 4. The last coimnn in Tabte 4 presents the sum of average
anneial damages from all floods over the 50 yeaz evaivatiou period. ��
The third major benefit category is preventable ground travel costs. When flooding at STP forces e
airport to close, tenants have to divert to another nearby airport. For the purposes of this study it is
assumed that most of the passengers azriving at STP are bound for downtown S�. Paul. If STP is
cwo�.,,�nes ana semn��,�v.«�t s���t�p«azy �remet 1�wiacias�q, na raa mxe p� � nPaow oxw«x i2zaos re��.ao�
v,o. a
�
0�-3�� �����'
ciosed, these passengers are likely to divert to the next most logical airport, MSP, which is located
further from downtown S� Paul than is STP. The result is an`increase in ground travel distances and
travel times whenever tr�c is forced to shift to MSF. The proposed dike will mitigate flooding at the
Airport and will, consequenfly, reduce the number of flood-induced closures and associated diversions
to neazby airport. This translates into zeduced travel distance and travel fime and, accordingly, reduced
ground travet costs for the patrons of STP.
The magni[ude of these iravel cost benefits is based on the assumprion that STP would be clased for 16
days during each 10 percent flood, 24 days during r each 5 percent flood, 38 days during each 2
percent flood, and 56 days during each 1 percent flood. Additionally, it was assumed tfiat four
passengers would be on each diverted aircraft operation and that they would each encounter an
additional9 minutes of travel 6me when forced Yo fly in or out of MSP rather than STP (15 minutes
from MSP to downtown St. Paul versus 6 minutes from STP to downtown). It was also assumed that
each goup of diverted passengers would take an automobile to downtown St. Paul and that the auto
must travel 8.25 miles from MSP to downtown St. Pau1 compared to only 2.5 miles from STP to
downtown St. Paul, a difference of 5.75 miles.
Using these assumptions, the foliowing steps were taken to estimate the benefits associated with the
reduction in travel time and distance:
1. Multiplied projected annuai operations at STP by the percentage of days a year that the
Airport would be closed due to a flood event (16/365 in the case of the 10% flood event) to
� derive the number of operations that would be impacted by each flood event. In 2015, for
example, operations at STP are expected to reach 147,360. If this number is multiplied by
(16/365), the product (6,460) is the number of operations that would be unpacted by a 10
percent flood event.
2. Multipiied the number of passengers per flight (4) by extra travel time (9 minutes), then by
the product of the calculation by ($48.60/60 minutes), where $48.60 is the value per hour of
time for a GA passenger. The resulring equation is [4*9*($48.60/60)) which equals $29.16
per impacted operation.
3. Multipiied the number of additionai miles that diverted passengers would be required to
travel (5.75 miles) by the current federal government mileage rate of $0.405 for total of
$2.33 per diverted operation.
4. Added tfle ground travel time cost ($2916) and automobile costs ($2.33) to get total travel
cost per operation of $31.49.
5. Multiplied the total ground travel cost per operation ($31.49) by the number of impacted
operations as calculated in Step 1.
6. Calculated the average annual incrementai cost for each flood level as described above.
7. Snmmed the average annual incremental costs from each flood event to get total average
annual costs.
�
The results of these steps are displayed on a year-by-yeaz basis in Table 5. As shown, these benefits
are expected to total $2.0 million over the 50 yeaz evaluation period.
5 FAA, Economic Yalues forEvaluallon ofFederd Aviallon Adminishahon Inveshnent and Regul¢tory Decisions.
� ��
C:�Documents and Settings�db3ack�i.ocal SepingslTemporary Intemet Fles\OLK14E1stp bca faa dike pius exc below OT3W oct 12 2005 revision.doc
Page 5
�
�� �
t�b-363
The fovrth category of benefits relates to aircraft delay at MSP. As menfioned above, it is assumed �
that when STP is closed due to flooding, aircraft that wauld othetwise use STP instead divert to MSP.
Aircraft atMSP experience delay even without the addiflon of flights from STP. When flights from
STP are diverted to MSP, they only add to the congestion and resuIting delay at MSP. This added
delay waild be prevented (benefit) by the proposed dike be�cause it wouid protect STP against floods
up to and including 1% ftoods and thus, prevent flood induced clo'sures at STP up to and including the
1% flood level.
The calculation of the pzevented delay benefits is displayed in Table 6. The first column in the table
shows projected annual operations at STP. The next four columns in the tabie show the estimated
number of days that STP would be closed due to each flood event The duration of these closures is
the same as in Table 5(16 days for the 10% flood level etc.).
The fifth column in the table presents the esflmate@ nnmber ofdiverte@ operations per day. Unlike the
ground travel cost catculafions, which assumed that all operations &om STP would diveit to MSP
during flood induced closares at STP, the calculation of delay benefits assumes that oniy one-thixd of
twin engine aireraft opeiations and twathirds of jet aircraft operations from 5TP wouid divert to MSP
during flood-induccd closutes at STP. It is assumed that the remaining twin eagine and jet operations
from STP, as well as all the single engine aiicraft operations, would instead divert to other less
congested airports in the region. The accepted forecast for the BCA indicates that appmximately 25
perceat of aircraft operations at STP are twin engine aircraft wbile another 35 percent are jet aircrafk
Using 2015 as an example; the number of aircraft operadons that divert to MSP each day was
calculated as follows: [(25% *(ll3)) +(35% *(2/3)) * 147,360], where 147,360 is the projected total
number of annual opeFatioffi at STP in 2015. The result of this equation is that an estimated 128
operafions would divert to MSP daily while STP was closed.
The next two coiumns in Table 6 aze labeled "Daily MSP Operations". Tfie figures in the first cotumn,
labeled "Without Diversion", represent ttie annual forecast of opezations at MSP divided by 365 � The
next column, labeled "With Diversion" includes (again, using 2015 as an example) the 1,699
operations that aze projected at MSP plus the expected number of STP operations (128, as calculated
above) tfiat will be required to divert to NLSP during a STP tlood-induced cIosure for a tofat of 1,827
operations. The next two columns in the table, labeled "Average Delay per Operation" were taken
from the MSP Capacity Enhancement Plan and represent expected average delay per operation at MSP
with and without diversions from STP.
The aext column displays the cost per operation per minute which includes both the aircraft (fuel, labor
etc.) cost of $33.47 per minute and passengers' (cost per iravel minute) delay costs of $33.63 per
minute. Tfris cost per operation per minnte figure was developed using FAA figures for the value of
passengers' time, and updated MSP fleet mix and load factor projections. These data were utilized in
the following formula: (Daily Operafions * Delay per Operation * Cost per Operation per Minute).
This calculation esrimates tiie average daily delay cost for both the Witfi Project case and the W'itfiout
Project case. The cost difference between the With Project case and the Withoat Project case
represents the delay costs that would be pzevented (benefit) by the Projeck �
The next step is to multiply the daily delay cost that would be prevented by ihe Project by the number
of days that flights would be diverted from STP to MSP during each flood event. Again, using 2015 as
an exaznple, the daily delay benefit of the Project is estimated at $620,285. During a 10 percent flood
6 Confirmed by written correspondence witt� the. STP air traffic control tower. ,��
�'iLe opecati� projations for MSP aze from ifie MACs Long-term Camp,efiensivePlart (LTCP1� H'i� Combinatio¢ 2 FoiecasC
C:�Documrnts and Setfings�lack�i.ocal SeumgslTempaary Wemet Fila\OI.K14Islstp Ma faadikeplos eac 6elotv OHW oc[ 12 Z005 revisioadac
Page 6
�
��
�
����� 06-363
event it is expected that flights will divert from S`I`P to IViSP for approximately 16 days so 16 is
multiplied by $620,285 to derive the delay cost per 10 percent flood event that would be prevented by
the Project. 'I'fiis calcularion is done for each flood event and then these costs are converted to average
annual incremental costs as described above. Finaliy, the average annual incremental cost for each
flood event is summed in the last column of the table to anive at the total average annual delay cost
that would be prevented by the Project (total delay benefit).
Table 7 presents a summary of the benefits (prior ta discounfing) that would be associated with the
Project. As shown, benefits from prevented flood damages are expected to total $15.4 million over the
evaluafion period. As mentioned above, the Project would protect STP against floods up to and
including the 1% flood and, thus, prevent flood-induced closures at STP up to this level. As a result,
the proposed dike would prevent the additional ground travel time that passengers incur when they are
forced to travel to MSP during a flood-induced closure at STP. As shown in Table 7, the estimated
benefit of preventing this additional ground travel rime is $2.0 million over the 50 year evaluarion
period. The presence of the dike will extend the life of Airport pavement, thereby reducing the a�erage
annual cost of pavement rehabilitation. This benefit is expected to total $3.54 million during the
evaluation period Additionaliy, because the Projebt wouid prevent flood-induced closuxes at STP,
STP flights would no longer have to divert to MSP during floods. This will prevent the additional
aircraft delay at MSP that is imposed by 5TP flights when they are forced to fly in and out of MSP due
to flooding at STP. Over the evaluation period the prevention of this addi6onal aircraft delay is
estimated at $1321 million.
Summary
Table 8 summarizes the annual incremental benefits and costs associated with the Project during the
2D08 - 2057 evaluation period. These costs and benefits are displayed before and after being
discounted using a discount rate of 7.0 percent. Total undiscounted benefits for the Project are
estimated at $153.0 million, compared to $26.2 nnillion in undiscounted costs. After discounting,
benefits aze estimated to be $27.5 million, compared to $21.2 million in costs. Because benefits are
expected to occur further into the future than costs, benefits are discounted more heavily than costs.
The resulting benefit-cost rario is 1.30.
��
C:V>ocnments and Settings\dblack�Local Settiugs\Temporary Intemet F'iles\OLK14Estp bca faa dike pFus exc below OHW oct 12?A05 revisiou.doc
Paoe'7
� � Ob-363
� Table 4
�� ST, PAUl. OOWNTOWM AtRPOR7 BENFFlT-COS7ANAtYS�IS
� PEHIMETER DIKE PROJECT �
EeBmated ConalraeNu�.06N, antl ReSlabl7zatton Coab
2005 DolYars
Annual
Construction OSM RecuMng SMd
Ye&' Cwfs (a1 Cost @) Costs [c) IIwts
2006
20U7
2008
1D09
2010
]017
2012
2013
2014
�15
2078
2077
2018
zoys
xzo
2027
20'12
2023
2024
2025
2026
2027
�
�
2030
2031
2032
2033
2Q34
2035
2036
2037
�
�
2040
2047
�
2043
2044
�46
2048
2047
2U96
2049
2050
2051
�
2053'
2U54
2055
2a58
205!
17,200,000
11,200.000
3'1�838
32,836
�,�
92.838
��
32,836
32,836
32838
32,898
��
32,836
�t,aae
��
�,836
��
��
��
�,�
32�896
32.836
��
32.836
32,838
32.836
32.&96
31.838
1
32,836
32.�i6
32.836
��
32.838
��
92,836
��
52.836
32�&?8
��
�,�
32,838
32,838
3'2.838
32.836
�,�
32,836
��
��
3'L.838
32.&36
32.836
32.836
42.480
42.486
42,480
42.480
42.480
42.480
4$480
42.48Q
42480
42.480
42,480
42,48p
az,aaa
42.480
42,48Q
42,480
42,480
42,480
42,480
azaeo
az,aso
42.480
��
42,480
�,�
��
42,480
42,480
42.480
42.480
42.480
42.480
42,480
42.480
42.480
42.480
42.460
42,480
42.480
42.460
42.480
42.480
42,480
42.480
42.480
42.4&0
42.480
42,480
42,480
42,480
11,200,000
11,Z�D,000
75,318
75,316
75,318
75,316
75,316
75,318
75,318
75,378
75 378
75,318
75,318
�s,a�s
75,3Y6
75,3i8
75,318
75,378
75,318
75,318
75,3}&
�s,�te
75,318
75,318
75,318
75,318
75,316
75,316
7b,316
75,318
75,316
75,378
75,318
75,316
75,316
75,318
75376
75,318
75,316
75,3l8
75,316
75,318
75,378
75,376
75,318
75,318
75,37 B
75,3iB
75,318
75,318
75,316
75,316
Total $ 22,4D0,a00 S 7,641,800' $ 2,124,000 $ 26.765,800
a sa20°ecanhngency a ran engneenngcosts estlmat at e canstrucUOn
costSj.
@) HNTB Malysis
(c) Esomated to cost appropmatley 236,000 perevenf, and indu�s some replacertrent of riprap and othe�
wwk To restabiGZe the dke. Evems requtring lhfs expenseare expected at a pro6a6�ty of O.iB.
Source: HMB analysi&
�
�
�
�� �
_,�, '►:. :. .
-;�:. �` . _.
Ob-363
Estimated Pavement RehabiliWtion Be�fits
2005 Dollars
�
�
Pavement Pavement
RehabllRation Rehabiiitation Average
Cost�N'dIs CostWiihout Annual
_ Year Pra[ect (a1 Proiect @) Beneflt
Average cost of pavement reha6ilitation ( t occurrencej $ q�pqg�ppp
2008
2009
2010
Zo�t
2012
2013
2014
2075
2016
2017
2018
2019
2020
2D21
2022
2023
2024
2ou
2o2s
2027
2ozs
2o2s
2030
2097
2032
2033
2034
2035
2aS6
2037
2036
2039
2040
2041
2042
2043
2044
2045
2046
2047
2048
2049
2050
2057
zosz
2D53
?A54
2055
20.56
2057
Reha6tlitatlon once every RehaDilitation once every
72years t0years
$ 354,000 $ 424,800
$ �`M1.�O $ 424,800
$ �` �� $ 424,800
$ �.� S aza,soo
$ 354,000 $ 424,800
$ `�.� $ 424,800
$ `3.�4,004 $ 424,800
$ 354,000 $ 424.800
$ ' � $ 424.800
$ `3�4.000 $ 424,800
$ 354.000 $ 424,800
$ 354,000 $ 424,800
$ 354,000 $ 424,800
$ 354,000 $ 424,800
$ 354.000 $ 424,800
$ �� $ 424.800
$ �� $ 424,800
$ �.000 $ aza,aoo
$ 354,000 $ 424,800
$ 354,OU0 $ 424,800
S ssa,000 g aza,aoo
$ 354,000 $ 424,8Q0
$ 354,000 $ 424,800
$ 354,000 $ 424,600
$ 354,000 $ 424,800
$ 354,000 $ 424.800
$ 354,U00 $ 424,800
$ 3 �,� $ 424,800
� 3.�1` �000 $ 424,800
� ��� $ 424,800
� � $ 424,800
$ �4.000 $ 424,800
$ 354,000 $ 424,800
S 354,�00 $ 424,800
$ 354.000 $ 424,800
� �4.�0 $ 424,900
$ 354,000 $ 424,800
$ �` ��� $ 424,800
$ 354,000 $ 424,800
$ 354,000 $ 424,800
$ 354,000 $ 424,800
� 3 `�,� $ 424,800
S 3.54,000 $ 424,800
� �AOO 3 a2a,eoo
S ssapoo g aza,aoo
6 354,000 $ 424.800
6 354.000 $ 424,800
6 354,000 $ 424,800
6 asa,000 g a2a,aoo
S 354.000 $ 424,800
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
S
S
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
8
$
$
$
S
$
70,800
70,800
�o,eoo
�0,eoo
70,600
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
�o,soo
70.800
�o,soo
�o,aoo
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,800
70,8(1�
70,800
70,800
70,800
70,800
70,800
70,800
70,8p0
70,800
�o,aoo
7o,eoo
70,800
70,800
70,8�0
70,800
70,800
Total
7ahte 2
ST. PAULOOWNTOWNAIRPORTBENEF(f-COSTANALYSIS
PERIMETER DIKE PROJECT
17,700,000 $ 21,240,�00
3,540,000
��,
(a) Assumes ihat with Pro�ect, pavemeM rehabdttahon would be required every 12 years.
@) Assumes that without Project, pavemert rehabililation would 6e required every 10 years.
(c) Difference (incremental benefit) between WITH and WRHOUT Projec[ altemative.
Source. HNTB analysis.
r
Q
�
_ �•
�
Table S
s
ST. PAUL DOWNTOWN AfRPORT BENEFIT-COST ANALY�IS
PERiMEfER DtKE PROJECT
Estimated Damages trom 10%, 5%, 2% and 1%Floods
2005 Dollars
�b-363 �
Tenantl�easeholder Flood Flood Flood Flood
3M
Natiortal Guard
SY. Paul FligM Center
MAC
RegaM Aviation
Horton Hangaz
MNJ�
Hubbard Hangar
Hafman 12
Wings
720 Bayfleld
740 Bayfleld
FAA (Tower)
Aviatton AAalntertanca
CAP
Total
Average Annual Damage @)
Mcremenqi Annual Damaqe (cj
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
608.543
95,720
213,709
172,295
282,�6
16.592
117,6b4
5,482
i8,t97
49�790
369
�s
33.186
1 t,207
5�
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$ 1,626,966 $
$ 162,697 $
$ t62,697 $
na,3se
i27,447
320�563
232.066
424,044
16,592
141,915
8.841
19,578
69.525
553
�is
3$186
14,5Q7
704
$
$
$
$
�
$
$
S
$
S
$
S
$
$
$
2.186,Oai $
109,300 $
27,952 $
1,075,565
i82,S69
507,558
336,665
671,403
16,592
184,365
9,218
20,243
104,166
S76
184
33,186
20�280
1,047
S
$
$
$
$
$
$
$
$
$
$
$
$
$
3,164,318 $
63,286 $
f9,56fi $
1,457,674
254.35M1
747,980 .
471,149
989,436
16.582
238,947
12275
27,099
148,705
1291
272
33,186
27,7Q3
7,489 �
4,422,152
44,222
12,578
(a) Tenarrt input, including relocation and damage costs. To estimate damages for diflereni tbod levels, relocation costs were
expected to be constant for arry flood, wh0e other costs were estimated to be proportionaC to ihe number of days STP was closed.
(b) Totat damage divided by reprrrance interval.
(c) IncremeMal dainages equai total damage from a flood less ffie total damage fran ihe previous (more frequent) flood drvided
by the Bood rewrrance intervat. For example, the incremental annua! damage of a 2 pereent flood is the total damage of the 2
percent t�ood less the total-damage of the 5 percent fbad droided by 50 year� or (25'e damages-5% ftaod damagesu50).
Source: Surveys of Airyort Tenards and HNTB anatysis.
�
�l �
�
�- � � �� O6-3b3.
� rame a
��� SLPAULOOWNTOWNAIRPORTBENEFlT-COSTANALYSIS
PERIMETER DIKE PROJECT
Average Mnuaf Benefit of Prevented Flood Damage from 109' 5%, 2%, and t%Flaods
2005 �ollars
Average nnnua� lnccemeniel {ncremenfa{ Incremental Total Averege
Damages Annual Damages Mnua7 Damages Annuai �amages Annual Damages
10 Perecnt 5 Percent 2 percert{ � p��t p��
Year _ Flood (a) Flood @) Flood (b) Flood (b) Floods (c)
2004 (cn $ 162.697
�
��
2008
2009
2U70
2011
2012
2073
2014
2015
2016
2057
2018
2019
2020
Z027
2022
2f123
2024
2o2s
2026
2027
2026
?A29
?A30
2031
2032
2033
2034
2035
2036
2037
2038
2039
2Q40
2047
2042
2043
2044
2045
2046
2U47
2048
2049
205Q
zas�
2052
2053
2054
2055
20.56
2Q57
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
S
$
$
$
$
$
$
$
_, $
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
569,950
177,810
173.700
175,600
m,sso
779,470
181,440
183,430
185,4-00
187,480
159,530
1si,stia
193,710
t95,840
197,980
200,150
202,350
2oa.sio
206,810
209,080
257,370
213.690
216,�30
2ia,400
2zo,soo
223,220
225,660
228,140
230,640
233,170
235,730
238,3t0
240,920
243,570
246.240
aas,sao
251,670
254,420
257,210
260,030
262,890
zss,no
268,680
2�i,sao
274,610
277,620
280,680
283,740
296,850
290.000
Totai $ 11.238.09�
$
$
$
$
5
$
$
$
$
$
$
S
$
$
$
$
$
S
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
S
$
$
$
$
$
$
27,952
29,200
29.520
29,840
30,170
so,soo
30�830
31.170
31,570
31,860
32,210
3'2.560
32.920
33.280
33�650
34,010
34,390
34,76U
35,150
35�530
35,920
38,310
36,710
37,120
37,520
37,930
38,350
38,770
39,190
39,620
40,060
40,500
40,940
41,390
41,85Q
A2,300
a2,no
43,240
43,710
44,190
44,670
45,160
45,666
46,160
as,s�0
47,180
47,700
48,220
48,750
49,280
49,820
1,830,729
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
79,566
20.440
20,660
20,890
21,120
zi,a�o
21,580
21,82A
22.060
22,'..00
22,550
22.790
23,040
23,3pp
23.550
23,810
24,070
24,330
24,600
24,870
25,740
25,420
25,700
2s,sao
28,270
26.550
26,840
27.140
27,440
27,740
28,040
28,350
28,660
28.970
29290
29,670
29,sao
30,270
30,600
30,930
31270
31,620
37,960
32,310
32,670
33,07A
33,390
33,750
34,120
34.500
34,880
1,351,500
$
$
$
$
S
$
$
$
$
$
$
S
�
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
$
$
$
t2,57B
13.140
13,280
13,430
13,580
13,720
13,880
14,030
14,780
14,340
14,490
14,650
14,810
14,980
15.1-00
75,310
t5,470
75,640
15,81A
15,990
76,760
78,340
16,520
is,�oo
76.950
17,070
17,260
17,450
77,640
17,830
78,030
18,220
78,420
18,630
i 8.830
79,040
�s2eo
19,460
19.670
19,890
2A,700
20,320
20,550
zo,no
21,000
2t Q30
21,460
21,700
27,940
22.180
22,420
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
222,793
232,730
235270
237,860
240,470
243,700
245,760
248,460
251,180
253.940
258,730
259,530
262,380
265,270
268,180
271.110
274,080
2n,oso
280.140
283,200
286,300
289.440
292,620
295,830
299.070
302,350
305,670
309,026
312,410
315,830
319,300
322,800
326,330
329,910
333.5-00
337.79(3
340,900
344�640
348.400
�,�
356.070
359.990
363,940
ss�,92o
371,970
376,040
380,770
384.330
388,550
392,810
397,720
868,840 $ 15,389,150
-, ^•-.4n� W"��a� � W������ ��,�e u, ewsumea w uicrease at same mte as aircrafc operations
(b) Inoremental annuai costs from Tabie 3. Assumed to increase at same rate as aircraR operations
(c) Sum of average annual and incremental annual flood darnage costs.
(� Potential benefik
J
a"ource i-iiv i u anarysts.
�
.��
.��'
� �'
�
� �
� _
..
�� S
�
� �� ;�
�¢ �
r� k' �
o �
o m
� �
ffi �
�
fl6-3b3
"��3����3g����������°�8m��&������g��y5�`s_c��a�e��E� �.
���s�.at#�, :sfs7 s�xta���a�sF� :�at��ss.—: 7ss�: ::9�sssn ��a �
ayawwwa+Nar«wwrx«x�srwr��.awr�wwxr��sw�srw�ww�sarx w
��K��������KKn���K���������������������}���������� f
wywwwws.�xxa�as.�r�sn�sr�a��wNrrr«rasrxawxw�+rsranrrr«a w
���W�������9�����§�����.������6�?�e�ne����������� �
N MMNMMMMNMNYMpNM� 1 Yi 1 MMMp1�MYNMNMYMNNY�yMMNYMtltluiYtltlMMq M
NBFai�n�a�pR�3n6i_�bpiSdo`��.j6Sm��dS,�S'���F�i����}E�6n��a.�de �
1 �NY M MM�tyNNNMNNNMYMMN4MY0MMMNNNMNMpMqYMMNNgMMMYMtlNp ♦
����������s�s�������aaaa���������a��a����$���aa �
Y MM N bNMyMNMMMMMMyqYqNMNYtlMNONYYMpNMMtl�YMYNYMNMMNNMM M
4YMM yy M MMMMMNyYgbNMYMYYMYMMMNMA4�MNNYNNINMMNMMMMYN
a� a�t� R� $ i 9'sR�ego����3 ���'a' s��a���as
� ��:�����s�9��a�����3�0��6���E���k����������s9�
wa wwa�sa��sa�orwrrwr aas� �swwa raya�ws � r a r wawr.ia ra.�wwy xw w w a
� a���7�=S�Y��'t����i��� a�� ����
a����a���;�a5 ��;����#��wa't��� 5.:�3� s ��::����pd��
aNa+aixa rr xrrwx sN rr waswaxa �s r�swww awx a a wywsN asa rs s r r xwrw
N qN N tlMpNMNNNNMtlNpNYNMNgYNYYMbMNbNYbMMbpNY�MMMNMNbMp
Qg�Y�QYg3g�3g33
n'nw'ma'�'ww�ei^w^.^.'m`n.`e.v�e'.m`n'm^.A'a'w :F.e^�'we�.�o`n`.^�a'ew`o'one'.S.'w`m'm�mr^.'w'm`m'm
Y p MM Np M NNNY 4 wMNY»NNYNwtlMqqYbYYNMppMMYNHNYNNMNMNNNN
�H��raa��d����d�N�dNa�n�
MYNNqYNpNN y YN qMMpYtlypYYNNqYYNNMM4MYMYNMMNtlMbNNbNMA
amememeeesemeomo'memmmameoaooemove�meamem�mm�amo
R
tlMMMNMMNNY MMNMNNMNNyMYytlYYMMMMiMMNNYtlNMpMNMMMNNMtlp
C s C �s , t�e - y y �g y &�� ! s���31E�` g ��3 ° -_��$`�'&ss���3��5��l���s$����
ptlNNfi�N�aNFIFIq aSe9e91g�.$.EeiCvR &$e9$�'we'�'n 8f Ae
�t����3��������3"a���
.-��� �eY�Saa3eYR�Y�A
��°
���m��m���������`
�$��3a����#����$s-���:����s' ��=���"s_�$��g��a8���+a'-�
���°e'S�Y94��b"5�;�65'm ����a.l'R'mE$��o38S`��$^w^�'Fiw������F�n��'��
$R$RA 3
�
�
�
3
a
�
€
�
�
�
y �
i
�
�
6
m
�
a
�
�
�
�
�
s
_O,b-*3,E
� g ��e&o���������������x���x��������saav�aa����e��
r 9�&'8"C�°.+�o
HMHHbIHHMHhNHHNNNNNNN(MMyNNKNWKHKKHHNHHWHNH/9HHbIHHNNH ; �
6 p qqqqp qq q q m y
VmJJYJJmVYVVVVV�JVJJVYJJ�1YrJVYJ�IVVVVJJVVmVVVVVVVJ T+�
00000000000000000000000000000000000000000000000000 9
HWHlAbIblblHbIWHHWHHHf9NHW4lK(qiqNblMNbIHWpHytpHNHHHH(9H(nH(9HHNH
O � o � o � O � o .��a�rr p r�u p +� o + o �� o + a + o +r q r o r O ��r a rr o �r� o .a.� rprr � r � rq �� 0
W9mmm�SSS
���t,�.��,.��,�f°i,4,4,Y.aCa�i(u4aSiPul.,fJ�^,f.,fJfJYGt�G��t,�GV V V V�3m0=4°iV �OPNNOOmOYv
J4VJJJJJYJJVJYVVV
(9pKHblHlbi(FN
NNNNmNNWNNNNNNNNNNNyNNNNNNNNNNNNNNNN±±±+��++++�±
aV��a�Vmi�gsJ�����V����A�W���ss����ss��sP�.s��A�x9
�$�sm
00+0PJN+P00 NflO �OOb 0
WNV1M(9NWWb16iHbIHHHHHNNNNg1y(Aq(qy(q NyNWNrpNNHV1NWN N(FWWWNb1 HH
���������.a.a�r��.�.�.��.��rrrr����
�m����os�mgm;�s������'^���°�°mo���a��mem�mos��m��°
�m�
NWlqNK6fH(NHHHHH HHNHb1HNHyb1(pHNWdHlMNNbIpNNMNNM NbIWHNlpNHWH
VO
�t�.S�P�aOro��mmm�m�
�ms8�m
d.w«.»wwwud.waw«.b.d.w«.w.9w
�im�m�mwmp��iYiiN+�000t
N�� Pi�iAm�mV�SN(
Q OJNNNj0 0 fJ(JV Or p�0A�4 A iNVidNV�!OPtOAW� q NNOJ+�NPWA� O �NO p i4�A O OV (J [�i��W
I�Vf
w
PHmp�mJ
J��NpON
�H�:�H�ss�a£c,om���w�H�m�s��m�������,��m��ms�����,���
w
AfJ+�90&4
�
S
M NMMp(Rb141NNb1pNHHGWNHHHNNNNWNNNHNNHNNNNNHHNfNNNNNHPf9(9N
S p�uNqNN�ufoN NNNNNNN��++r�������������������� J
+ ° ma �0 ,1 ��
£ �§�o�m,� �s���,m��,��o�_°s�,�������,�m���m,��N�$�m�����
_ ����90�W$�e���s��°'� N��Sk���ssJa� m��� +�
00 JNOJmWO�dO+ 0+0qJ41 PNN 0 W�AWqVAm
M NHNHNNFpKNNpH6)f94IWHHdb1lq(qWHHMBIbIWMHMHMNbINbINNHHNHW(9HHW
N
; 3��m�H�N�go�000�'$�.�a������o�w�s��N���o,�mH�o�����m
a 9������s�����s���se����m��mN�sms�m�N"s�s��::om�����
» �.�,«.�,�.�.�».»�.«.�,�.H«.�,��,�»«��.WW�.H«.w�,�«��,«.�«�.«.�.W«�«.«W�.�.H�.«.«.��,»
A> y A pA (.�La(.� qf.� � 4t (pip � NN m NNNqN p NN 0
O p�V
N O>OL
N (9(9f9HHNbI41V
b N J N (J N � j q q 6
N pmYJNV±O�VNVYmAOO
� ��m�������m�Nnmos��s��°�o�em��em�o����WOO�N����&;N
� ��������ywyNyy�N�yy�yyy�H�����y������yyy����������
� � P ��Od������fnN�N��� NNNNNNNNNNNNNNNNNNNN � +++++++++++
q J{� N q ym O OitIN� IJIV+�00�d�mfNP(J� m
O m y N / �Vl�iaO�VAO� ? JNp� ? Pm O 0�d±0 Q N4i�+tSY N H O O (p �W�ON q �S $ �i��+A p �m q WN
+ qY�p
.�
, �,�: _
a
<
Z
i
n
m
g
e
�g3
n
s
0
P
d
A
Y
�
9
D
!�'
O
4
m
a�
3
my
O�
m
vm
��
o�
ti�
i
<
N
N
�l �
4 '
,�:
�
�6-3b3
F ���������������������������������������:��a:���o��
mmmmmmamamawmma:mmammmaW:maWam�mmmmmmmmm�mm�amemmm
aS'A' `�'SL'>eS'S'i"e
mm�����������mmmm�m�mm�mmmmmmm���mmmmmmmmmmm�mm��m
mm
��
tlJA+O
d
��$Zm��3������s������&���������mm.roe���e&��e���:��
ea000aesooevao°o"soo"sooe000a000eooaeov�o�:o�a�,oaaNt
NNNNp
�Hobb
NpYPMM � NMpppN NNN M NMNMNNNbNNqNNNNNNWbNN00YMYYNMMYNN
9 99,. ° .9"t9999 9 399 9 939 9 39'i399"i99999999399999999�93�999
' o ' oe " oo " oo " e ' eo " oo " o'oo'o'o'o"oeo'o'o'o"o'oo'eo"o'o'o'o'o'eo"o'oo"o'o'o'e'oo'o"oc"o'o
��
�
$ s
i
g
�
�
3
��3
4 ��
� Z
a
�
�
�
�
`
a
€
m�� a9
� Z
a
vB
�� e
��
�
m
�
�� �
8�-3b�
�
�
Ta61e 8
ST. PAUL DOWNTOWN AIRPORT BENEFIT-COST kNALYSIS
PERIME7ER DIKE PROJECT
Comparison of Undiseour�ted and Discounted Costs and Beneftb
2U05 Oallars
�� �� ` �� - _� ,_...
UtMiseouMed Dlscounted (a)
Year Casts (b) Benefits tc) Costs Benefits
2006
?A07
2008
?AU9
2010
2011
2012
2013
2014
2015
2016
2017
2oia
2019
2020
2o2t
2072
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041
2042
2043
2044
2045
2046
2047
2048
2049
2050
2051
2052
2053
2054
2055
2056
2057
� Total $ 26,765,800 $ 752,984,637 $ 21,157,671
Benefit-Cost Ratio (d)
Table 1.
Tabie 6.
Discounted 6enefit tlivided by discounted cost.
$ 17,200.000
$ 11�2t10,000
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,318
$ 75,316
$ 75,316
$ 75,318
$ 75,316
$ 75,316
$ 75,318
$ 75,318
$ 75,316
$ 75,318
$ 75,318
$ 75,318
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,376
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,376
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,318
$ 75,318
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,378
$ 75,316
$ 75,318
7.355,848
1,438,559
7,527,515
1,591,196
1.658,025
i,�zs�m
1.801,83:i
1,879,155
1.972,118
z,o�o,az�
2,174,378
2,284,349
2,400,687
2,523,751
2,597,510
2,632.917
2,675,730
2,718,198
2,762,080
2.806,838
2,852,492
2,699,063
2,946,565
2,995,020
3,044,462
3,094,916
3,146,396
3,798.940
3,252,564
3,307,3}6
3,363,204
3,420,259
3,478,531
3,536,051
3,598,823
3,660,979
3,724,346
3,789,128
3,855,344
3,923,002
3,992,182
4,062,8&5
4,135,153
4,209,072
4,284,636
4,367,933
4.440,982
4,527,863
4,604,610
4.689,287
$ 27.525,872
7.30
$ 10,467.290
$ 9.782,514
S 61,480
$ 57R�
$ 53,699
$ 50,766
$ 46�903
S as,a3s
S 40.967
S 38�287
$ 35,782
3 a�,a.ti
$ 31,253
$ 29�209
3 z�,2sa
$ 25,572
$ 23�843
$ ���
$ 20,826
$ 19,463
$ 18,190
$ 17,000
$ 15,888
$ 14,848
$ 73,877
$ 12,969
$ 12,721
$ 77,328
$ 10,587
$ 9,894
$ 9,247
$ 8,642
$ 8,076
$ 7.548
$ 7,054
$ 6,593
$ 6,182
$ 5,758
$ 5,382
$ 5,030
$ 4,7U1
$ 4.393
$ 4,106
$ 3,837
$ 3,586
$ 3,351
$ 3,132
s zsz�
$ 2,736
$ 2,557
$ 2.390
$ 2,233
i,ios,ns
t,097,470
1,089,097
1,060,281
1,032,535
1,005,815
980,078
955,267
936,939
sis,zsa
902,290
885,970
s�o,�20
854,882
820.406
778.985
739,696
�ozasa
667,079
633,540
601,724
571.540
542,902
575,729
489,946
465,482
442,266
420,236
399,327
379,485
360,652
342,776
325,809
309,705
294,415
279,902
266,123
253,039
240,6tH
226,823
217,625
206.989
796.8&9
787,296
178,187
769,534
161,345
153,507
146,090
739,043
Source: HNTB analysis.
�'�
. . ,�
� .�
��
Tah(s,
ST. PAUL DOWNTOWN AIRPORT BENEFlT�COST ANALYSIS
PERIMEiER DIKE PR0.IECT
s�anmry a una�+wwaa e.nams
�005 ooilvs
70.BOD
70,BOU
70.eU0
ro,eao
�o.eao
7o.eoo
70,800
�o.eao
70.800
�o.sao
�o.sao
�o.eao
�o.eoo
�o,eoo
70.Bao
70.BOD
70.80D
7U.800
70.BOC
70.800
711.800
�o.soo
�o,eao
�o.eao
70,800
70,800
70,BOD
70,800
70.800
70,8110
70.800
70,8W
N�
70,800
70.80U
70.800
70,SQ0
70,800
�A�
70,800
7(1.900
70.800
ro,eoo
70,HW
7(Ip00
ro,eao
R1.8p0
7(I.BOU
m,aou
ro,eao
Prw�nNd R�uad Pro�nYd
Prevenled AdNtbnY PtwminL AdrlRlonal
t7ooU 4oun2Tnv�1 RMab AfccraROelap
Yur UanaS�(tl Cosb@) Cosqk) atMSP(A1 ToM
2U06
20M
26f0
san
T012
2013
mts
20tS
m�s
zon
sme
��
�
�t
�
202i
�
TD3
2W8
20T1
w�s
un
zoso
2031
�
�
2074
�
�
��
2036
2039
2090
2041
2U4'!
2095
2094
2095
ioac
2047
204C
T099
uw
�57
2052
mu
2054
1055
mss
�
232.730
236270
237,88D
zw,a7o
24atao
z45,780
248,4fi0
257.t80
2B3.940
zge.rao
we,s3a
�
ses��u
2seaeo
271.110
274,080
27],090
280,740
283200
288,300
288A4o
z�.�zo
�
302.95U
305,870
308.WA
312,410
316,Ba0
319,300
32'2.90�
328�330
329,910
333.5M10
337.140
340,900
34A,84U
348.400
a5z22u
358.070
959.990
389,9M10
s�.�zo
37t,870
578,040
aeo.no
38M1.330
388,6b0
3sz,sio
a�.t2o
?8,518
28.896
��
zs.sea
�ASz
aopeo
30�884
31 p4
31.888
az,ias
at,sas
�
��
�tt,eoa
��
34.760
�2t1
36.876
98.157
38,837
37.118
a�.eo�
sa.ioe
36.BY3
39.175
39,844
40.17t1
40.703
41,7A2
41,7�
42,34A
42�9�6
43A74
44.057
44.695
45?�7
GG.SZ/
46.435
a�.os�
47,676
98,307
48,948
�,�
Fi0255
50,927
si,ss�
62,281
52,975
sa.sn
sa,�eg
row 5 �s.�.tw 5 z,00a,a�a
1.023.900
1.103,593
7.789,575
1,2$0,268
1,3t4,a86
i.3eiasr
1.451.1OB
,,rls.eoz
1 A75,880
�.no,�ee
i.ei�.su
�ata�os
z.m�zu
z,tso.eza
2215,aot
2�53.287
2�97038
2,331,580
2.371.928
2,N3,1W
2,955,736
z,ees,a3t
�ui.�
z.sea,s�
2,83�187
2.678,8�2
2.728,4U8
2,T)5.028
2,824�692
2,875,428
2.�7281
2,980,224
3.644,348
3.089,BB0
3,146.T97
3,203,992
3,759,079
���
a3es.zra
3�448.458
3,51$OBS
3,579,187
�,e+e93e
$F8,047
3,788,874
a�.ses
3,993,6Ti
4,009$3B
4,487,323
a.�ae.e7s
06-3b3
1,355.848
t.438,559
1,527.515
1,597.198
i.ese.o2�
i.Tm.m
1,801,833
�.a�sa�s
1.9M,718
z,o�o.az�
z.na.a�e
z2ea,aae
z,roo.ee�
z,sxt,7a�
zse�.sm
2,832,917
2,976,130
2,7ts.198
2,782.080
2.808.838
2,852.492
z.ees.osa
z,saesec
z,ass�ozo
9.OGdq82
3.084.518
3.748.386
3,796,940
3,252,584
3.9D'7.518
&3832�4
9/120,?S9
3.478,.i,`41
3,Si8,057
3,598,823
5.660$19
3.724�348
3,789�128
3.855.344
3,823,002
9,892,182
4,082,885
4.736.753
4�Oe,P2
4,264,838
4,3B1,9S3
4p40,9�
4,527.883
4,6P1,870
a,aee�
s s,sso.aao S��.osoSi� s ts2,ses.�n
(a) Tama 4.
@) Tahle 5.
(c)TaMa2
(�Tabiee. �
Sou�tt HNB anaryele.
��
`
�
�
�
�
��
ST. PAUL DOWNTOWN AiRPORT
� .
�.A.A.� Mp6s.
A;srperfs Dis1. O�f,
06-363 �ovo�zoo�
PERIMETER DIKE PROJECT—BENEF[T COST ANAYLSIS
Introduction and Study Purpose
St. Paul Downtown Airport (STP) is located on the Mississippi River and, since 1965; the Aiiport has
been forced to close five fimes due to flooding. Most recendy, STP was closed for.78 days in 2001
due to spring flooding.
The financial impact of these flood-induced closures includes not only the�cost to ciean-up and repair
Airport facilities and pavement, but also includes increased ground iravel costs and increased delay
costs at MSP. When STP is ciosed, Airport patrons are required to use other neazby airports, many of
which are located further from the patron's primary destinaflon. The result is an increase in overall
ground travel distances and costs. Additionaliy, MSP operates with delay costs and any flights that aze
diverted to MSP, because of flooding at STP, would increase this delay.
These flood-related costs could be alleviated with the construction of a dike along the Airport's east
perimeter along the Mississippi Rivex. The purpose of this Benefit Cost Analysis (BCA) is to compaze
the benefits and costs associated with the proposed construction of a dike at STP. The proposed dike
(the Perimeter Dike Project) would protect the airport from all floods that would have an expected
annual occurrence of raore than 1 percent. Potential project benefits include the mirigarion of flood-
related damages and the prevention of added aircraft delay at MSP; whereas project costs include the
projected cost to construct the dike, the estimated annual cost to operate and maintain the dike, and the
estimated cost to periodically re-stabilize the dike.
Role and Objectives of Benefit Cost Analysis
A BCA seeks to determine whether or not a certain output shall be produced and, if so, how best to
produce it. The BCA requires the examinarion of all costs related to the production azitl consumption
of an output, whether the costs aze borne by the producer, the consumer, or a third party. Similarly, the
methods nsed in BCA requitre an examination of ali benefiCS resuiting from the production and
consumption of the output, regardless of who realizes the benefits.
Consistent with the principles of benefit-cost analysis, bene£ts and costs for future yeazs should be
discounted to convert them to present value terms. Benefits and casts are discounted to account for the
fact that a dollar today can be immediately invested to gain real returns, whereas a dollar ten yeazs
from now wili not have had the opportunity to gain returns over that ten year period. For example, at a
6.0 percent annual real rate of return, $1.00 invested in 2000 will be worth $1.79 in 2010. Therefore, a
dollar in 2000 is worth $0.79 more than a dollar in 2010. Based on guidance from FAA, the discount
rate for BCAs for AIP-funded projects is 7.0 percent.
Project Objectives, Aiternatives, and Description
Since,1965, the MAC has explored a number of options to meet its ob}ective—flood prevention at STP
up to the 1 percent flood event in order to provide the region with a reliable reliever airQort—and these
� options include:
i. No investment: no perimeter dike or interior drainage improvements. ` �i
I �
1 FAA, Airport Benefit-Cart Analysis Guidance, December, 1999, page 3. , '
C:1Documenis and Settings�dblackV.oca1 Settiags\Tempoxary Internet Fles\OLKI4Estp bca faa dike plus exc below OHW oct 121A05 revision.dx
Page 1
r e
O6-3b3
2. Construct a new airport configuration with flood protecrion.
3. Provide flood protection around the current airport configuration.
4. Complete closure of STP and demolirion o£ airport facilities.
5. Provide only interior drainage improvements at STP, no flood wall consYruction.
6. Reconstruction of the ai�etd with flood pmtection (protect primary runway).
�
A number of studies have deterntined that option #1 is not acceptabie given the economic impact of the
Airport and its vital role in the MAC system of airports. Parther, construction of a new airport
configurarion (#2} has been deemed too costly and dismprive. Complete closure of STP (#4) wouId
have documented negative impacts on the local economy and on air haffic management at the nearby
auports (to which STP tenants relocate). Interior drainage improvements, without construction of a
flood wall (#5), would result in operational use of the mnways more quickly after a flood event, but
would not prevent the floods themseIves. Reconstruction of the airfield with flood protecuon (#6} was
considered nnfeasible in a 1999 report (HNTB) because it would rec�uire a considerable capital ouflay
while still leaving many areas on the Airport wlnerable to flooding.
The remaining option (#3), the Perimeter Dike Project, would pmtect the enrire A.irport &om floods
having a greater than 1 percent chance of occurring in any given year and pro�ide the region with a
reliable reliever airport. The Peruneter Dike Project (the Pmject) would consist of both permanent and
temporuy dike sections. The permanent dike sections would be comprised o£ sheet pile components �
and eazthen components along the east perimeter of the Airport. The temporary dike sections would
only be deployed prior to an anticipated flood event and would be pIaced across the east ends of each
runway to seal the permanent dike components.
It is anticipated that construction of the dike would increase the stage level of the 2 percent flood event
by an estimated 0.03 feet. As a result, some sort of additionai miugation will be necessary to offset
this anticipated increase in stage level (set it back at zero). Three sub-altematives were considered to
achieve this goal:
a) Compensatory excavation below Ordinary High Water (OHR�,
b) Compensatory excavation above OHW, and
c) Compensatory excavation with mitigation of impacted structures.
These alternatives have been analyzed, and sub-altemative "a" has been chosen as the preferred sub-
alternarive. It is this sub-alternative that has been incladed in the With Pmject case modeled for this
BCA.
BCA Assumptions
Tlus BCA evaluates the benefits and costs of the proposed Perimeter Dike Project and compazes them
to the Without Project alternative. T[ie Without Project case is not intended to be a"do nothing"
course of action in which conditions at the Airport aze held staYic. It is intended to xepresent a
reference point against which both the incremental costs and incremental benefits of the proposed
alternative are measured. The Withoat Project case assumes no dike is built, but that significant
impmvement is made to the interior drainage at STP. For The purpose of Yhis study, the With Project
case assumes that a dike is built, and that significant improvement is made to the interior drainage at,
Z Lssue Resolnlion Conference, Briefing Paper and First Draft Screening Iztter Report, St. Paut Downwwn Airport (Ho[mmt Field) FToad Co!trol
Feasibiliry Study. �
C:\Documents and Settm�ld6lacklC,ocal Settings\Temporuy iatemet Files\OLK14E�stp bca faa dike plus exc below OHW oc[ 12 2005 revisio¢,dac
Page 2
�
�
�
1. •
STP prior to construcrion of the dike. Under the Without Project case, it is assumed that ST`P will
experience 16 days of flood-induced closure due to a 10 percent flood (flood levels having a 10 percent
chance of occurring in any a ven year), 24 days due to a 5 percent flood, 38 days due to a 2 percent
ftood, and 56 days due to a 1 percent flood.
The BCA is based on the following general assumprions:
► The prnposed Project will prevent floods at STP that have a�eater than 1 percent chance of
occumn� in any given year (protect up to and including the 1 percent flood event) and STP will
remain operational duning the 10 percent, 5 percent, 2 percent, and 1 percent floods.
� Growth in activity at the Airport is based on the most reeent FAA Ternunal Area Forecast (TA�
published in January 2005. The TAF growth rate was applied to the Aiiport's CY 2004 operations
levels to generate a forecast of operarions for use in this BCA. It should be noted that the TAF
only extends through 2020; therefore the activity levels beyond 2020 aze extrapolated using the
TAF growth rate.
/ Passenger growth at MSP is based on the High Combination 2 forecast scenario in the LTCP.
/ The project evaluation period is 50 years after Project complefion (2008-2057).
/ All doliaz figures are presented in year 2005 dollars 4
Estimate of Costs
This section discusses the costs associated with the Project; including canstruction costs, re-
stabilizarion costs, and annual operating and maintenance (O&M) cosCs. Costs are presented on a year-
by-year basis in year 2005 dollars over the 50-year evaluation period (2008 — 2057).
As shown in Table 1, the estimated construcUon cost for the Project is $22.4 zniHion, which includes a
20% contingency factor and engineering costs, which are estimated at 30% of total construetion cost.
Construction, and associated costs, is expected to occur evenly over two years. Annual O&M costs
associated with fhe Project are expected to run about $32,836 a year. Recumng costs required after
major flood events is expected to cost approximately $236,000. Because this expense is expected
approximately 18 percent of the Ume, the average annual recurring cost is esrimated at $42,480. When
these costs are combined, the total cost of the dike over the 50 year evaluation period is estimated at
$26.2 million.
Discounted costs are discussed in the smnmary section below.
Estimate of Benefits
A number of benefits would be associated with the construction of the Project and tesulting flood
preventian. For the purpose of this analysis, project benefits were divided into four categories,
including the benefit of:
1) Longer useful life of Airport pavement (major rehabilitafions occur less frequendy)
3 These figures were 18, 28, 49, and 77 days prior to the confirmation that the interior drainage improvements would be
complete prior to constcucfion of the dike. Hydraulic modeling of the drainage improvements revealed estimated
reductions in ciosure days as a result o€the improvements. ,
° Per FAA SCA guidance, constant doliazs in the year of BCA development aze used for these analyses. 1 �"
C:�Documents and Setling\dbiackV_ocal Settings\Temporary intemet Files\OLK14E�stp bca faa dilce plus e�ce beLow OEiW oct 121A05 cevision.doc
Page 3
flb���'��
2) Prevented flood damage from 10%, 5%, 2% and f% floods, �
3) Prevented additional ground travel costs.
4} Prevented additional aircraft delay at MSP
5) Reduced pavement rehabilitation costs (discussed above in the cost section)
These benefits are estimated as incremental benefits—the difference in benefits between the With
Project case and the Without Project case.
Table 2 displays the costs for pavement rehabilitation under both the With Project case and the
Without Project case. These costs are shown separately from those in Table 1 because pavement
rehabilitation will be required under both scenarios; however, rehabilitation is expected to be more
frequent under the Without Project case due to a higher incidence of flooding, and thus an increase in
pavement deteriorauon. 'Fhe fust column in Table 2 presents projected pavement rehabilitarion costs
assuming the dike is built (With Project) wiule the second calumn presents these projected costs under
the Without Project case.
Under the With Project case, pavement rehabilitaffon is expected to take piace every 12 years at a cost
of $4.248 million per rehabilitation for a total of $17.7 million over the evaluation period. When
annualized, these costs are estimated at $354,000 per year. In comparison, pavement rehabilitation is
expected to take place every 10 years under the Without Project case for a total of $21.24 million over
the evaluation period. The difference in pavement rehabilitation costs (incremental benefit) between �
the With Project case and the Without Project case is $3.54 million, or approximately $70,800
annually.
The ne.xt category of benefits, prevented flood damage, is specific to flood events, and represents the
cost savings that result from prevenung damage to, for example, tenant aircraft and Airport pavement.
Table 3 includes the estimated tenant damages from a 10%, 5%, 2%, and 1% floods. As shown, the
severiry of damages increases with the severity of the flood. The incremental increases do not follow a
set pattern, however. Tenants reported four distinct types of damages from the most recent flood event
– relocation, damage, clean-up, and fuellrent/other. Relocation is presumed to be a£ixed cost; when it
is required, it is so regardless of flood duration. The remainder of these damage types aze variable
according to the number of days the Airport is closed. Total damages range from approumately
$1,626,966 for a 10 percent flood to $4.42 million for a 1 percent flood.
These damage estimates were then annualized by dividing the total damage amount for each flood
level by recurrence interval of the flood level. For example, a 5 percent flood is expected to occur -
once every 20 years. Total damages from a 5 percent flood are estimated at $2.1&6 million. These
damages are annualized by dividing $2.186 million by 20 years for an annual average of approximately
$109,300.
The final row in Table 3 presents the average inciemental annual damages from each flood level.
These are calculated in order to avoid doubie counting prevented flood damages. Incremental annual
damages are calculated as follows (using 2% flood as an example): [(Total damages from 2% flood
minus Total damages from 5% fiood)/50 yeazs]. The incremental annual damages in Table 3 are �
shown on a year-by-year basis in Table 4. The last column in Table 4 presents the sum of average �
annual damages from all floods over the 50 year evaluation period. \
The third majorbenefit category is preventable ground travel costs. When flooding at STP forces the`
airpost to close, tenants have to divert to another nearby airport. For the purposes of this study it is
assumed that most of the passengers arriving at STP aze bound for downtown St. Paul. If S'IP is
C:�Dornments and SettingsWblack�incal Setlings\Tempoary Interne[ Files\OL.K14E�ctp 6ca faa dike pins uc below OHW oc[ 12 2005 xevision.doc
Page 4
�
�
06-363
closed, these passengers are likely to divert to the next most logical airport, MSP, which is located
further from downtown St. PauI than is STP. The resuit is an increase in �ound travel distances and
travel rimes whenever traffic is forced to shift to MSP. The proposed dike wili mitigate flooding at the
Airport and will, consequently, reduce the number of flood-induced closures and associated diversions
to nearhy airporE. This translates into reduced travel distance and travel rime and, accordingly, reduced
�ound travel costs for the patrons of STP.
The magnitude of these travel cost benefits is based on the assumprion that 3T`P would be closed for 16
days during each 10 percent flood, 24 days during r each 5 percent flood, 38 days during each 2
percent flood, and 56 days during each 1 percent flood. Additionally, it was assumed that four
passengers would be on each diverted aircraft operation and that they would each encounter an
additional 9 minutes of travel time when forced to fly in or out o£ MSP rather than STP (15 minutes
from MSP to downtown St. Paul versus 6 minutes from STP to downtown). It was also assumed that
each group of diverted passengers would take an automobile to downtown St. Paul and that the auto
must trave18.25 miles from MSP to downtown St. Paul compared to only 2.5 miles from STP to
downtown St. Paul, a difference of 5.75 miles.
Using these assumptions, the foilowing steps were taken to estimate the benefits associated with the
redaction in travel time and distance:
Multiplied projected annual operations at STP by the percentage of days a year that the
Airport would be closed due to a flood event (16/365 in the case of the 10% flood event) to
derive the number of operarions that would be impacted by each flood event. In 2015, for
example, operations at S'I'P aze expected to reach 147,3b0. If this number is multiplied by
(16/365), the product (6,460) is the number of operations that would be impacted by a 10
percent flood event.
2. Mulflplied the number of passengers per flight (4) by extra travel rime (9 minutes), then by
the groduct of the calculation by ($48.60/6fl minutes), where $48.60 is the value per hour of
time for a GA passenger. The resulting equadon is [4*9*($48.6Ql60)] which equals $29.16
per impacted operarion.
3. Multipiied ihe number of additional miles that diverted passengers would be required to
travel (5.75 miles) by the current federal government mileage rate of $0.405 for totai of
$2.33 per diverted operation.
4. Added the ground travel time cost ($2916) and automobile costs ($2.33) to get total travel
cost per operatian of $31.49.
5. Muifiplied the total ground travel cost per operafion ($31.49) by the number of impacted
operations as calculated in Step 1.
6. Calculated the average annual incremental cost for each flood level as described above.
7. Summed the average annual incrementai costs from each flood event to get total average
annual costs.
�
The results of these steps are displayed on a year-by-year basis in Table 5. As shown, these benefits
are expected to total $2.0 million over the 50 year evaluarion period.
��
5 FAA, Economic Y¢lues for EvaZunttort ofFederal Avialion Adminisna6od IR�estment and Xegu1¢tory Decisions.
C_�D�cumeats and Settings\dblackV_ocal Settings\Temporazy Sntemet Fi7es\OLK14bistp bca {aa d'yke plus exc be]ow OHW oct 12 2005 revision.doc
. Page 5
Ob-3b3
The fourth category of benefits relates to aircraft delay at MSP. As mentioned above, it is assumed �
that when STP is closed due to flooding, aircraft that would otherwise use STP instead divert to MSP.
Aircraft at NFSP experience delay even without the addition of flights from STP. When flights from
STP are diverted to MSP, they only add to the congestion and resulting delay at MSP. This added
delay would be prevented (benefit) by the proposed dike because it would protect STP against floods
up to and including 1%a floods and thus, prevent flood-induced closures at STP up to and including the
1% flood level.
The calculation of the prevented delay benefits is displayed in Table 6. The first column in the table
shows pro}ected annuat operations at STP. The next four columns in the table show the eskimated
number of days that STP would be closed due to each flood event. The duration of these closures is
the same as in Table 5(16 days for the 10% flood level etc.).
The fifth column in the table presents the estimated number of diverted operations per day. Unlike the
ground travel cost calculations, which assumed that all operations from STP would divert to NLSP
duting tIood-induced closures at STP, the calculafion of deIay benefits assumes that only one=third of
twin engine aircraft operations and two-thirds of jet aircrat't operations from STP would divert to MSP
during flood-induced closures at STP. It is assumed that the remaining twin engine and jet operations
from STP, as well as all the single engine aircraft operations, would instead divert to other less
congested airports in the region. The accepted forecast for the BCA indicates that approximately 25
percent of aircraft operations at STP are twin eng'me aircraft while another 35 percent are jet aircraft.
I7sing 2015 as an example, the number of aircraft operations that divert to MSP each day was
catculated as follows: [(25% �(1/3)) +(35% *(2/3)) * 147,360], where 147,360 is the projected total �
number of annuaioperations at STP in 2015. The result of this equation is that an esrimated IZS
operations woald divert to MSP daily while STP was closed.
The next two columns in Table 6 are labeled "Daily MSP Operations". The figures in the f�rst column,
labeled "Without Diversion", represent the annual forecast of operarions at MSP divided by 365 � The
next column, labeled "With Diversion" includes (again, using 2015 as an exaznple) the 1,699
operations that are projected at MSP plus the expected number of STP operations (128, as calculated
above) that wiII be required to di�ert to MSP during a STP flood-induced closure for a total of 1,827
operations. The next two columns in the table, labeled "Average Delay per Operation" were taken
from the MSP Capacity Enhancement Plan and represent expected average dalay per operation at MSP
with and without diversions from STP_
The next column displays the cost per operation per minute which includes both the aircraft (fuel, labor
etcJ cost of $33.47 per minute and passengers' (cost per travel minute) delay costs of $33.63 per
minute. This cost per operation per minute figure was developed using FAA figuzes for the value of
passengers' time, and updated MSP fleet mix and load factor projecuons. These data were utilized in
the following formula: (Daily Operations * Delay per Operation * Cost per Operation per Minute).
This calculation estimates the average daily delay cost for both the With Project case and the Without
Project case. The cost difference betcveen the With Project case and the Without Project case
represents the delay costs that would be prevented (benefit} by the Project.
The next step is to multipiy the daily delay cast that would be prevented by tYie Project by the number
of days that flights would be diverted from STP to MSP during each flood event. Again, using 2015
an example, the daily delay benefit of the Project is estimated at $620,285. During a 10 percent flood
6 Confumed by written correspondence with the STP air traffic control tower.
7 T6e operation projections for MSP aze from ffie MAC's Lang-term Compmherzsive Plan (LTC�, .`&gh Combination 2 PorecasG
� ��
C:�Documents and SetlingsWblack�Locai Settings\Tempoxary Intcmet Files\OLKI4Estp bca faa dike pius exc below OHW � 12 2005 cevisiun.doc
Rage 6
�
�
�
��
event it is expected that flights will divert from STP to MSP for approximately 16 days so 16 is
muitiplied by $620,285 to derive the delay cost per 10 percent flood event that wouid be prevented by
the Pro}ect. Ttus calculation is done for each flood event and then these costs are converted to average
annual incremental costs as described above. Finally, the average annual incrementai cost for each
flood event is suimned in the last column of the table to anive at the total average annual delay cost
that would be prevented by the Project (total delay benefit). �
Table 7 presents a summary of the benefits (prior to discounring) that would be associated with the
Project. As shown, benefits from prevented flood damages are expected to total $15.4 million over the
evaluarion period. As mentioned above, the Project would protect 5TP against floods up to and
including the 1% flood and, thus, prevent flood-induced closures at 3TP up to this level. As a result,
the proposed dike would prevent the additional ground travel time that passengers incur when they are
forced to travel to NISP during a flood-induced closure at STP. As shown in Table 7, the esfimated
benefit of prevenfing trris addirional ground travel time is $2.0 million over the 50 year evaluation
period. The presence of the dike will extend the life of Airport pavement, thereby reducing the average
annual cost of pavement rehabilitation. This benefit is expected to total $3.54 million during the
evaluation period. Additionally, because the Project would ptevent flood-induced closures at STP,
STP flights would no longer have to divert to MSP during floods. This will prevent the additional
aircraft delay at MSP that is imposed by STP flights when they are forced to fly in and out of MSP due
to flooding at STP. Over the evalnation period the prevention of this addirional aircraft delay is
estimated at $132.1 million.
Summary
Table 8 summatizes the annual incremental benefits and costs associated with the Project during the
2008 - 2057 evaluation period. These costs and benefits are displayed before and after being
discounted nsing a discount rate of 7.0 percent. Total undiscounted benefits for the Project aze
estimated at $153.0 million, compared to $26.2 million in undiscounted costs. After discounfing,
benefits are esdmated to be $27,5 miliion, compared to $21.2 million in costs. Because benefits are
expected to occur further into the future than costs,.benefits are discounted more heavily than costs.
The resulting benefit-cost ratio is 130.
��
`
C:�Documents and Se[tings\db]ack�Local Se[tings\Temporary Sntemet Filu\OLK14E�stp bca faa dike plus exc below OHW oct 12 2005 revision.doc
Page 7
Table 1
Estimated ConstruMbn, O&M, and Ra-Sta6(ization Costs
20Q5 Dollars �
az,aao
42,480
42,480
42,480
42,-080
42,480
42,480
42,480
42,480
az�
42.480
42,480
42,480
42,480
42.480
42,480
42,480
42.480
��
42�480
azasa
42,480
42,480
42,480
42,480
42,480
42.480
42,480
42,480
42,480
42,450
42,480
42,49Q
42,480
42,480
42,480
42,490
42,480
42,480
42.480
42,480
42,480
42,480
42.480
42,480
42,480
42.480
42,480
42,480
42.480
Anrtua7
Construction O&M Recuvri�g TWaI
Year Cosis (al Cost (b} Costs (c) Costs
2006
2007
�
2009
2010
2017
2012
2073
2074
2075
2076
zon
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
Z034
2035
2036
2037
2(138
2039
2040
2041
2042
2043
zoaa
2045
2046
2047
2048
2049
2050
2057
2052
2053
205G
205.5
2056
2057
ST. PAUL DOWNTOWN AIRPORT BENEFIT-COST ANALYSIS
PERlMETER D1KE PROJECT
$
$
s
$
$
$
$
$
$
$
$
S
$
$
$
$
S
$
$
$
$
$
S
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
�
$
11,200,000
17,200,000
s
$
$
S
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
s
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
S
$
az,a3s
32,936
32,836
32,936
32,836
32,836
32,836
32,836
32,936
�z,a�s
32,836
32,836
32.836
32,836
32,836
32,836
32,636
32�H36
32,836
32,836
�z,s3s
32,836
3Z,@36
32,836
32.836
32.836
32,836
32,836
32,836
32,836
32,836
32,836
32,836
32.836
32.836
32,836
32,8:i6
32,836
32,836
32.836
32,&36
32,836
32,836
32,836
32,836
32,836
32,836
82,836
�,a3s
3Z,836
raai $ rz,aoo,000 S �,sd�,soo s
Ob-3��
41,200,000
i 1,200,000
75,376
75,3� 6
75,316
75,316
75,316
75,316
75,316
75,316
75,316
75,376
75,376
75,316
75,316
75,316
75,316
75,316
75,316
75,318
75,316
75,316
75,318
75,316
75,316
75,37&
75,376
75,316
75,316
75,376
75,376
75,376
75,316
75,3� 6
75,376
75,316
75,376
75,316
75,316
75,316
75,316
75,316
75,316
75,316
75,316
75,3Y6
75,3Y 6
75,3t 6
75,316
75,316
75,316
75,316
z.�za.aao � zs.�ss.aoo
a) InGU�es a?A % con8ngency faMOr arltl associate engineenng costs esUmat at 30 h Construchon
cost3).
@1 HNTB Malysis '
(c) Estimated fo cost appropmatley 23&000 per event, and includes some 2piacement of riprap and othei
work to re-stabilize the dke. Events raquiring this expense are expected at a probability of 0.78.
�
�
���
�
Source: HMBanalysis. -
�
�
Tabie 2
ST. PAUL DOWNTOWN AIRPORT BENEFIT-COST ANALYSIS
PERIMETER DIKE PROJECT
Estimated Pavement Rehabilitation Benefits
2005 Doliars
�
�
PavemeM Pavement
Rehabilitation Rehabilrtation Average
Conyyith � Cost Without Annual
� Year Project(a) Proiect(b) Benefit _
Average cost of pavement reha6ili[ation (per occurtence) $ 4,248,000
Fiehabilitation once every Reha6ilitation once every
�2years t0years
pppg $ 354,000 $ 424,800 $ 7�,600
2009i $ 354,000 $ 424,800 $ 70,800
2010 $ 354,000 $ 424,800 $ 70,600
2011 $ 354.D�0 $ 424.869 $ 7�,8�0
2012 $ 354,000 $ 424,800 $ 70,800
2013 $ 354,000 $ 424.800 $ 70,80Q
zota S asa,000 S aza,soo S �o,aoo
2015 $ 354,000 $ 424.800 $ 70,800
2Q76 $ 354,000 $ 424,800 $ 70.600
2077 $ 354,000 $ 424.600 $ � 70,800
2018 $ 354,00� $ 424,800 $ 70,800
2019 $ 354,�0 $ 424.800 $ 70,800
zozo S 35a,oao 5 aza,soo s �o,soo
2027 $ 354,000 $ 424.600 $ 70.800
2022 $ 354,000 $ 424,800 $ 70,800
2023 $ 354,000 $ 424,800 $ 70,600
2024 $ 354,000 $ 424,800 $ 70,800
2025 $ 354,000 $ 424,800 $ 70,600
2026 $ 354,000 $ 424,800 $ 70,800
2027 $ 354,000 $ 424,8�0 $ 70,800
yppg $ 354,000 $ 424,SOQ $ 70,800
2029 $ 354,000 $ 424,600 $ 70,800
2030 $ 354,000 $ 424,800 $ 70,600
pp37 $ 354,000 . $ 424,800 $ 70,800
2032 $ 354,000 $ 424,800 $ 70,800
2033 $ 354,000 $ 424,840 $ �70,800
2034 $ 354,000 $ 424.800 $ 70,800
� 2035 $ 354,000 $ 424,600 $ 70,800
20;i6 $ 354,000 $ 424,800 $ 70,800
2037. $ 354,000 $ 424,800 $ 70.800
2038 $ 354.000 $ 424,BW $ 70,800
2039 $ 354,0�0 $ 424,800 $ 70,800
Z �� $ 35q,ppp $ 424,600 $ 70.800
2041 $ 3`'4,000 $ 424,800 $ 70,80Q
Zpq2 $ 354,V00 $ 424.800 $ 70,800
2043 $ 354,000 $ 424,800 $ 70,800
2044 $ 354�000 $ 424,800 $ 70,8�0
2pq,y $ 3gq�000 $ 424,600 $ 70.800
' 2046 $ 354,000 $ 424.BOD $ 70,800
2047 $ 354,000 $ 424,800 $ 70,800
2 � $ 3,5q.ppp $ . 424,8D0 $ 70.800
2049 $ 354,000 $ 424,600 $ 70,800
2050 $ 354,000 $ 424,800 $ 70,800
ppg� $ 354,000 $ 424,800 $ 70,800
2052 $ 354,000 $ 424,800 $ 70,800
2(153 $ 354,000 $ 424,800 $ 70,800
2osa S 3sa,aoa S aza,aoo $ �o,soo
z � g �.� $ 424,8U0 s �o.soo
2056 $ 354,000 $ 424,800 $ 70,800
2057 $ 354,000 $ 424,800 $ 70,800
Total $ 77,740,000 $ 27,240,000 $ 3,540,000
(a) Assumes that with Project, pavement rehabilitation would 6e required every 12 years.
(b) Assumes ihat without Project, pavement rehabilitation would be required every 10 years.
(c) Difference (incrementai benefit) beiween W I17i and WITHOUT Project altemative.
Source: HNTB analysis.
06-3�,3
\` ��
l
Table 3
�6-3�:�
�J
ST. PAUL DOWNTOWN AIRPORT BENEFIT-COST ANALYSIS�
PER{METER DIKE PROJECT k
Estimafed Damages irom 10%, 5%, 2% a�d 1%Floods
2005 Dollars �
Tenarrtfleaseholder Flood Ftood Flood Flaod
3M
National Guard
St. Paul Flight Center
MAC
Regent Aviation
Horton Hangar
MN Jet
Hubbard Itangar
Holman 12
Wings
720 Bayfield
740 Bayfietd
FAA (Tower)
Aviation MaiMenance
CAP
Tofial
Averege Annual Damage (b)
incremental Annuai Damage (c)
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
608,543
95,72Q
213 ,zos
t72,295
282,696
16,592
117,654
5,482
19,197
49,730
369
78
33,186
11,207
508
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
1,626,966 $
162,697 $
t62,697 $
778,369
127,447
326,563
232,066
424,044
16,592
141,513
6,841
19,578
69,525
553
1i6
33,186
14,507
704
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
2,186,003 $
1Q9,300 $
27,952 $
1,075,565
182,969
507,555
336,665
671,403
76,592
184,365
9,218
20,243
104,166
S76
184
33,186
20,280
1,047
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
3,164,318 $
63,286 $
19,566 $
1,457,674
254,354
747,950
477,149
989,436
16,592
238,947
12,275
21,099
148,705
1,291
272
33,186
27,703
1,489
4,422,152
44,222
12,578
�
(a) Tenant input, including relocation and damage costs. To estimate damages for ditterent Bood Ievels, relocation costs were
e>cpected to be constant for any flood, while other costs were estimated to be proportional to the number of days STP was closed.
(b) Total damage divided by recurrance interval.
(c) Incremental damages equal total damage finm a flood less the total damage from the previous (more frequent) flood divided
by the flood recurrance interval. For e�cample, the incremental annual damage of a 2 perceM flood is the total damage of the 2�
percent flood less the total-damage of the 5 percent flood divided by 50 years, or (2% damages-5% flood damages)/50).
Source: Surveys of AirpoR Tenants and HNTB analysis.
� � �
\ �
��m���
l_J
�
�
Tahle 4
ST. PAUL DOWNTOWN AIFPORT BENEFIT-COST ANAlY51S
PERIMETEA D{KE PROJECT
Averege Mnuai Benefit of Prevented Flood Damage from 70%, 5%, 2%, and 7% Floods
2005 Ooilars
Averege Annuaf fncrementat incrementai incremenia! Total Average
pamages Moual Damages Annual �amages Annual Oarnages Annuai Oamages
�p perecnt 5 Percent 2 Percent � Percent All
Year Flood (a) Flood (b) Flood (b) Flood {b) �oa� (�1 -
2U04 (� .� f62.697 $ 27,952
2008
2009
201U
2011
2072
20'13
2074
2015
2016
2617
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
202B
?A29
2030
2031
2032
2033
2034
2035
2035
2037
2038
2039
2040
2041
2042
?A43
2044
2045
2U46
2047
2048
2049
2050
2651
2052
2053
2054
2055
2056
2057
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
19,566
20,440
20,660
20.890
21,120
21.356
21,580
21,820
22,060
22,3W
22�550
22.�90
23,040
23.3��
23,550
23,810
24,070
24,330
24,600
24,870
25.140
25,420
25,700
25,950
26,270
26,550
26,840
27,140
27,44a
27.740
28,040
28,350
28.66U
28,970
29,290
29,610
29,940
30,270
30,600
34,930
31270
31,620
31,960
32,310
32,670
33,020
33,390
33,75�
34.120
34.500
34,880
1,357,500
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
$
$
$
12,578
13,t40
73,280
13,430
13,580
13,720
13,880
14,030
14,180
t4,340
14,490
14,650
14,810
14,980
15,140
15,310
15,470
is,sao
15,820
15,990
16,160
16,340
16,520
16,700
t6,880
17,070
17260
77.450
t7,640
17,830
18,030
18220
18,420
18,630
18.830
19,040
1925Q
79,460
19,670
19,8�
20,100
2Q320
2D,550
w,no
21,000
21,230
25,460
27,700
21,940
22,780
22,420
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
222,793
232,730
235270
237,860
240,470
243,700
245,760
248.460
251.t60
253,940
256,730
259.530
262.380
265,270
268.180
271.110
274.08a
zn,oso
280.140
283200
286,300
289,440
292,620
295,830
299,070
302.350
305,670
309,020
312,410
375,830
319,300
322,800
326,330
329,970
333,54D
337.t90
340,900
344,640
348,400
352220
358,070
358�990
363,940
367,920
371,970
376.040
380.170
384,330
388,550
392,870
397,t20
S6S,840 $ 15,389.750
(a) Average annual costs from Table 3. Assumed to increase at same rate as aircraft operations ���
(b) incrementaY annual costs Rom Table 3. Assumed ta increase at same rate as aiYCraft operations �
(c) Sum of average annual antl incremental annual flood damage costs.
(d} Potential benefit ,
Source: HNTB anatysis.
Total
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
169,950
171,810
173,700
775,600
177,530
179,470
181,440
183,430
1 S5,4A0
t87,480
189,530
791,610
193,710
195,840
197,980
200,750
202,350
204,570
206,810
209,0$0
211,370
213,690
216,030
218.400
220,800
223220
225,660
225,140
23�,640
233,170
235,730
238,310
240,92Q
243,570
Z46,240
248,940
251,670
254,420
257270
260.030
262,890
265.770
268,680
271.630
274,610
zn,szo
280,660
283,740
286,850
290.000
1t,238,090
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$,
$
$
$
$
$
$
$
$
$
$
$
$
�
$
$
$
�
$
$
$
$
$
$
$
$
$
$
29,200
29.52U
29.840
30,170
3Q500
3Q,830
31,170
31,570
31,860
32Q70
32,560
32,920
33,280
33,650
34,0�0
34,390
34,760
35,150
35,530
35.920
36,3tQ
36.710
37,720
37,520
37,930
38,350
38,770
39,190
39,620
40,060
40,500
40,940
41,390
41,850
42,300
42.770
43,240
43.710
A4,�90
44,670
45,160
45,660
46,760
46,670
47,180
47,70Q
48,220
48,750
49,280
49,820
1,93q720
M
6
w
Y /�
YV
�a
ma
° ��
a $o
� �w
a�
z�
¢
za
8
<
w
3
� !
E
Y
g
0
�
��
<g
F�
i
m
6
c
<
��� � ; -
x � �
�$ "dr,°,� �`�'.6m$�m��8��.�Y���Ra�sd�`�'�Q�m WG� m
mi�. '$ _ _ _' 'qee:eQece.7Qe^&e<:o _ _ �
n�r«�.°�Rm��n������;��m'�A�,.°,�, e�eee3e e
» »..,» «,.»»» «,»» �»» �,»»» a �» «,»» e
»»»»»»»�«»»»»»»«»»»» »
���
»»» «,�»»«»»g»�.�»»»»».»»»»»»»»»»a»»w»».»»»»»»»»« , »»»»»»
m�m��m�;$mm��m�;W�°$a<�Qe:
ww» w w m�nw�n»w»..«.w.e....�n». , �«.««.n.o«.�wawwwww«www»«.a»awww�n«.w
�m���mma�ws$ma���smaa° �����s�mmo����e;��W��sss_r�
:ea.Q.���-����� ,��e�-mmmmeme�mmm���w.�����
»»»»»»»»»»�»»«»»»�»».»»»»»»a»»»»»»�»»»»� »
���e�m�°a^°sg���e�s:m�a����ma$��a"_e��"ss�� °
�nS�vemo _ ' ' ' -
���mmmRR.°VR��N��F.InN�t7�NSan�HNffinC�.^.�rNn�N°e°,�,�,����mSA�m $
»»»w»»»V.»«,�„»»6,»�„».,»»»«».,»y.»»».,«,».,»»»»».,.»».,.,«»»»»»« »
mm���a�m msMaa�e wamx�mm��e�°�� ma"m°a"a��ss�mm��°�
am�mmmgrr�°�����sm���m�mmgmWmmamm�es�oso���%�s
»�n x«.w�nm..�n«..wr«.»us«.»«m �nas..» x»..w««.n«xww�n�n.saa..s.s»».s».�«a�n
m m��m m�m�3� � �m ' - o - -��e °
"` �o�B ��$°�d��.m aRo ag$n
ea"e.<a�o��mm"��n��nw��e�m�eaae�mm��R���.°����am�i
wNqw�sN�sNHmHHNUiN»WNH»MMNHN�aMNNMNNyNNNN
� m�3���a�ee��� �m�= ���omss;p���oo��rs���a��m�
��r�������,�,m�,�.���� ;�m ;^��� ;se<e�e�`s"a:ee::�r.eeem�
N»NMM»M»NpNUibNNwNpHNNUiNNbMNwHN�nHNxiHpxiNN
3 J:Wee°e8�2:°��ovo���mm�emr��S�q�e�,��m�S�$e�meSe«�
mm��m�s��$���n�����H`a�"annrr$r��«�$r��s$AAm�����=��
�»».,,» «,»»» «,»K» �»» «,»»»»»»»»»»»«,» «,» �»»»»»»»»»»»»»» «,»»
aBeaaee<¢ee:.;<;�Qae�ecee<eeq�a�ep
mmmwnana � a m t �n w anawnao»anmm�e�nmanmwwnmmm'n�ueana`e'mme`>n.i`m'na`o'ne'�'a`m`n
�.,.»��»»H»�.»»�,�,»»»»»»»�»�»». .»w»»..,»»»»,�H».,a».»»»«.
m�a�����;�ma����m����;���������q����;��m��mm
cVNttnaNNOiNNWNNwciNNwnldWVVWwryNNCiNCiry'NNNNnNNOiNN
HNxiNNqwNeiMNNU�MNb�sb»bNNHNUNHNWNNM»»MN
m0mmm0mmmmmmmmmmmmmmmmmpommbmmabmm�ommmoo
�n� n�R�� ���rR� r�r� �r� ���� r�Rr an�n
uiNNNHNmHNNHN�nNNNwNMwaN�nHwxNH�nwHwNN
I�enmw�anmmdoe�me�ne�mmmmmmauu� uu�wmm $m� ae
��msrs�ss���se�_e�9.��am�� �
�n��r�anaa�nr��n�ar«�w��n«�r�m° :;.�,���a :9���:��'�����
m��e����a^����3s�����a�
���-����.������-�.�.�e��..�.-.��'��`�'�mNNNt^VNNNSYa�v�YNC�S�aS�aa��i W �Yt
WYVdYa�oNb�n r6 m0nnnnn 0m om
�me��eem�m���§��������s���amF�m�a��"s_��eF��:��$me's�
- mWmwm �oe000vo�=��r__°__��������s�ss���eeemmmmm
�a$����sb���g�.��n�e$§�mmo��<����$o�°$e��m°��e��a"s"_a
usdm.umrom
�e�"' m�� �Bo��n��emam�e�� m8��3m��m9�6 m
��r_$B=__�_������m� « ��mY�m!_.-m�SR�n..�wN°3r`.�3�n.°dnn��N
.�4R.S.°�.Rr.........�..�°.�$.�°�..`�.iw.�.&N°.�..�9.�3°rawRnRa°�.p°V.a3n�nR&8g8o�r�.�°.�$S�w �
d
�
�
�
0
�
>
E
a
�
§
a
�
i
S
�
�
E
3
E
e
�
E
�
�
�
b
$
a
a
a
f
E
e
�
�
�
`s
�
4
s
s
�
E
� � s
E o
$ N e
9 a �
�
� c��
am
m��
� ��m�
��a�Y�
m 'aE�
� oa
Sq��2",
�so>mm
�m
mE���'m
E m ��o
��g�E
�� ^Q U tiB
E m..�.ES_.
�
�
✓ �
�J
Ob-363
���� 000a000°oao°oov0000a°eoa00000a000aoaaaoov000e
�������e�mm����mm�����e�����������������e�����
HN4INNHHHNHHHNHNHWHWNwHMMHKHwWbaGV1WHWMHHHWwKHNHM»NwN
VN�D0010�N4NbncOOrWCWNWONdNI�m�-t�v�mONv
_.-_���������°�r��C��
mn mo.wmnoenevm000000eoc000000e00000eaooaoQe0000000
rnmmmmmaadcd.-���.-�.-���.=��-:��.:
�
i
�
�G
�' w
wa
ws
ma
w
a �a
~ QW
a�
3�
ow
i6
O
0
a
N
�
a
�
�
�
9 N
c��
° �S
i��
0
a`
6
�n o`Q
m�mm
a
�
s
�
n
7 i
�B
a�
3 m
Q 0
�c
�D
S�a
�
m��M1mmm°-��x�000voaove�0000vooeva00000vo�oe00000e
e � e ������������������������������������������
_>��__.._..___.__..__�..___..____�________.._..__________
,�a_�,h��,o_m�,��o�e.�ma�
r���«��������rss�ss���������e���cm�m�$�w����n�===�
�$u`°i�n�a�����wu`4���m�e$Rh�$�����e�„�eme�,�n�n�em�ew�n
nmmmmna�na�mm�eammn�mm�mnna�n�mmmma�mmmmwcic�ma�a�mmovma�hne
m w m m mmmmmmmmmmmmmmmmw
NN(SNNNNa
8
s
N
s
H
m
V399�
mN
ab
$$`d$c
�a�a�
o��o�
mSd�'a�
�����
�a�z�
l mmm�u^m�nmamm�ummmmmmmm�arommm'am�nmmmumvmmammvu�nN�om�omm
�
_.�. ,.��m���e�,�n�,�,�,
c� -��° �.-���.-�.ne..�.�"'-���m'�i^me`!�al�.oa_a�m $r�coi�m_vrowmm.�iea.�ie
� ' _ _ _ .-_�_W�iaa�.w.'��'a`�Y`�
4Q
��oso" s
r���r�r����n���r���r�r�r�r�n���
Y
J �
\
. �
N
� Z
Q
0
Uti
= �
wa
w¢
m °-
° s ��
t. ¢ ¢
�w
aw
z
oQ
3
�
6
F
M
V
a
�
S
`o
$
..
9`q�
E n `oo�
a`$"
m
6 '
>
6
�
�� .R ._. ��, �-. '��.
m<ro. o.oae<rmmom�harnrommwm�amo�. m.ncm� r<m�m.em ^
��i�rNNNN[�'/_NONA��00b00vON�c�iNCS���OVNCQ�mfSrNmN�c�'I_0 b
--m�°mH.".��°�mme�em���..°e.'r�ee��m^mmooQ.m°.�_�m�d�^e�mmwooffi �
�_��..�������aa«a.v.a.�.w a�awrvna.vn.�nrae�ui.v.ocinm�acio:.�viv<v �
w«awmmwwm�»wwwae�ww.nww�n«�ww.aav.w»wnwx�wwww.nwwwwuw�»»we�e+ww .+
"'n"'m�i.°a"' $
m�.$v�oNmN�emmnomrm�num�mivno n
1�tpm0 N�d��nWO m V
����������- ..� � N-
NbitliMtlIMMNNtlie9MMMHMMHMMMHWMHNNNGiNtl1Ht9N(9H(9(9MHNHf9✓iH�fB`Bi9f9 N
��mObNnOmNma�'
cOqbYma�'1_O�f10�0NN�N�O� 4 W mt?000tu1�W�(�! �
�VwW01�mW�mNYNbONNr�mO�m�Ob�naC��OSHyr�O«0N�0nMIN��y � <
��� �� NlV aVNNw[mVNC91e�INa�a�oW�t�iW�Wmna�Oa�n�<V<eCYOCY �
I9MM�9MbfHWNKMWMWHHMHHf9Mf9WNMMHNH�dHWMHHMM1ANtl1HWHf9NMWNNN N
��0���
v<aVOH��A���a1Y�NW�n�at��iN$rW�OWb[�Wya�NN0lmo�c717NTcV�0<OP1� I�va0 m
�-��NNt�ttNNNI
Hf9HHNNf9HNNMbMHHHNHHNtqWNHNHHNHHNNNHMVfHf9NH19HNHMNfHWMN N
�$��m��$���m��a��<�������°��mms��"a°m����m��.as�q�<�
$��`.Fmm��oo�^a'�&"�<$�
� � � ��.� ����� � �NNNNNtVNtVNNNNNNNtVd
ViMHH1Y1HH�9(96fMMNN4lNHYlN
e�'�'�'_<�m
W �cJp q V 00 in(JNUiNO W O V ��-mbNYCIOm��On�aVi�l�N
e ��O�WSonnONmN�YN�00 m T�m0mp� 0 S�m?OYO C � i �m O N mO � S �V ObNOY �N� O
wc�Nam.��n"�3�mme«v�°ae"�S3m$"�ie^mme.°u`i'�mffimm^m°�d°ri nnn^rn�m"S$mm°{'m"d�
« . ww« .v i «.www»w.9.nw«.«�wwd.�ex�«.nwm.nw«.mwwmww.au�«�www u. w ww«+.g.n«+d.« �
w.n»�»e�Fn�»wm.rswu��n»«�.n«+«i wm».nw»»�nw wwww.a n�»v�»w.nwmwwm�»�wenvi«a�n
o�°o�e
ammmo. vmnqcmwm��caw<m'v
'�m�'»ro<.��i�NOCiemvnmmro i.i�mvm<oiat naemv�°iovi°no�mm�<�cim�.ric5
m
wH»�nraesuswasuf westnN N�nNaf /NrRxlrnnbt»�9ie�bm�nro�nvsx�wMwtnWwMdiHw
wemn�"anw�embm�v
a�ayra.�rmn�nm�r
p m.��im oa+ a n
�Se3"�en�om�n�"�m�$'m"d$
H(96fHM•9(9b(9bbbfBNHWtl1MMH(9HNH9lNHHN(qHNNNHNHNKHHMHVf WNf9NbIN
;
s
HNWf9�MHMVlUSM�MMM�4NHf9NNMHHMf
�mmN $ Nl � O01 � c1 � -T � ar � )Wm YPYC<Y<@OC<CYYY I � I � I � AI �� I � hhl � l � hnl � f � l � I � r
m m�,m����,n� < e< �e::ee��«�"�<�Q«
er
nrmm �wmoo`.-w^o.wn.owlfwnwmmn'.n.�^^` ., '. _
b1tlYYf NHNMHN�9I9HN(9HMe9HN(9NHHMNHNNHHNHNN
pO00000000000000�D0000000�0000G0000 0000000�000000
Nb00�OmmN�Nb�lb00m@m000�Nm0
vi9YN65ef9YMNl�MNNM69HHNfRMHHMf9HH(9fB•B(9MNMf (MN MNNHMtlfHWNHViNNH(9f9N
� o�� w O A � b O O �� N N� O O O O O O O O O O � O�C� O C a O P O�� O H O O�� G n m� p b
dp pdRNryddf�'Ia�VqddqNtlWdNqNN[addpdpppqdN Ht�`�HNRNqdN
V
�
� � � -
�
06-36�
Ta61e 7
ST. PAUL OOWNTOWN AIRPORT 6ENEFl7-COST ANALYSIS
PERIMETER DIKE PR0.IECT
Summary of Und(seaunted Benefi4
z005 oollars
�
�
Preven�d Heduced Preventd
Preven4ed Atltlitionai Pavemmt Additiova{
Flootl GrowdTravel Rehab AircraftOelay
Y az Dam g(a) Costs @) Custs (c) at MSP (tl) Total
2008
2004
2010
2077
2012
7A13
2074
zois
2076
zm�
2018
?A79
2020
2027
207L
2023
2024
2025
2028
2027
2U26
2029
2030
2037
2032
2033
zosa
2035
2038
2037
203a
2039
2040
2041
2042
zoaa
zoaa
2045
2046
204T
2048
2049
2050
?A51
2052
2053
2050
zoss
21156
2057
S
$
5
5
$
S
$
S
S
5
S
$
$
S
$
$
$
5
$
$
$
$
$
$
$
$
s
$
$
$
s
$
$
$
$
S
5
5
$
$
$
$
$
$
$
$
$
8
5
$
232.730
235,270
237,860
240,470
243.700
245,760
248.460
zst,iao
253.960
us,r3o
759.530
2G2.380
265270
288.tao
277.110
274,030
277.080
280,140
7B3.200
286,3W
789.440
292,620
295,830
299,070
302,350
305,670
aas,ozo
372,410
3t5,830
319,300
szz,eoo
326,330
�,970
333,540
33�,t90
sao,soo
aaa,sao
348,400
352.220
356,070
359,990
363,940
367.920
377.970
376,040
360.t70
3H4,330
asa,sso
392.810
397.120
$
5
$
5
$
$
S
S
$
$
S
$
8
S
S
5
$
$
S
$
$
$
$
$
$
$
s
S
$
$
$
$
$
$
S
$
S
8
$
$
$
$
S
$
$
$
$
S
$
$
28.578
18.&96
�280
29,fi68
30.062
30.4G0
30.866
a,z�a
3t,688
32.109
sz,s3s
32.9fi6
33.4Q3
a3,sas
347-�
34,750
a5211
35,678 �
3s�tst
36,63�
37,176
37.609
38.108
38,613
39.t25
�,fi�
ao.na
40,703
41242
41.789
az,aaa
42,905
43,474
44,051
aa.635
45227
45.827
46,435
4�,051
47,675
48,307
48.948
49.597
50255
50,927
51597
52,28Y
s2.s75
53,677
54.3&9
Tota1 S 15,389,t50 $ 2.004.878
5
$
5
S
$
S
5
b
5
$
s
$
5
$
$
$
$
$
S
$
$
$
S
$
$
$
S
S
$
$
$
$
$
$
S
$
$
S
$
$
$
$
$
5
S
$
$
$
$
$
]0.800
70,800
70.800
70,800
70.800
70.800
]O,SW
70.600
70,800
70,800
�o,eoo
70.800
70,800
70.800
70,800
70.800
70,800
70.600
7o.floo
70,800
70,800
70,800
70,800
7Q800
70.800
7Q800
�o,soo
7o,aoo
70,800
70,800
70.600
70.800
70.600
70,800
70,800
70.800
]0,800
70.600
]0,800
70,800
70,800
70.800
70.800
70.800
�o,eoo
70,800
70,800
70,800
70.800
70,800
S 1.023.800
5 1.103,593
5 7.189575
$ 1,250,258
$ 7.314.064
5 7.387.757
$ 1,457.709
$ 1.525.902
$ 1,615,690
$ 7.710.788
S t,SnS7a
$ 7.918203
$ 2.037214
$ 2.750.925
$ 2,215.304
$ 2.?53287
$ 2,?92.039
$ 2.331.580
$ 2.377,924
$ 2.473,707
S 2.955,135
$ 2,498.036
$ 2.541.827
$ 2,586,537
$ 2.6ffi.76] -
§ 2.678.802
$ 2.726,4-06
5 z.ns.aza
$ 2,824.692
$ 2.875.426
$ . 2.92728t
$ 2.980.224
$ 3,034,346
$. 3,069,6fi0
$ 3,146,79�
$ 3,203,992
$ 3283,0�9
§ 3,323,493
$ 3,385,2�4
$ 3.448.458
$ 3,513,0&5
$ 3,579.797
$ 3,646,836
$ 3.716,047
S a7ss.s7a
$ 3,859,368
$ 3.933.571
$ 4.009539
g� 4.�87.323
$ 4,T66,976 �
3
5
S
$
S
$
$
S
S
S
5
$
$
$
$
$
$
5
$
$
$
$
$
$
$
$
$
s
$
$
$
S
$
$
$
$
4
S
$
$
$
5
$
S
$
S
$
$
S
5
1,355,848
1,438,559
1,527,515
f.591.796
t.sse.ozs
1.T28.7T7 �
t.801.833
1,879,155
,,s�ztie
2.O�o.a27
z,na.a7a
2,284.349
2,400,687
2,523,751
2,591,570
2.632.917
2.fi75.130
2,71H,798
2,76�080
2,806,838
2.eszasz
2,899,063
2,946,565
2,995,020
3,044,462
3,096,978
3,748,398
3.798.940
3,252,564
3,30],376
3,363,204
3.420.259
3,478,537
3,538,051
3,598,823
3,660,979
s,rza.sas
3.789,128
3,855,344
3,923,0�2
3,992,182
4,062,ea5
4,735.753
4,2Q9,072
4,284.636
a.aei.sa�
4,440,9ffi
4.527.863
a,soa,sto
4,689287
$ 3,540,000 S 132,050,517 $ 152,964,637
@) Table 5.
(c) Table 2 .
(d)Table e.
Sourca: HNTB anatysis.
��
�
P �` 2+ _
Tabie 8
ST. PAUL �OWNTOWN AIRPOflT BENEFIT-COST ANALYSIS
PERIMETER DIKE PROJECT
Comparison of Undiscounted and Discounted Costs and Benefits
200.5 Doilars
Ob-363
Undisrnunted Discaunfed (a)
Year Casts (6) 6ene£ts (e) Costs Benefits
Z006
2007
2(106
2009
26�0
20t1
2012
21113
2014
2015
2016
2017
2018
2019
2020
2027
2071
2023
2024
20?S
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2�36
2037
TA36
2039
2040
2047
2042
2043
2044
2045
2046
2047
2048
2049
2f150
Z051
2(I52
2053
2054
2055
2056
2057
$ 71,200,Ofl0
$ 17,Z170,000
$ 75,316
$ 75,316
$ 75,376
$ 75,316
$ 75,316
$ 75,316
$ 75,376
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,376
$ 75,316
$ 75,316
$ 75,316
$ 75,376
$ 75,316
$ 75,316
$ 75,376
$ 75,376
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316 •
$ 75,316
$ 75,376
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,376
$ 75,316
$ 75,316
$ 75,316
$ 75,376
$ 75,316
$ 75,316
$ 75,376
$ 75,316
$ 75,376
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,316
$ 75,376
$ 75,316
Total $ 26,165.800
Beneftt-COSt Ratio (�
$ '
$ '
$ 1,355,848
$ 7,438,559
$ 1,527,575
$ . 1,591,196
$ 1.658.025
s � aze.m
$ 1,801,833
$ 1,879.155
$ 1,972.178
$ 2,070,427
$ 2,174,378
s z2aa.3as
$ 2,400,687
$ 2,523,751
$ 2,59t,510
$ zsa�z,sn
$ 2.675.130
S z��a,isa
$ 2,762,080
$ 2,606,638
$ 2,852,492
$ 2.899.063
$ 2,94G,565
$ 2,995,020
$ 3,044,462
$ 3,094,916
$ 3,146,396
$ 3.198,940
$ 3252,564
$ 3,307,376
$ 3,363,204
$ 3,420,259
$ 3,478,531
$ 3,538,�57
$ 3,596,823
$ 3.660.9t9
$ 3,724,346
$ 3.789,126
$ 3,855,344
$ 3,923,002
$ 3,992.782
$ 4,062,885
$ 4,735.153
$ 4,209,072
$ 4,284,636
$ 4,361,933
$ 4,440.982
$ 4.521,863
$ 4,604,610
$ 4.689.287
$152,984,637
$ 70.457.290
$ 9,782,514
$ 61.450
$ 57�458
$ 53,699
$ 50,186
$ 46.903
$ 43,835
$ 40,967
$ 38,287
$ 35.782
$ 33.441
$ 31,253
$ 29�209
$ 27298
$ 25.572
$ 23.843
$ 22,283
$ 20,826
$ 19.463
$ 78.190
$ 17,000
$ 15,888
$ 14,848
$ 13,877
$ 72,969
$ 12,121
$ 71.328
$ 10,587
$ 9,894
$ 9,247
$ 8.642
$ 8,076
$ 7,548
$ 7,054
$ 6,593
$ 6,162
$ 5,758
$ 5,382
$ 5,030
$ 4,707
$ 4.393
$ 4,106
§ 3,837
$ 3,586
$ 3.351
$ 3,132
$ 2,927
$ 2736
$ 2,557
$ 2,390
$ 2,233
$ 21,157.671
S -
$ -
$ 1,1W,776
$ 1,097,470
$ 1.089,097
$ 7.060281
$ 7,032,535
$ 1,005.815
$ 980,078
$ 955.267
$ 938,939
$ 919,294
$ 902.290
$ 885,910
$ 870.120
$ 854,882
$ 820,4�6
$ 778.985
$ 739.696
$ 702,434
$ 667.079
$ 633,540
$ 607.724
$ 571.540
$ 542,902
$ 515,7Z9
$ 489,946
$ 465,482
$ 442,266
$ 420236
$ 399,327
$ 379,485
$ 360,652
$ 342,776
$ 325,809
$ 309,705
$ 294,415
$ 279.902
$ 266,ti23
$ 253,039
$ 240,618
$ YL8.823
$ 217,625
$ 206.989
$ 196,889
$ 187,298
$ 178,187
$ 169,534
$ 761,315
$ 153,507
$ 146.090
$ 139,043
$ 27,525,872
1.30
rate.
(6) Table 1.
(c) Tabte 6.
(d) Discounted benefit divided by discounted cost.
Source: HNTB analysis.
�
�
�
��
\
Page 1 of 1
� ! i
From: dimond �dimondf@earthtink.net>
To: <elliotibtac[c@faa_gov>
Seat Eriday, Fetsruary t0, ZQOfi 25Q PI�A
Rtfach: Rirporf DiKe FAA Bertefif Cast Fteview_doc
Subjecf: Saint Paul Airport dike cost benefit analysis
Aftached is a tetfer.
Thank yau
Tom
<><><><><><><><>�y<><>v<>
�rann o�nno�� �� susan� aEn�a�o
2119 Skyway Drive
St. Paul, Minnesota 55�t 19
�651-735-6667
�
��
�
3/3/OE
Tom D'vnond
2114 Skywag Drive
Saint Paul, MN 55119
651-735-6667
Febniazy 10, 2006
RE: 3ai�E Faut Airport IIike
!.
To use FAA AII' funds a groject is required, to fiave at l� a total discounted benefit tkat
exeeeds totat diseounted cost. The cost benefit analysis dated 1�IQVeutber 4, 2005 has a
cost benefit of L30. There are some serious sfiortcomings in that caIculatia�
In practice, FAA ittterPT� �F�t�Y P�olecfs ta �tclude those invoIving aew cc�nsfrucEion
or reeonsE7uctiag af asrport infrastraeleue i�ended to aecontmodate ar faeilitate airpart
traff c. The EA gage 2 Sec. 2.1 staies tfiat tfie purpose of tbe dike is to reduce damage and
to redu.ee the impact that 8oQ€1 evegSs have o4the eagacit�r ofthe M"u�n�lis-3t Paul
Incernsticrnat Airg€�rt (14isP} and the 1�Iationat Airspaee system.
Airport �a�acih' PFOjects meeting a dollar fbresfiold af $5 millian or more ia AIP
discxe,�ionazy grants aver the fife of the pro�ect, and ati airport caP�Y Fr�1�'�S
requesting LOIs m�sE be shown to have totat discounted benefifs that �ceed tatal
disconnted cctsts_ FAA lexter dated February 7, 2Q(tb groposes SS nullian in ESIP
diseretionary grants far the d�.e stcadure itsel£
Tab1e 8 tisfs the cose of tt►e dike as $22_4 million instead of $28.5 miflion.
Tabte 2 lists Q&M as $32,&36 a year_ PresErmably this izeeTudes the cost af ma�a�tenance
dred�ng. Can maikteaar�e, 'racftading dre.�igi��� be dcnte for a� average $32,83fs far 5�
years? The 14F�nnesota DNR letter dated Augetst 4, 2W5 stated_ Tfie EA does nat describe
a monitoring plan to assure thatthe stcrrage remains over time. The EA also does not
provide azia(ysis of frequency crf exeavatic�a to ma;rrtain the storage_ The D�IR w�t[
reguire tfiis inforn�ation prior to issuing a Puhfie Waters Work pernEit_ The EA response
states_ A monitoring glan witl be develoged in coordinafion with the DNR Division of
Waters_ 1t�AC wi2t femd aag requFred s�aiutenaBCe effctt�ts fos the eompensataFY
excavation area. Without a p1an, what is fhe O&M based on and is iE realistic?
�
�
Table 3 bases flood costs on tena�t input buE grovides uo dawmentatiasz to supgort the
aete�at eiaims. EA respc�nse 84 sEates t6atfhe te�anE costs in f6e Inty 2(JElS draft EA vKere
$3.1 but Have 8een revised to $3_8 mittion ia the 7anvary 2Q06 EA Again tfiere is no
docuaeentatiou tct s�gperrt these uumhers. �
i ` �
\�
,�
Fage 1 vf 1
06-363
From: "dimond' <dimondtLearthtink.neb
To: <eEtiott6tack�faag�
Sen� SlVedrtesday, Pebruary 15, 2006 8:43 AM
Subjecf: Sai� Pau[ Airgort Qike
Do you have any iclea when you might have answers to the questions we talked
about?
ThanK you
Tom
<><><><><><><><><>�>�><>v
�ana a��no�� �n� susa� o��or��
2119 Skyway Drive
St. Pauf, Minnesota 55119
{h) 651-735-6667
�
�
��
3!3/0�
��
06-3�3
Tahte 3 in the ➢raft EA lisfs MAC fIood pregaration, damage and cleanng at $359,351.
Tfie Final EA Iists the cost at $41f},9I2. 'Fhere is no cioeuutentation to suppoFt this.
Table 3 in the Dcatt EA lists deIay easts fa airtines at $17,2I1 ger day. The �'mal EA lists
the cost at $24,962 ger day. "I'here is nQ dacumentatiag ta s€�gpaFt tf�s.
Table 3 in tfie Braft EA lists ground travspartation costs at $2i6,497_ The Final EA lists
the eost at $317,424. There is aa doeumenta€ian to supgo�t tFtis.
Tahle 1 an page 5 Iists the 5$c�crds of recorcL Tah1e 1 t�sts tite duratian of tloods as 31,
32, 35, 3� aad 78 days. MAC states ig respanse 81 t�tat 84 daps is the eairect �gvre to
use as duration of ftoods. Eighty percent af the floods 2isted in the �A had a duration of
35 days ar 1ess.
Tabte 4 bases grevented $crod damage on tice ass�mptioa that no �zture ftacsd t�itt ea€ee.ed
the ldt3 year �Tvc�ci levet and the dike will ncrt be tcrpped. Twcf af the frve ffoads ar €orty
gerceFet eited in tha EA as justification for the dike would have topped the d�ce. Even if
one of tfie IIoods tagped the dik� rt woutd re�uee the grajected beaefits_
When foriy pereern of the flaods in the gast fifty years have �€ceeded the desig�c aftfie
� propased dike, is it reasonahle tcrr ass�me, tkat in the next SQ gears floods will never
exeeed fhe design?
A pasitive cast benefit ratio is not sugpcfrted by the in€armation pravided.
�
2
��
�
r
Ob-363
Page� of 2
From: <EIGotE.B(adc@taa.gov>
To: "�imond' <dimondt�earthiink.nef>
Cc: <RQEiert.Huber�faa.gov>
Sent; VfJednesday, Eebsuary 15, 2(30fi 9_32 PM
Su6ject Re: Sainf Pau1 Airport E?ike
E}ear Mr. Dimond:
1 apotagize t4�at [ hav� not yet be�n ab[e to respond. { f�ope to be sn a
position to get back to yo� sFtortly.
Ffaving said that, I wi[1 be out of the offiee tomarrow and Friday, and
Manday is a Federa( hoticiay. if wiii fherefore iikeiy be Tuesday at fhe
�[iest. Titart[c yau for your patrence.
Efliaft B{ack, AGL-610
lVianager, PtanninglProgramming Braneh
Federa{ Aviatian Admi�istratian
Airports E�ivisiQn, �rea� Lakes Regior�
2300 E. C}evan Avenue
Des Piaines, f L 60f�'( 8
1"ei (&�7} 294-7246
�
i(��� ��fi
�f
<��t�tE3ncff f�eart�i[tct
k.net> To
Ell�ot� B1ack/RGL/F1� r�i FAA
Q2/15/2tI06 09:43 cc
Al4tf
\J�
\
3f3l06
r
Sul��ect
SaEnt Pau( Airpor� Dike
06-363
!e
Page Z of 2
�
�o you i�ave any idea wh�n you might hav� answers �v the questic�r�s �re tatkec!
about?
Thar�k yc�u
Tam
<> <> <> <> <> <> <> <> <> <> <> <> <>
T�M Q4MO�tt3 and SUSAM a#R1[O�€�
2'['!9 Skyway {3rive
St. Pau�, Minnesafa 551'{9
{h) 65't -735-6667
L��
�
�
�
sr�ia
Page 1 of 3
�
From: dimond' <dimondt@earthtink.net>
To: "Masites, PatcidC �PMosifes�mspmac.org>
Sent Wedreesday, Fetiruary 'E5, 2006 8:15 AM
Su6ject: Re: CBA questions
The CBA arrd the EA sFtouid be using the same basis far tfteir analysFS. Tr F�e
finro do not appear to match up. l� addition the EA appears #a haue rtew
numbers and nQ basis far the ei�ange has been provicfeci.
Thank you
Tom
----- Originat Messa�e -----
Frorr�: "Masi�es, Patrick" <�RRc�sites a'�„�'�rnspmac.t�rq>
Ta: '"dimor►d"� <€�imantl� c earth[intc.net>
� t: Wednesc3ay, �'ebruary 'f5, 20t}6 8:20 AM
b�ect: RE: GBA q�est�Qi�s
> Tom,
>
>!n your phone catt yau referred tha fhe CBA but now y��r are asi�ing abc�ut
the
> EA. Piease cEarify.
>
> Pat
>
> -----Originat Message-----
> From: dicnond [mai�fa:eiimondf�,'}a ear�h�ink.netj
> Sent: Tuesday, February 14, 2446 2t�_59
> Ta Masifes, Pafrick
> Subject: Re: CBA questions
��\
> Ho�nr r�an flaod events are ro'ected ov�r 50 years in the EA as the bas€s
y R l
far
3/3/OE
y
Page 2 af 3
�a-:;:
> Cc��CEtI��tOf1S?
> VV�taf are the prc�jeeted fEaod intensities af the fiQOds prc�jeetec� aver that
> same 5Q years?
> V1i�at are the projected duratians of eaeh ftooc� ever�t anc3 �he prajected
tatat
> d�ratiQr� (a�rfeid c(asur.e cfays} pro�eetec� over ft�e 50 years in fi�he EA?
> Wtiaf is the basis far the fcequency, ir�tensity ac�d duratian of the
pro}ec#ed
> �oods?
>{n additictn can you exptain f€�e [�asis of fF�e sigrt�canf ehanges in the
> n�tmbers of Draft EA Table 3 Page 9 and EA Tat�te 3 Page 8?
>
> Thank you
>
> Tom
>
>
> -- O�igina! Message ---
> From: "Mosites, Patrictc" <Ptl�tasitesC�mspmac.orc�>
> To. `°f�irrtond, Tom <dimondtc.�eaeEhtintc.r�ef>
> Sent: Tuesday, February 'E4 3:46 PM
> �ub�eet� CBA questians
>
>
> > Tam, „
»
>> Sorry I have not gottert back to yQ�. CQUtd ya� please restate your
> question�
>> to me again sa [ can get the mast accurate answer for you_
»
> > Thanks
> > P�t
»
> > Patrick 1Vlosites
> > Metropotitan Airports_Commissian
> > Airside Pro�eet Manager
> > Airport E}evelopment
> > 6�4E} 28th A�venu� Sc�uth
�
�
, ��--� �
\
3F3l�
�Minr�eapat�s, �N 5545(�
> > PH: 612 7'[3-7493
> > Fax: 6't2 794-44�7
>> Chectc our websit� Qut at
> > http�/Iv�vESw mspaimort.eaml
»
»
�
�
06-3�3
' Page 3 af 3
��
�
3f314
�
� �9 j�,�j
Fram:
�6;
Cc:
senr
S�Egect
Torn,
Pa�e 1 of 4
"l�tosites. Pafrick" <PMosites@mspmac.org�
"`d"tmo¢d° <dimondt@eatth�nknet>
'°B(adc. E7avEtf"<DB[3cK�t "R[ef BrtdSet"�BRief�msprttec.arg>:'"E3aI[am, LarrS'"'
<L€iALfJ1[Uf�Hl�ffB,co[r�; "'dreuEF, Glen"' <gfen.arcutt@faa.gov>
Wednesday, Februacy 15, 2006 Si22 AM
E2E; CBA quesfrans
6 have ccmferreci with aur consu[tanf who prepared the CBA for the FAA`s
review and offer tite fol[owing ar�swer ta your gu�stions. ft addresses t�te
bactcground an ha�r the CBA is prepared and what becorrtes ap�arent is tl�a� the
CBA ta[ces the s€afisfieaE risk c�f �tcsocis ar�ci fr�es fc� quanf�fyr the pofentia!
cost tv the airport over the study perir�d. As y€�� can understar�d it is not
ar� exact scienee i�uf is ar� aceepted practic,� by the F�A and ofhers for
detem�ini�g the wc�rEh €�f a pr€�ject.
(nformation presenfed by Kenf Vancien Oe�er, HNTB:
w� ����d tr�� eca o� tr�� ���� tn�t �t �������y t��� ��c� ye�� ��� ���
uvorse} tQ clt�se fhe Aicport for ar�y periai c�f fime. �tVe so�newhaf
simplified the approach by �nodeling 'ttl-year, 20 year, 5a-year, and
1 QO year floods. If you mode[ these �jrpes, there �s approximatety an
18°fa chanc� in any ane year fhat c�ne of these ffc�c3ds v�rou(d oce�r_ .�f1le
didn`t specifea[1� say thaf in a partieuiar year, a�[ci�d v�rou[€t i�appen
or not. We caicutated the avoidect cos� EACH year by ca[cutafing the
average prevented cosfs fvr each fyp� of �Eofld. t� 't00-Year f#ood, far
examp[e, hap�ens 't °fQ af the fim�. So, fc�r each y�ar that th� d€tce
prajecf exisfs, we "preven#" 'I °fo of fhe costs assoeiated w�ttt f�at type
of flaad. That's why tab[e 6 shows beneffs in every year.
With regard ta the ather questir�rt, there's nc� easy answer. The rnode!
cfoesn`t specifieatty state that a certain flood hap�er�s in any given
year. Saseci stricfly on prababiiities, fhougf�, t'd say fhat of aIl the
ftaoe! fttat actualty cic�se the Airport (under current cc�nditic�ns},
approxirr�afely 1 in 'f2 wauld be fvr 5� days or [onger (t�tis assumes th�
drainage pro}ec# is complefed}. Nate, thaugh, that th�s is a guess on[y
far floads thaf close the Airport, nc�t more minor river etevatwns fhaf
�
��
��
�i��o•
� Page Z of 4
�not clvse the faci[ity.
@�-3�3
As you pass this along, p(ease take care to na#e the basis for these
answers. 1Ne never acfuaifiy estimafed fhe number filoods during fhe_
planning period. We used average duratiQrts and darr�ages tc� account for
various scenar�c�s.
!rt regards to your last question, the FAA haci asE�ed us ta� change sor�te of aur
rnethods foc caicuiating the CBA informatian and we vvere stitl receiving
addifiona# informafion during fhe review period which wouEd have
neceessitated the information to be updated. This infQrmation v�ras reviewed
by the �AA as par� of fhe EA process.
lf you have further questions [et me lcnow. Gary has asked me ta abtain a
c�py of an econamica[ reparE on the Sf Pau( aowntavvn AirparE dgne by V4llder
�search. t hape fc� Ftav� a haed cc��y ar etectranic versic�n by �he end c�f
�lciay. tf elecfranic t wi[t send ta yau. Ef hard cap� � wil! cail or ema�!
to (et you knaw you can pick it up at the frant desk.
Sincecely,
Pat Mosites
-----Originat Message-----
Fram: dimond [maitfa:ctimondf a�ear�hlink.netj
Sent_ Tue�day, February 14, 2006 24_59
To: l�osites, PatrEC6c
Subject: Re: CBA questions
� w many flood events are projected over 50 years in the EA as the basis for
Icu(atic�ns?
Vi�►at are the projected flaod interts�ties o€ th� floads pr�jecteci over tha� ���
sa�ne �0 years'?
UVhat are fhe prvjecteci durations af each �toad event and the prv�ecfed fotai
3/3f(
�
Page 3 of 4
Ob-363
duratian (ai�eid c(asure days} projected aver the 5� years in the E�i?
What is the bas`rs far the frequency, intensity and durafion of the projected
flaods?
€r� additi�n can you explain the basis of the sigr�ificartf changes in the
numbers of Draft ER Tab€e 3 Page � and EA �"ab[e 3 Page 8?
Than#c yau
Tam
--- Origina! N[essage -----
Fram: "Mosifes, F�atrick" <P�c�sites c�3z m�mac.r�rg>
Ta: " Tc�m"' <dimond�ea�h(ir�k_ne�>
Sent: Tuesda�t, February 't4, 2Q0� 3:46 P�tt
Sub�ee�_ GBA questions
> Tom,
>
> Sarry ( have no� gatten back to you. Goulci yau �tease restafe yaur
questic�ns '
> t€� m� again sa I can get the mas�t accurate answer for you.
>
> Than€ts
> Pat
>
> Patriek 11�asites
> IVletropo(itan Aarpor�s Commission
> Airsfde Pro�ect fVfanager
> pirpart �eve(opment
> 6U4(} 28th Avenue Sauth
> Minneapotis, �lft� 5545fl
> PH _ 6'i 2 713-7499
� Fa3c. 612 794-4407
> �heck our websi�e euf at
� htt�:llvv�nr.ms�airport.cam!
>
�
C�
�
���
3t�la�
' Page I of 2
06-3b�
Erom: "�ttosites> Pattick' <PMosifes@mspmac.org>
To: "'dimond'" <dimondt@earth�nkneh
3en� Thursday, Febntary '!&, 20Q6 t0:00 AM
Subjecr RE: CBA and EA
TOSTZ,
t witt refer your questions ta our consuttanfs ar�d get back to y�u as soan as possibte. E�ave
peinted aut a capy of ihe �[cfer re�r� anc� wi44 4eave it �p at aur �€c�nt des[c f€� pick u�. Ft �vi[[
take a whiie ta round up the infiormation on the tenant survey. t wiii Vet yc�u knovr v�rhen it is
avaitabEe.
Pat
-----Originat Message-----
�rom: dimanc! [mai[to:cfir�tartcEt@eartFtEinK.netj
Sent: Wednescfay, Fe6ruary 15, 2046 20:42
� To: Mosites, Patrick
Subject: CBA and EA
(f t undersfand eoRectly, the pra�e�Eian is t�tat there wit( be 9 flood �vents
over t11e neact 5t� years. Nine floods af 'lE�O year intensity or fess that woufd
ctase the airpoct.
Ta es�ab{ish benefifs, projected days closuce had �o� Eye c�feu(atecl. Can you
provide me with the total days projectec3 ctosure used ta catculate benefits
over 5a years ir� the CBA?
Why does �he CBA fist the ciike cor�str�cfion cc�st as �2Z.4 mit[ion insteac� of
$28.5 million?
The �BA lisfs $32,836 as the artr�ua( C)&M. V`Vif�at part c�f that is mair�tenance
dree�ging? V�at ►s fhe dredging ame�unf basee� vn sinc� r�o �lan t�as Fieei� ,
deveRoped yet?
� EA response 84 states that the tenant cc�sts in the July 2(It�S [�raf� � w�re
$3.'i miftic�rt but have been revised fa �3.8 mif��on in �t�e Janua�r 2t�� E1�.
What is #he basis for the change? �
�� 3/3/66
rPage 2 of Z
06-363
Tabte 3 in the t�raft EA [ists delay costs tc� aieline� at �17,2't 1 per day. TE�e
Finat EA fists the eost af $24,961 ��r €iay. �at is tF�e basis fc�r the cftange?
Tab[e 3 ir� the E3raft EA lists ground transpartation casts at $216,4g7• The
FFnaf EA iists the cosfs a� $3't7,413. V�ihat is the basis for the change?
[3aes Tab[e 5 of the CBA prc�ject operations at STP to increase from 134,377
fo 256,28E}? That is a near c€c�ubling of operati�ns.
Gan yau get me a eopy Q€ the Survey of l�irport Tenants and HI�TB anatysis
fisteci on Tabie � as the basis �or Tabie 3 af the �BA? � cc�uhi pidc fhem
up with a hard eopy vf the Wi[cier S�udy. The electronic version does nat
open.
Thank you
Tom
<> <> <> <> <> <> <> <> <> <> <> <> <>
T�}l1A f}E[tftONE3 and SUSA[�t �[ME)NQ
211 S Skyway Drive
St. Paut, Mirtr�escrta 551'f9
(it) 65'f -735-6667
�
�
\"��
l
3/-
��
t3b-3��
Tom Dimond
2119 Skyway Drive
Saint Paui, MN 551 t3
651-735-6667
Febmary 21, 2006
Re: Misrepresentation of Material Fact; Immediate Withdrawal of Application Demanded
Review of Ramsey Couuty property records reveal that the land MAC plans to e�cavate
is not under MAC ownership or under any known leaseholder agreemerrt. EA maps
submitted by MAC admit that the proposed excavation is outside airport proper[y.
Property records reveal the land is owned by the City of Saint Paul.
5ec. 61.301 of the Saint Paul Zoning Code states eaplieitly that "any person having
ownership or leasehold irrterest in the subject land andlor building (contingent included)
� is eligible to file an application with the planning commission for [for variances and] site
pian approval.
Unless it shows conclusively to the coimary, MAC is riot the owner ar leasehalder on the
land upon which it seeks to excavate. 'Fherefore, MAC is not edigible ta fzle an
application with the planning commission for any variance or site pIan review affecting
this property. MAC's application teflects a material misrepreszmation offact and musC
be immediately withdrawn.
If the maps MAC submitted are inconect and there is additional information that reflects
the area to be MAC properrty, you are to furnish the undersigned with copies of such
documentarion or immediately afford the undersigned with the opporiumty to review
such. Failure to do so, will be treaLed as an admission and the demand for the withdrawal
of MAG's appiication sustained since it will be in d'uect violation of the City's Zoning
Code.
SincereIY
� ��
Tom Aimond
�
" `�
�
�CVJ��.I\.]II4Y�RL1 --_ -- ��
- � r�AND ' = - == -
'=` DONPIELLY � ^_ � �' �
��. . � / r'
-eS W: f� c�tat -�vc r_
� -
Saint Paul
June 20, I9g5
VIK\cd�:c.NtC85S3G? :/ -'tG?CN,�
p� 4f��E 3 :���5^C� 7C 2CGC3 ':SC?tiU55°'5.323'dl1
° _, .r. �s ` - - =�cae =_cz aaa-s_aa - :earcr:e eaT�
- - � ��.�; �, : c .�
. . ' "cY ?c23?
. �
�
Ob°3��c��E
� ,��1�����
z� 66. �dg5`(
Federal Aviation Administration
c/o Minnesota Department of Transportation
Aeronautias Di.vision
Transportation Building
Saint Panl, M�nnesota 55155
RE: St. Pau� Downtown Airport {Holman_Fieldl_198�-$6_AIP__
Gentlemen:
In support .o� the appl.icatioa of the Minneapolis-Saint Paul
Metropolitan Airports Commisszon, soiaetimes referred to as the
Metropolitan Airports Commission (MAC), for feder.al fundinq for
its 1985�86 Airport_ Improvement Program, MAC has sought from
us an updated and current title opinion for tlie captioned Airport
and adjoining properties invo2ved in the project.
This opinion refers to the-attached plat of the Airport properties
and adjoining lands directly� invo].ved in or affected by this
project, all of said �ands being represented thexeon in various
colors which identi.fy the ownership status.
tditIi reference to this plat:
(1) Phe greater part of the existing Airport, colored in yellow,
consists of the initial Airport as to which title in fee simple
remains in the City of Saint Paul. Pursuant to M.S.
�§473.601-473.679, Aixport operations were passed from the City
of Saint Paul ta MAC, but the fee tit2e to this property comprising
the initial Airport as turned over to MAC �or operatian and control
remains with the City of.Saint Paul tM.S. §473,621, subd. 2),
f2) The'small area colored in hrawn at the west side of the
Airport is owned by the'Minnesota National Guard_
(31 The areas coloreci in green and red are Iands acquired and
awned by MAC for Aixport purposes.
1�
�
��
> . ; '. , i• 1 CK �t1E.{'(�K�
' AIND
DONNELLY
�Federal Aviation
June 10, 1985
Page 2
Administration
4b-363
�
(4) The lands colored in orange, blue and purple were acquired
bY MAC but_ later conveyed to the Saint Pau1 Port Authority for
development and use, subject .to heigfit restsictions and MAC
overflight rights as Airport operator.. �
In conclnsion, alI of the lands represented in the variaus colors
on the attached plat are either owned or controlled by MAC, or
where owned� or contrdlled by others, are subjeet to heiqht
restrictions and over�light rights required incident to the Airport
operation.
- —_ _. . --- - --- ...-- - - --- -- ----
Very truly yours, .
� .
Theodore�;
� JM:keh
ttachment
�
�,
�
_ _ _ _ _ _ _ _ _ ? _ _ _ I I 11
�ff P1i
Ob-363
�
-- _�1��
- . . (
f' , �
_�'S=.J�,
�,_ � �
'
_'& ,iy`>...z�-_`_
° t.. _ �,:
< __`;.
i , __:
/ .
"- �:
� - _ - z.
_'_. ' �
t
2` , �
�1�. ,..
_" l
�
�.\ �
_ �.._..�.� �
�--= `- _. - - _ `=:
�'--. �= i � � -.
. sc�m,� ` -- "
Airport ;_,- -.
: _ .. . .� � ;�-.:
� Properfy Lin`e_�--, -_ ; -.
�-,�_-==_�' <�-_
�
' ��_" . ' _�'_'� w \ `� �``` �,"�"'`.x� ,
_ /�:' `,. '_ ' - ."— -' ?a \ � K'ji � , _ ' -�„�. 3,.
- t��.,i.- _"__'"J' :-.`" '`' ��
_ " ?y. ,-_y��.. ���'r�� ���� , �a
h��'
" ° 't.�t\ '�` ����. �= , : \„+' F „ R
. . `. ' \' J , �->` �`` %�� _
,. � .4:' n,�. ��+ � � �� G'
. 'w: A'`'�,�`�i' . & � i � - � '
� ' ' �i.[ �� 1 �� ``t ;
k o�._"" .` � �. . . �� m .' . '� %��;.V'
i . - — '� ��� _ �%' r '�:; , ,-�,'.
��: �.," �'�• at� a y .. _ �•� s
/ � ° � "` F . C"�.° .;` �' ;
_ ,� . � . � `: �
-- _- �, .,� :: ��".�nv�,.'�
u i `�� \ ay'3 ::,, . '_4" ,:.!,iJ Xy
�ii _ ��*;+�i��a �'so:� �\ti:��<s',, " !
_ .c�=,,� . . +
_" _ .�,�' . "�s, ' - ♦
� �\� . . _'_ _ _ �
, � • � S � s �,..avn��,a_.. � '_ waY9l4Ft00'-%3.65T_ - =-.... . i t
"Y ' � . A' - _ + �
� � �
j ra. re - . �1'. ~ �
���, � �.�_�__ t .
�' f � X_� ...._,�&ktrazrc .. A ' ��� . .' �
' ^ "- � .LOntrol Tow ' \' � � �. "\ �$
. � ' �' �� ' .
\ ' �. .Y F _ ����'\\ ��}�� `-
\4 � ��
� \ \ .
-. 1� S --nr � \� � : `P4 � '.
4 '�.� r
, � _ ' { , .� : `, .r�``'i .. �; !
�� � �""'ESY FCShY"< S i J / , y
t. -0 1�.,� �- 1
� t �..- � � �r� �: �. � '�z t '' . �
^ � � � `i � '� \ .v�!' i> �/: : ����:1 l4 '.��� , i
'C ' �' . . °..
). . \'- ' �*,S :.. . , i\ p " �� s�'-, e
� � .��.�z �e -'�'r� ...fi/'t' �'>-, `E
�� \\t� � �l-� ��� yX�
`,c;, 5 .� �e V.�� . �l. %. _ y � ,. \,,Q _ �i `�'.
�.� .�` ���,, �\� /: _ J .r .y•i � i� ,
•,4 n/ Y \ U� �i y f �. j ':•
�.�.� �\� � `a+ � ��.- � �`��`: f_ !l� /`_\Y.. `�� �
! \.'� C
'� ,` _ d�ly � \ ..�\t Y P 'J. 'i �.\ ��
_ � � `� \p ` _ � �\y ii/`` lii ��, ry�
� ��� � ,��'` �� _ � ��•°• � �
, �� ,'��.�� �'`-' \� t ,,� _ -� �
_ x� � ` j
.\�4 � � q�`.�.�1`\"� . , �
. -.. �: i, i
- : <_ �
'.. --
\
ibL"-,=_._-..__ ,�}k`'. \,
,',� '�.
� \�^� •
C+
t: � "�
\
�
"°;:;�"„� �• .' � Perimeter Dike and RSA Improvements Existing Airporf
a . � . -
St. Paui Downtown Airport Figure
-.:.i:o,��::lo�es P%i
:i 's . �:�.::._g; ���Gia�
���. �i
'�33<
il •
\��. �'
CiviXplorer Online! Attribute Report
6-363
�
�
�
�!i
__--_�:
_ - ;; -.
ti �
� ParcellD: 042822320001
�= Street 6 �
_> tdumber:
�� Street: BAYFIELD ST
Ci�y: ST. PAUL
< dvon�r i�am� MPLS ST PAUL MET AIRPORTS
�— l: COMM
'1 - ---- - --- -- ---`� �_
'� This map is neither a legal/y reco�ded map nor a suiuey
and is not intended to be used as one. This map is a
compilaSon ofreco�ds, infoimation and data located in
ua�ious tity, munty, state and fede�a/ o�ces and other
sources regarding the a�ea shown, and is to be used for
reference ourooses oNv.
9�amsey County
Propei$y (RRTi�4�0} Search by Parcel ID
Search
F'arcellD 04282Z320001
streef Number 644
+Jnif
Str2et BAYFIELD ST
City ST. PAUL
�IP 55107-1008
t3wner tdan;e 1 MPLS ST PAUL MEf AIRPORTS COMM
Owner Name 2
Owner Straet Address 644 BAYFIELD ST
Owner City/State/Zip ST PAUL MN 55107-1008
Homesteader Nama 1
liomes�eader Pdame 2
Homesteader Street
As3dress
Nomesteader
C"rtyJStateJZip
D2eded Acres 358.05
Deaded Area (sq.ft.) 15596658
Approxima�e Lot p
�rontage (ft)
���-
__,�+$
� �
-°.-°;�`^ _
`' �=, .=
``�`'�
if.P.wii_ .
\F
.
�
Page 1 of 2
� ���,��� couri�
��
�:��� � ��. -
� �� �. - ���
� �arc�;i�
y� _, � �
- _ _ �.,° Info�rnation
� - �tepart
��
�
LAMPREYS ADDITION TO SAINT PAUI IX LEASES & IX NATI GUARD AIR BASE; PART E OF RY
OF FOL; PAR7 OF GOVT LOTS 7-11 IN SEC 4& GOVr LOT 4& 12 & E 1/2 OF 13 IN SEC 5 T28
http://maps.metro-inet.us/rcarcims/ims?ServaceName=raansey_master&ClientVersion=4.0&... 3/2/2006
RCB310M3 COUNTERI RfiCAP Collection System
3/02/2006 10:10:10 Inquiry - Legal/Parcel Location
R R 04.28.22.32.00Q1 MPLS ST
2007
TX LEAS�SS & EX NATL GUARD
AIR BASE; PART E OF RY OF
FOL; PART OF GOVT LOTS 7-11
IN SEC 4& GOVT LOT 4& 12
Sc E 1/2 OF 13 IN SEC 5 T28
R22 & S7./2 MOL OF BLK3 ZO-
12 & ALL OF BLKS 1-9 E AMBS
ADD & S1 2 MOL BLK 5& ALL
OF BLKS 6-8 2ND ADD TO
BROOK & ALL OF LAN-
GPsVINS 3RD ADD & ALL OF
LAMPRI3YS ADD
F3=Exit F12=Cancel
�
��
Bottom
�
�
5
;
�
PAUL
�
MET AIRPORTS COMNF
Plat; 01244 Lot: ��7�:3 �i �
DesC: LAMPREYS ADDITION
Sct: Q4 Twn: 028 Rng: 022
X: .00 Y: .00 Z:
�
�
�
CiviXplorer Online! Attribute Report Page 2 0� 2
Li�
Tax f�escrip�ion R22 & 51(2 MOL OF BIJCS 10- 12 & ALL OF BLKS 1-9 F AMBS ADD & 51(2 MOL BLK 5& ALL OF
BLK
€'lat Name LAMPREYS ADDITION TO SAINT PAUL
Date Plat Recorded 18851224
AbsCract ID Z-28
Torrens ID
Count��r Land Use Code � pAUL AIRPORT & MAC PROPERTY
(CAN1�)
C4unty Land Us° Cou�e SPECIALTAXING DIST
(PREcR)
Market Vaiue Larid 31193100
2006
hlarket Value Bidg 16102400
2006
Market Vafue Total 47295500
20�6
P7arket `Jalue Land �
2005
MarketYafueBldg �
2005
Market Vatue Totai 47295500
2005
Total Tax payabie gg16
2005
Dafe of Last 5a3e
Sale Arice 0
Nosnesteat! Non-homestead
f3escr'sption
t�Yumber oF Resadsntiat �
Units
Year [2esidence Su"sit 0
Totai Residentiat 0
Living Area
Residence �xtsrior
Residence Htyte
Kesidence Number of Q
Stories
Rasidence MumBer of �
Rooms
Residence Number of �
Bedrooms
Comrnercia! Sttucture �ILJBUSJAIRTERMINAL
Type
Commercial Yaar Suilt 1950
Topagraphy Level
!ltitiYies AII Public
Schoo{ Distrsct Sc Paul
iNatershed i�istrict Lower Mississippi
��
�
http://mapsmetro-inet.ushcarcims/ims?ServiceName=ramsey_master&ClientVersion=4.0&... 3/2/2006
�
z�-
2�
�2
: ,
�
: �
�
� , o = � . �
` �
I ; . + Zo.
�' 30
J F
� Q ' � �.
_ Z 6 ' ��y
. I9 ' � . _.
�� . /8 t�) 8 ` `'
. Yho
17 °' 9 . .
` � l6 �p
� !I
l� � I2 . � _
3 13
Z o.
�4 o a'f•
30
t �
_
� 2$
'� ,
$ f
�� ' `
A
� sF. • - � v \
+� � 2 3 , ' p 5 , � � .� .
1 .. �� ,
� • 2�
t . ' Z i - ° ,<:�
.
21 �` 2 5 = '� � �
� � ' �. ts) .. S • ? • .
� ' 26 6 ` . yk • 8 � n A
� ` -- — �
� 25 � s 23 9 ` �
' . 2 ,�. B - 2 2 = . :.
� � � , /o -
23 g 2�
• _ - � /i
� 22' 10 - = 20 =
� j '
� - Z� � tf 19. !3 . . _
� � 20 � , j2 '� ' 1 � �
,s ,3 - `r ,
� .' � , � �
1 ,8 14 � �6 ' � ''' —
-o
; ```.. • �
I7 �6 ._ `i e : :::...^.
' , jza _ DO � # Z ZSj6
/6 . E o �
� , a � V cp /
` s � `•'-' A 19
,_, F. �) u_'� 2
� . :' r`''" ao• °
' • � I . /8 . 3 =
,.. �.::,.: -
�
- .,,�;:. _ .
:;�,:;;; : a; . , _ _ - —
�, . . _�:-i �� - ` -=.:. . - .. . � . �� —
� �� �.
F
���
Document: Environmental Assessment for the Perimefer Dike and 12unway Safety Area
Improvements Project at the St PauI Downtown Airport, Ramsey County, Minnesota, July
2U05, federal agency: FAA
Airport Development Date: July 2S, 2005
Dear Ms. Rief:
The NEPA 7mplemenYation Secrion has received the document lisfed above. Under the
National Environmentai Policy Act (NEPA), the Councii on Snvironmenfal QualiFy regulations,
and Section 309 of the Clean Air Act; U.S. EPA reviews and comments on major federal actions.
Typically, these reviews focus on Environmentat Imgact Siatements, but we also have the
discrerion to review and comment on other envirovmental documents prepazed under NEPA if
interest and resources permit.
�� �_ r �
� �� ,�
UAIITED STATES ENYIRON!'�NTA,I. PROTECTION AG�1\'CY
� REG QN V
`'�� on Bonlevard
Chic o, IL 60604
AUG 01 �}05
� We did not undertake a detailed revisw of the document you sent to this office, and will
not be generating comments because of the reason selecfed below.
The document was not prep�red under NEPA.
� The document was given a cursory review, but other workload oriorities precluded us
.. �
�
The document was given a cursory review, and we deternutted that there were no
significant concems meriting comment.
We opted to wait for the next level of documentation on this project befare decidirig
whether or not to cotnment.
�ue reserve *_he ri�t to reconside* undertaking a review at future pl�nnine stages, or if
significant new data on the project is made available by the sponsoring agency or other interested
parties. Thank you for providing information on the project.
Sincerely,
.�i<��'��%�"r/ .
Keimeth A. Wes e, Chief
NEPA Tmplementation Section
Office of Science, Ecosystems, and Communifies
`��
l
�
;
;`
i
CEIYIVP-OP-R 2005-7386-TJF j
SUBJECT: Notice of AppGcation for Permit
s. .rvlusvicTTOrr.
- ;�� "�'� -- �; �;� "<:
v /J
Tius excavation aad riprap project comes under the regutatory jurisdiction of ttie Corps of Engineers
because the work would take pIace within the Mississippi River, a navigable water of the United
States.
REGiJLATORY AiITHaRITY: This agplication_ w�ll be reviewed according to the provisions
of Section I O of the Rivers and Harbors Act of 1899 and Section 404 of the Clean Water Act
Therefore, our public interest review will consider the guidelines set forth under Section 4Q4(b) of the
Clean Water Act (40 Code of Federai Regulations 230).
T'F� APPLICANT HAS STATED THAT THE FOLLOWING STATE, COUNT'Y, AND/OR
LOCAL PERNII'TS HA`ZE BEEN APPLIED FORITSSiJED: Cify of St. Paul; Minnesota Deparhnent
of Natural Resources. The dike proposaI would not commence until the Cily of St Paul adopts the
Letter of Map Revision (LOMAR) for revisions to the floodway liittits approved by the Federai
Emergency M Agency (FEMA) in Jvne 2005.
6. STATE SECTION 401 WATER QUALTTY CERTIFICt�TION.
�
Valid Section 4Q4 pernuts canaot be issded for any activity unless state water quality certif cation for �
the activity is grauted or waived pursuant to Section 401 of tfie Clean Water Act The state Section
40I authority in Minnesota is the Minnesota PolIution Conlro[ Agency (1�IPCA). The St. Pau1 Disfric:
has provided this public norice and a copy of the applicant's Seotion 404 pernut application form to the
MPCA. If MPCA needs any additional information in order for the 3eciion 401 application to be
'considered complete by MPCA, the MI'CA has indicated that it will request such information from tke
appficant. It is the permit appt�cant's responsitii2ity to ensuze that the MPCA has received a valid,
complete application for state Section 401 certification and to obtain a finai Section 40I accion from
the MPCA. �
The NII'CA has indicated that this publie notica serves as its pub&c notice of the application for Section
4�2 water quatity certification under Minnesota Rules Part 70Q1: The MPCA has also 'vndicated that the
Section 401 process shall begin to commence upQn the issuance date of this pubtic notice uriless the
NIPCA notifies both the St Paul District and the permit applicant to the, contrary, in writing, before the
eapiration date of this publie notice:
program due
MPCA is intendine to
certification applications with limited excep�ions but the IvIPCA reserves. the right and �rity to
proceed differently if e�.treme or �que circumstauces merit a different approack. In many cases, the
waiver of 40I cefification means that the MP�A has not reviewed federaify permitted projects in
detail for conformance with state water qtiality staudards nor has the MPCA made a determinatiori of �
the proposal's compliance with state water quality standards. This waiver action, however, will not
exempt tke app&cant from the responsibility of corriplying with alt appficable water. quality standards
and requirements as contained in Minu. R. eh. 7050 and all other applicable state rutes regaiding water `�
L
1
r
3
�
USFWS NWI Wetlands
��� ��
��������� ,�. .
������
'- �i� - �?I�-�
�
�
�
G
S
C
legend
f/ InMrstate
Major Roads
�{ OtFxRoad
�y mes�m
N sarengnway
�y UShgFway
�* Roads
� CONUSCities
�, CONUS USGS quad fndex 24K
Lower 46 Wetland Polygoms
I �ESWarireaMMarineOeepurafer
I �ESWmireaMkarNeWetlantl
i, � Erashra[er Eme'gant WetlaM
� Freslwater Foreshadf5hrvb WMbiM
� FreshxaterPand
� iake
� Olher
� Rherine
Lower48 Availabie Wetland Data
., Ncn.Dig�al
Oi9iFai
�•,:; No Dafa
z.: Spn
� NH� Waterpodi�s
�„+ NHD Streams
g� Canatlian Water6odies
p CQNUS Counties 1QOK
-� Ucban A[eas 9QQN
� CONUS Sfates 9UOK
:p Soutt+Amer[ea
0 NORh Ameriw
Map center. 44° 56' 6" N, 93° 3' 17" W
� Scale:7:35,899
is a user generated static output from an Iritemet mapping site and is for general reference oniy. Data layers that appear on ihis map may or may not ba
airent, or othervvise reliabie. TH�S MAP �S NOT TO BE USED FOR NAVIGA710N.
t
93-0-0 W 933-40 W 93-320 W 933-0 W 93-2-00 W 93-2-20 W
l
O�EAN6 P�Etl�FAlIE
�
:�
��
�
��
�
�`; i ��iT�
�
��
� F
�°
�
���'�^�
PAEif6TAl1(E tilLA1B
� � ��� � � ��
�� �� ��
.�
--- _ — : ::
-- ;�„�,-- :
,
t�'��
a-_-
.
Page 1 of i
�
�
�
`��
ht�p:lJwww.fws.govinwifPabs_ReportsJ�lass 14fam�aUfignresl�g4.gif
2/27/Oe
President Announces Wet[ands Iuitia4ive on Eacth Day
��� ��
�������+r� �
06-363
Presictent Announces Wetlands tnitia�ive on Earth Day
Wel{s Natianat Estuarine Research Fteserve
Weils, !1t[�ine
H in Focus: Environment
12:12 P.M. EDT
Page 1 of �
,. �-
,- �r
For 4mmediate Rekease
Office af the Press Seeretary
Apn122,2004
� ��� -
Presidenf's
Remarks
THE PRESIC3E�{T: So great to be here, thanks. Gosh, my �'��"`
outtook improved dramatically the m�nufe
beautiful piece of tartd. Thastks for having
honor to cetebrate Earth aay with you in:
( e, in an asea fhat i navff realize [ krtaw �
ber 41 and t fiked ta try ta catch s�rip
ound here.
I stepped c�rt this � tisten
rr�e, and thanks for coming cwt ta say heEia. {t's my
� state that I}cr�ow pretty darn welt, in a state that I
vett because if was rsght €�ff the beach here that otd
:d bass. (Laughter.) It`s a prefty good place to fish
Before 1 start gaing on too (ong about Mot�er Eart[�, E do want
ta recognize rrty r�at��r on Ear�h. Thartks for eor�tirrg, AlEc�rrt.
(pPPtause.) ! hape you're up th� road rnaKing my bed.
(Laughter.}
Earth Day has become a great tradition in our cauntry. {t`s a
day that reminds us that we musf be goad stewarrfs of the
land around us. That's what this day says fo ess_ And we`r�
iucky tv five in America, because we`re btessecf wi�Et suctt
unbe[ievab4e (ands: As the Pcesiden�, t'm fact�nate fa be abte
to travef and see � tot of our beautiftti r�ati4n, whethe€ it be frem t�te — frc�r�t Maine to the Big
Sur in Ca4ifarnia ac parts o� fhe great stafe of Texas thaf a�e beautifu! ta took at, toa.
The �rr�partance about Earth [3ay is that it remtrtds us �ttaf we can't taKe the natural wanders
for grantecl. �at's what �arth Clay says to rne, and 1 hope it says ta yc�u, as weif, that we
have responsibifities fo the natura[ world fo eonsertre that+�vhieh �re have ancf to make if even
� tsr. l"t�at's the caii for �arth Day.
the years since Earf(� C3ay was esfabtished, t�merica has made great st�des in F�an�r�ng
the ideal of conserrration and [iving by high standards of sfewardsE�ip. We`ve made
tremendous progress during #he last four years. i have a respnnsibstity as the Preside t to
http:ffwww.whitet�ouse.gavinewsfreleases120041Q4/printf2E}04Q422-4.hfm1 ���127/06
President Announces Weftands Ixritiative on Eaith I}ay Page 2 of 6
�����`�
put peopie in an administratian that understands the irnpo�tance of conservir�g our natu�
resources and rna�irtg �ern f�etter-
My administration has put in place some of the most impo�tartt anti-pa[lutior� �olicies in a
deeade — palic�es that have reduced harmf�t e�rt'tssions, rec4aimecf brownfietds, euf
phosphorus reteases into ot�r rivers a€xf streams. Sir�ce 2004 , the condition af Amer'sca's
fand, air and water has improved. EAp�tause.}
Today I want fQ talK about �nretlands. TC�e aEd potiey of wetiands was fc� iimit f[�e fass af
wetlands_ Taday !'rn go�ng tQ ar�nounee a ne�r �licy ar�d a new. goal for our cc�unfry: lnstead
of just (imiting o�►r tosses, we wii[ expand the weffands af America. (Apptause.}
f appreciafe Paut very much_ He's a— abviaus[y a good manager. First af al[, he Eaves what
he does. He eares deeply about the mission. He's ga� such a jayous smi[e on his faee that he
must be an easy feltow to work wi#h. And i want to thank hECrE fo� ht`s Frospita�ity. He d€ctn't
even campEain about the size af my entaurage or tt�e impasition that we must have imposed
on Paut and his great staff.
i atso want ta thantc the staff for �ivorking hard ta rnake sure
tt�is stice of heaven is as beautifu{ as passibt�. 1 appreciate
sa very much State Senator Paut Davis �aining us today,
Senatar. {Apptause.) Yes, thanks ior co�ing. 1 suspec� ther�
are sam� taeal a€ficiafs whci are here. 'C[�artks far beirtg here_
1 tike ta rernind toeal offlciais to make sur� tF�at you em�ty the
garbage and fit( #he pothotes. (Laughfer.)
E had the tic�rtor of crteeting Ray ancf Becky Davis at tfte
airpart. 'Chey're tocat cit�zens_ The reasan I bring up Ray and BecKy is because they're the
parersts af fF€ree sons �nc�� have -- are no�nr wea�irtg �Ete t�niform csf tF�e Elnitecf States EUti[�ary.
(Appiause.} Sergeant Graham Da�ris, Marine eorps_ (Apptause.) Thank you, sir. Privafe First
C[ass Stewart E?avis whv is now irt Afgttanistan. Nlatce sure, Grattam, that yau — f�PPlac�e} —
- matce suee yau fet[ your bra�ser, Stewart, and brother Bradfey, fhaf fhe penpte nof onty
applauded you, but they applauded fhem, as well_ EAPplause.)
! want ta thank the Davis family far their steadfast support of warfcing ta secure this — of
raising sons v�rhQ are vuarKing hard ta seeure thi� cc�anf�. - t't�ese have �eer� t€�ugh tfrrtes for
Arrteriea, but we`re do�ng the right thing. We're spreading freedom and peace, so that our
children can growr up i� a peacefu[ waeld_ (Appiause.}
What's interes�ng about this year`s Earth �ay [s that it €atls in the rrriddle c�f l�at�a�a[
Volunteer Weeic_ This week we hanor fhe 64 �i![[on Arne�icans �rho vcrie�nteer. And on�
my responsiDi[ities is to cai[ peop[e to a higher caliing. [f you're r�ot votunteering, da sv. t
make so�nebady etse's life better, inetuding your own. {App[ause.}
hi o . ov/newsfreleaseslZfYa4<fS4 '�fl2dQ4Q422-4.htm2 � , 2J27�
htfp:lfwww.w teh use g /pn `�,(�
�
Presideni Announees Wettands Initiative on Earth Bay Page 3 0£ 6
06-�63
�what makes this beautiful part af the warld go is the 4tJ0 voiunfeers who worEc here — tf�e
�tl vo[unteers rr�ho are exercising �heir responsiE�iteEy as eifizens f� maKe tttis beau�fu[ �art
of the worid even rriore beautiful and more meaning#u(.
And so, first, i want ta tl�anK a{t the votunteers wha have "
taken time out of their tife to make this such a speciaE spat_
Pasficu4asiy, t want tQ fi�an[c F�ank and Carof He(4er. 1 met
Frank ar�d Carol at the airport when t landed here in Vlfetts, in
Sanford. And R gave them the President`s Votunfeer Seroice
Awar@. t did so because of iEheir strong eommif.ment anci work
here, but t suspect they`tt say they received the award on
behatf of the other 398 peapfe wha maKe this such a speciaf
p(ace. ThanK you a(I for working hard here_ (Applause.}
And I saw firsthand why you tike to c:orr►e. lt's 1,600 acres of sa{t marshes and �aches anci
forests and fresh�rater uveftands. Tt�e W�E[� Reserve is an exar�tpte af ho�v cctrnmit�ed �ec�pte
come together to not o�fy protect, but to improve the environment. it's a good exarnpfe of
what t'm going to talk about here irt a littte bit.
�nmunity and carporate partners, atong with the federat gc�vemrnent, are working an the
� kes tstand marsh restoratioct — community ared carpacate partners. En vifiec r�rards, rn
cder to make sure the restoratian works, it requires more than just gavernmen�. It requires a
buy-in 6y ecimmur�ity pa[tners. tt requires a buy-in by corporate America. See, cocparate
Arrterica has a responsibitity to the communities in which fhey live. They've gaf the
respansibi[ity ta tet[ fhe tEUth when it cames ta fheir balance she�ts, and they've gat the
resporrsibiiity to conf€ibute the q�atify af the communities i€� v�rhich �ey tive. (R�pptause.)
The Laudha4m Farm, where so rr�uch enviranmentaE educatiact and research takes pface, is
supported by a private trust. You sup}xtr� the private tn�s� ir� Kennebunkport. don`t yo�,
Mom? So do 4. Ray Bradbury — we've ga# Sradbury's Markef. (Laughter.) The guy wha awns
it has put together a tand consen►atian trust in Kennebunkpart �1Ie're �rauci suppa�t�rs af it.
{n other wards, ci�izens can make a significant difference in impravtng the qualify af the
envircrrtment, just lik� thase whQ have cfone sa at the LaucEhatm �arrr€. Artcf at the Li�tte �
Estuary, t saw the va4unteers working an pEatfacros that attaw students and researches to
view the marsh, ta understand the marsh, w�tt�out harrning the grasses or the sh€�r�line.
There are good peQp{e worEcing toge�ter for this reserve, for the sake a� wiRdli�e, far ttie sake
of undersfanding artd fcnowtedge, and for. the sake of future generafsQrts of peapl� wha are
unate enaugh to corne hece. (App{ause.}
�"he uvorK you're doing here to presenre wef(ands is an :��=:' " ��
�.-� � . � �
important part of a nationaf commitment_ For many years, our =� ,:
nation has been working fo prevenf the net Iass of wef(ancis. � �
m�::;_.: _
http:/lwww.whitehouse.gov(newslreleases/2604l04/p2intf200 � 2/27/OE
President Announces Wetiands Initiative on Eazth Day
Page 4 of 6
-- - -- - - - tii � ° � � �
And there`s a reason why. Ame�ica's wetEands are tE�e habitat
for thousands of species c�f wildEife. ,fust �ang au�, out ir� fhese weflands out here, and y
know what !'m talking about.
Up fo haEf of a!! t�orth American bird species nest or feed in wetfands. About half of at)
threatened and endangered species use wefiartds_ There`s sa�e endar�gered speci�s €�sing
the wet[ands right here on this piec� of prapesfy. f3ur wetfands help ta trap pottution. What 1
bet a(ot of peop(e don't understand is the we�ands he(� to c[eart the water; as �rekl. They
red�ee the impact af tloods.ltttettands stab"slize s�are areas. As u�retl, vuefiancfs pr4vide
recreatios�at apportunities for guys iike me wk►o like to fish, and for people Eike my wife who
like to watch birds.
Wetlands hava beert eatted it�e nu�secies of IiPe, and their �nreif-being is vifat fo the h�alth af
aur er�viranment TFtree deeades aga, the �!n"st� States was tosing almast 54Q,UU€� acres of
wettands each year. Americans understoad that coutdn'f be sustained, and so the nation
began to taKe ac�on. Every [eveE o€ gavemment, joined by tandowners and ecsnservatii�nists,
worked hard ta #urn fhe sifuatiors around. tn afher rhrnFds, if taotc a ca[latxirative ef�ort af
peo�le vvho eared about the env�ronment.
Our governmen# began ta provide substantiat financia{ incentives far 4andowners tQ return
farm[and tv �nrettar�ds_ Ta7cpayer do[tars have been rrtatched by sfates ancf laeaEities an�
cortsenratian graups. Et`s the cEassic pub(ic private partnership for the gocad of fhe
environment_
Our national commitment to wetEands is shawing goad prc�gress -- really better than good
progress when you thirtK abaut the fad that �nre were [�sing a half-�-rnittior� aeres a year not
so many years agv.
Accarding ta figures announced foday by tRte �epa�finenf of Agricu[fure, we have greatiy
rectuced the annuat tass af wettands. Ar�d that's a pos�ive development. We're nearir�g �
tong standing goai of acivalty r�storing as many acres of vsre�iands that are tast. The figures
show that an agricuiturat fands, we've seen sorrte ga�ns for tt�e first fime, which leacis me to
believe we c;an do a be�er �ab irt the nafion if we focus our aftention. ,
So taday, i'rn committing our govemm�nt ta a new paticy-
wit{ rnove beyand th� no net lass of wetlands in America tc
having an overail increase c�f A�nericarts` wettands aver thr
nexf five years� (Apptause.)
We can achieve this goat. !f is a reatisfic goa(_ To da sa, w
wit! work ta restore artct to irrtprave and ta protect at least
tFtree mi[tian aeres af wefiancfs aver fhe nexf five years. Fii
we wil! r�store at least — we uvit� restora �t teast one millic� t
acres vf wetlands that cia nat exist foday. Thraugh ex�sanded incentive and
http://www.whitehcnise_gav/news/reIeaseslZd04f04/print12dt
partrtefs�i�p
��� ��
President Announces Wetlands Fnitiative on Earth Day Rage 5 of 6
sures, such as the Qepartmenf of Ag's Wstland Reserve Prog�r �nc�'�rough the new
f�'
[1�S UEtdeC �� �R�2fIQC I��R�E�fTt@R�`S I�IOC�E't AICt2C[C3[t VIIB�I�t1(�S �4ClS�CVB�[Q[t AC� — WfT[Ch,
by the way, was signed by your husband, my dad. (Applause.)
Listen, �ere`s a Cat af things we ean do thraugh these programs. We can set strearns back .
on their naturaE coctrses, alEowing weflands to returr�. V1te car� pravi@e incenfive� fo our
farmers and ranchers to stop cu(tivating areas that were ance wetfands and make them
wettands again.
A good way to make sure we restore wet(ands is ta take thase lands that were once
wetEands and pravide incentirres to fhe landowners ancf say, here`s an oppo�tc�nity for you to
confribufe fo the increase of wetfands in America for the good of the cauntry, for the good of
the habitat of our country, for the good of the witcflife of our country. All these effarts wif{ add
to the beaut}r of our nation and prouide habitats for mi[(iQns of birds ancf f�sF�.
Second, we wiil improve tF�e quality o# ar�other mitfion acres of existing wetlands thraugh
expanded public-private effor�s, such as tlte Inferio€ Deparfinent`s Partners far �ish and
WiVdlife Program. { know we've got some peop[e from Fish and Wildtife here today. t want to
fhank you fac senring yau country so admirab(y. ! appreciate yaur serrr�ce_ (Applause.}
� well, we will use NOAA's Coastal Wetiands Pianning Frotection and Resforation
ragram_ ! know we've a[so gc�t NQAA representatives here, t�Q. ( ttrank yQU for eoming. An�
thanks for your good work. (Apptause.)
Too many weUands are degradecf and can no langer support heatthy wi[dlife papu[atians, so
they need to be resfored to F�ealth. [n other �rords, they need to be nurtured; they were ance
wetlands areas, and they nee'd to be nurtured bacEc ta be a wet{and.
Tamarrow, t'rn gaing dowrn ta Ftorida. i'll be seeing Brather. Plt be glad ta give hirt� your best.
(Laughter.} Ancf we're going ta go to the EvergEades. tt's a great weftands area. The prob[err
is, is that the wettand — the Everglades have been invaded by a— by certain plant species,
nan-native piants that are gaing tc� ehoke out the wetta�ds.
Ancf so one af the things we`re going to do is to encourage programs that rtvil{ remave these
irtvasive species sa that native vegefafian eart refurrr and the wettands eact be revital'szed. [n
other words, we can restore wetEands so they f�nction better, so they functian as t[�e
A(rr�igFtty wanted them to functian in the first p(ace. As they becc�me hea[thier —(aPP[ause.}
Anct finalCy, we will protect art additionat one mitlian acres of wet[ands that are currently at
� by increasing grants far land profectivrt programs ar�d E�y r�aking it easier fo� €arEners
d other 4andowners to participate in these prvgrams. We'ft encourage these tandowners t�
p[ace easerrtents on their v�retlands, on the wetland partian of their praperty, sa that migratoi
birds ean rest on their [ortg joumey. In other words, with proper government paticy, we can
encourage proper habits by private fandowr�ers to understand that they can do a better �ab
http:!/www.whitehouse.gc>v/newstreleasesl2004/fl4tprinf12004Q422-4.hfm2 � �� 2/271
President Anuounces Wetlands Inifiative on Earth Day
with their land.
Page fi oi 6
�b�36�
� not on! im rovin the (ands -- the �
We !! dv the ducks and other bicds a good tum by y p g
wettands, but alsQ the (ands near ttre wettands. [t's one tf ta ha�e a good wettand, but
tF►ey`ve got fo have a piace for the ducks to nest, as we[i. And so the program is to — is to be
wise about the incentive programs we put in piace. t`m ecinf�dent these measures wilt be not
anty appreciated by peopt�, t�ut by birds. (Laughter.)
Ta meet the goat of wetland expansior�, the govemment must eorr�mit rrtoney, and rr��
administratior� is prepared t� da sa. The first thing we've dorte irt the — 2Q{Y2, E signecf the
farm bitt. And one of the mast important as�ects af the farm bitl was the canservation tittes. tt
was a sign�cant expansiQn of federa( money avai[able ta encourage pea�le to �xpand areas
of their farms and ranches, fike we�lands_
And secandty, the budgef i proposed — or sent to Cangress, propases to spend $349 �niltion
on two key wetEands programs, which is an increase af mace than 5Q percent since I first
toa[c office. TFtese monies `nritt he[p. These �onies witt pravide pr€�per incentive f€�r gaad
conseroation rneasures.
But the thing f thirtk is very importanf ta empFtasize #tere is fE�at goad conservatian and good
stewardship witE happen when peap[e say, [`€n just not gc�ing ta rety upQn the goverr�rne�
be the svtution to the probtern. (Apptause.} t've come here because this is a great exam��f
peop[e seizing th� initiative; a great e�carr�pfe 4f where the gaverr�ment ca€t help, bt�t not
sfand En the vreay of eommon-sense pQticies tha� �rit! matce a signif�eant diff�ence ta the
wet4ands and fhe native speeies.l�nd it sends a cEear signat to everybody e{se around our
country that if you wanf to be a responsibte citizen, da samething abaut the qua(`�y af tFte Cife
in fhe community in w[zich yau tive_ (Appfause_}
ft's my honor to come here today to eelebrate this fantastic project; to re�nind our fettow
citizens that we att have got responsibi[ities; to dec�are tE�at the federa! gavemrnent has set a
new, imperrtant goaE of increasing the net — the wet4ar�ds att across America; and to ask
God's btessings on tf�is beautiful part of the wor[d ancf the peopte who (ive here.
Thank you ail #or coming. (AppEause.}
EN� '[2:33 P.M_ EE3T
Return to this articte at:
hft��//wvvw whitehause ctovfnews/releases{2UQ4/04f2QQ4Q422-4.hfmt
��� ��
sh�s doaa+�se� _ -
kttp://www_whifehouse.govinewsfreteasesf20
�
�
`�
2I27fOf
�WS Wetlands Defigition
Q�����
l�a�iana� V�etlan�.s I�ve�tary
�
:.� .�.t ,: - s
�ervice �et�ands F'}e�nition
Page 1 of i
The Serviee`s wetiands definition is acioptecf from the Service publicatiort
"Classification af Wetland� and Deep�vatet- Habitats of the United �`tates. " "i n general
terms, wetfands are lands where saturafion witit wafer is fi�e clominant facfor
determining the nature of sail cleveloprr�ent and the types af plant and animat
communiti�s iivirtg �n the soil artc! or� ifs surface. The singfe feature that most
wettands share Es sait or substrate that is at least periaclieaEly saturated with or
couered by wafer. The water creafes severe physioiogical prot�lems far a(I
� an�sy�����c��i�i�a��`�er�����$�t� �k}�'��r�'a�cin
���� � here the water table is usually at or near the surface or the land is
DE� ���� sha�low water. �or purpvses of thas elas,s�eatio» wettands must
ave one or mare of the fallowing three attributes: (Ij at teast periodically,
the land sup�art,s pred�rtninantly hydrerphytes; (2) the substrate is
predomdnantly undtained hydrie soil; as�d (3) the substrate is nansodl arad is
saturated with water ar eovered by shallow water at so»ee time during the
gtowxn,����t�e�'��� �'�'De � ater Habitats of the United States
Y
Lewis {Ul_ Cawardin, U.S. �ish a �td[ife �en � �t ( arth�rrt Pra�€�e V�[fciiife Research
V�iIIIC �/C�lit�SlQ��
Virginia Carter, t�.S. Gec�l+oc�iea4 Sunrey, Reston, �lirginia
Francis C. Golet, Department of Natural Resourees Scier�ce, University of Rhode lslane
Kingstor�, Fil, and
Edward T. LaFtoe, U.S. hlatianal Oeeanographic and A#rr�asphenc Administration, Offic�
Wettartds Mapper � Wetlan�9����1�r���c����� {�ttand Cc3des & Qefinitio�
Wetfand PFants � Weflaads Sfatus and Treri2�t�F�tfalfis � Regiansl €3ff�ces } Kids and Educator�
U.S. i3epartrnent af fhe interior,�� ��nt��tVcf�Eife Serrriee, O�ce of Biatogicat
�
Services, Wasi�ington, E1C
FWS/OBS-79/31 December 1975
�
��
http:(/wvvw.fws.gav/awifde�nitian.htm �
NWI �Talues of Wettands for F[ood and Stonn Surge Atfenuafion
� ♦ _ . � .
I +
_. �
_. �
� �� �:
v �_; ,
"_ ,,. �: a :
Page I of �
Va�ues af Wetlands far Flc�od Starage and Storm
Surge Attenuation
Wetlanc�s provide many functions that are vatued by peaple. Tkese functions (and ttzeir
values} iticlude: surface water stc�rage (�Iac�d contrvl�, shareline stahiliza�ion (wave
damage gratection/shoretine erosion con4rol), streamflow maintenanee (�nai�taining
aquatie habitat and aesthetic appreciatio� opportunities}, g�'QUnc�.v�rater recharge (some
types replenish water suppfies}, sediment removal and nutrient eyeling (water quali
protectian), suppaxti�g aquatic produe�ivity �fishing, shellfishing, and waterfc�wl
hunting}, production af trees {timber harvest}, production of palatahle herbaceous
grawth (livestock grazing ax�d haYing}, prctductiQU af peaty sails �eat harvest}, artd
provision of plant and wildlife habitat (hu�ting, trapPing, plant/wilc�lifelna4ure
photography, naiure abservatio�r, �d �esthefics}. SQme ofthe "values" are attained at
the expense of natural wettands, such as peat mining, farmiug �e.g_, cranberry
produetia�), and �imber harvest, att�tough the I�.tter can return to a mare natural state
depending an site-specific silviculfural practices.
Destntcfian of wetlands etiminates or severeiy minimizes t�eir values. Drainage of
wettands prevents surface water stc}rage aud reduces their water qualiiy enhancement
functivn, while accelerati�tg the ftaw of water daw�siream which may eause i�cre�sed
flaad da�ages_ Wetland fiiliug daes likewise as weli as destroying vita� habitats for
native fish anc� wildlife species. T�e vast majority ofwetland benefits accrue to the
generat public which makes it important to conserve these va�uat�le nat�ual resvurces.
More. _.http.lfwww.fws. gavinortheastlWetlandsf
Wetlands functian as natural spanges that trap and slc�wiy re�ease surfaee water, ra�
s�owmelt, grounclwater a�d floc3d waters. �x�es, rc�vt mats, �d ��hher we�land
vegetation alsQ slow the speed offlood waters and distribute them more slowly over
the flaadplair�. This carnbined water storage an brakit�g aetion lowers flvad heights, and
>tp=lfwww_fws.govlmvefstormvatues.htm �� 2127106
�al �V�t�anc�s In�entar�
1�iWI Valu�s of Wetlands for Ftood and Storcu Surge Attenuatioa
Ob-363
Fage 2 of 2
� uces erosion. Wettands withiu and dawnstream of urban areas are partzcularly
luable, counteracting the greatly increased rate and volu�ne af surfaee- water runoff
from pavement and buiidings_ The holding eapaeity af wetlands helps co�trol floods
and prevents water Iogging of crogs. l'feserving a�d restorit�g wetlands, together with
other water retentian, ca� aften pravide the Ievel of flaod co�tral atherwise pravided
hy expensive dredge Qperations and Ievees. 'The bottamland hardwaad- riparian
wetlands along the Mississippi River once stored at Ieast 64 days of floc�dxrater. I�ow
they store only 1� days becanse mast �tave been filled or �rained.
Reference: U.S. Environmental Protectio� Agency. 1945b. America's wetlands: 4ur
vital link between land and water. O�ce af Water, O�ce of Wetlands, Oceans and
VtTatersheds. EPAS43-K-95-041.
'Tl�e ability of wetiands to control erosion is sa valuable that same states are restoring
wetlands in eoastat areas ta buffer the stvrm surges fra�n hurricanes and trc�gical
storms. Wetlands at the margins af lakes, rivers, bays, aud tke oeean pratect shorelines
and stream banks against erosia�. 't�t�etland pta�zts hold the soil i�t ptace wi��€ their raats,
orh tlze energy of waves, and break up the flaw af stream c>r river eurrents.
ore...http:/Iwww:epa.govlowow/we�iandst
Wettands Mapper ( Wef{ands Dafa ( Wefiands Metadafa and Map SearcFt j V�(etEand Godes &[}�nitions
We�land Plartts � Weflancfs Status and Trends � Publicafions ( Regiona! Offiees � Kicfs and Edercafars (
About tJs � Contacf Us
�
��
�
http://www.fws_gov/nwi/storcnvatues_htm Z�
Secfiort
,' � . � 7
3 "
Faga 1 of 6
[Code of Federal Regulations� �
[Title 44, Vo�utae Ij
[Revised as of October l, 2003]
From the U.S. Gavernment Printing �ffiee via GPO Aceess
[CITE: 44CFR9_4j
[Page 82-85�
TI�LE 44—EMEFt�ENCY MAL�IA�EMENT ANB ASSIS`I`ANCE
CHAPTER I--FEBER�I, EMERGENCY N3AI�AGEI�IEI3`F AGENCY. DEPAI7�MEI3T OF HOMEI,F
SECFIRITY
PART 9--FLOOI}PLAIN MANAGEMENT �1NI� PRf}TECTIE3N OF WETLANI3S--Tab�e a� Cc
Sec. 9.4 Befinitions.
The following definitions shall apply thrauc}hout this regulation.
Action �neans any actian or activity inclu@ing: (a} Acquiring
managing anci disgosing of FederaZ Iands and faeilities; (b) grova c
federally undertaken, financed or assisted cons�ruction and
improvements; and (c� conetuc�ing �`ederal aetivz�ies and programs
affecting land use, including, but not limitecl to, water and related
C C�'age 83] �
land resources, planning, regulating and licensinq dC�1Y1.t12S
Actians Affecting ar Affectec� by Floadglains or Fletlands Faeans
actions whieh have �he potential to res��t �n the long- or short-tern
impacts associatecl with (aj the occupancy or modification of
floodplains, and the direct ar indirect support af floac#plain
development, Qr (b) �he destruetian artd modification af �rretlanc�s and
direct or indirect support of new construetion in wetlands.
Agency means the Eederal Emergency Manac}ement Age�cy f�'��).
Agency Assistance fneans qrants for prajects or p�anning activitiE
loans, and a11 otYter farms of financiaZ or technical assistance provi
by the Aqency.
Associate Direc�or �aeans the head of any. 4ffice or Admin�str�or
=he �'ecleral Emergency Management Agency, who has programmatic /}
°espansibility for a particular action. � �
Base Flaoc�rneans the flaoc] wh�eh has a one percent ehance af beir
�qualled or exceeded in any qiven year (also known as a IQQ-year f2oc
f.tp://a257_g_akamaitech.net/'T/257/2422(Q4nc�L0(Y32500fedockeE.aECess.gpo.gov/eFr 2003/octc�tr/44efi9.4.h.._ 2/25/06
Section Page 2 of E
4 N J d
F
i� '»�°.� — i ';� �
s term is used in the National F1ood Insurance Program (NFIP} to
dicate the minimum level of flooding to be used by a comm�nity in :
floodplain management regulations.
Base Floadplain means tl�e 1Q0-year flaoc}plain {ane percent chanc�
floodplain).
Coastal High Hazard Area means the'areas subject to high ve3.ocit
waters including but not limited ta hurricane wave wash ar tsunamis.
a Flood Insurance Rate Map (FIRM), this apgears as zone �71-30, VE or
Critical Action means an action for which even a s2ight chance o
flooding is too great. The minizaum floodplain of concern �or critica
actions is the 50t3-year floadplain, i.e., critical ac�ion flaadplain
Critical actians include, but are nat limited to, those which create
extend the useful life of structures or faciliti.es:
(a) Such as those which proctuce, use or store high�y volati�e,
flammable, explo_sive, toxic or water-reactive materials;
(b} Such as hospitals and nursing homes, and housinc3 for the
elderly, wY�ich are likely to contain occupants who may nat be
sufficiently mobile to avoid the loss of life.or injury during flooc
storm events;
(c) Such as emergency aperation centers, or data storage center�
hich contain records or services that may become lost or inoperatiti
during flood and storm events; and
(dJ Such as generatinq p�ants, and other principaZ points of ut-
lines.
Direct Impacts means changes in flooclplain or wetland values anc
functians and changes in the risk to I.ives and groperty caused or
induced by an action or related activity. Impacts are caused whenevE
these natural values and functions are affected as a direct result -
action. An actian Hrhich wauld resnit in the di.scharge of palluted s
waters into a flaodplain or wetland, for example� would directly af
their natural values and functians. Constructian-related activities
such as dredqinq and �zllinq operations with�n the floodglain or a
wetZand would be another exazapZe of impacts caused by an action.
Director means the Birector of the Federal Emergency Managemen�
Agency (E`EI�A} -
Emergency Actions means emergency work essential to save lives
protect propert� and public health and safety performed under secti
305 and 3C}6 of the I3isaster Relief Act a�'1974 E42 U.S.C. 5145 and
�163. See 44 CFR part 205, subpart E.
���� Enhance means ta increase, heighten, ar imprave the natural anc
beneficia�. value� assaciated with wetlands. ���
Facility �eans any man-macte or man-placed item other than �
structure.
http:f/a257.g.akamaitech.netl7/257l7A22l04na�2d031500/edoeket.aceess.gpo.gav/cfr 2003/csetqtr/44efr9.4.h... 2f2°
� �
Section Page 3 of 6
�b-3b3 �
FEMA means the Federal Emergency Management Aqency.
FIA means the �'ederal Insurance Administration.
Five Hundred Year Ploodplain (the 500-year floodplain or 0_2 perc
change floodplain) means that area, including the base floodplain, wY
is subject to in�zndation fram a f�aod having a 0_2 pereent chance o�
being equalled ar exceeded in any given year.
Flood or flooding means a general and temporary canditian of part
or camplete inunclation af narn�ally dry Iand areas fram the av�rflaw c
inland anc3/or tictal waters, and/or the unusual anct
[[Paqe 84�j
rapict accumulation ar runoff af surface waters fram any source.
Fload Fxinge means tha�. portion o� the flooclplain outside of the
floodway (o�ten re€erred ta as "floc�dway fringe" }.
Flood Hazarcl Bounclary Niap (FABM) means an offical map of a
community, issued by the Director, where the boundaries of the flaod,
muctslicie (i.e., mudflow} and relatect erosian areas havin.g special
hazards have been designated as Zone A, M, or E.
Flood Insurance Rate Map (FIRNF) means an official map of a�r
on which the D�reetor has cielinea�eel both the special hazard area r
the risk premium zones applicable to the cammunity.
Fload Insurance Study (FIS} means an exami�ation, evaluation and
determination of flaod hazards anc�, if approprzate, correspanding wat
surface elevations o� an examination, evaluation and determination o1
mndslide (i.e., mudfl.ow} ancllor flooc3-relatecl erosion hazards.
Flaociplain means the lawland and relatively flat areas ac3joining
inland and coastal waters including, at a minimum, that area subject
a one percent o� greater chance of floociing in any given year. Where�
in this regu�ation the term " flaodpI.a�n " is used, zf a critica� act
is involved, " floodplain " shall mean the area subject to inundatior
from a fload hauing a 0.2 percent chance of accurrinq in any qiven yF
(500-year floadplain}_ "�loodplain " does nat inelude areas subject
only to mudflow until FIA adopts maps iclentifying "M " Zanes.
Floodproofing means the madification af individual structures anc
facili.ties, their sites, and their eontents ta protect against
structural failure, to keep water out, or to reduce effects of water
entry. �
Floociway means that portion af the floodplain which is ef� e
carrying flow, within which this carrying capacity raust be preser
where the flood hazard is qenerally highest, i.e., where water depth:
and velocities are the greatest. It is tt�at area which pravides for t
discharge of the base flood so the cumulative increase in water surf�
http:(Ia257.g.akamaiteefi_aef17l257/2422/Q4nov2�(33150�/edocket_access.gpo.gov/cfr 20€t3(octqtr/44efr4.4.h.._ 2l25/06
Section
S' i
F
" Page 4 of 6
Ob-363
� ation is no more than one foot.
Functionally Bepenctent Use means a use w�ich cannot perform its
intended purpose unless it is located or carried out in c2ose proximi
to water, (e.g., bridges, and piers).
Indirect Impacts zneans an indi.rect result of an action whenever t
action induces or makes possibZe related activities which effect the
natural values and functions of flaociplains ar wetlands or the risk t
iives and property_ Such impacts occur whenever these values anc�
functions are potentially affected, either in the short- or lanq-terr
as a result of undertaking an action.
Minimize means to reduce to the smallest amaunt or degree passib=
Mitigation means all steps necessary �o minimize the potentially
adverse effects of the proposed action, and to restore and preserve '
natural and benefacial fiaodp�ain values and to preserve and enhance
natural values of wetlands.
Natural Values of Floadplains and Wetlands means the qualities o
funetions serveci by floodplains and wetlands which inelt�de but are n�
limited to: (a) Water resource values (natural moderation of floods,
water quality maintenance, groundwater recharqe}; (b) living resourc
� ues (fzsh, wilcil�fe, p2ant resaurces and habitats}; {c} cultural
esource values (open space, natnraZ beauty, scientific study, outdo
education, archeological and historic sites, recreation); and fd3
cultivated resource values (aqriculture, aquaculture, forestry}.
New Construction means the canstruction of a new structure
(including the placement of a mobile home} or facility or the
replacement of a structure or facility which has been tota�.ly clestro
New Canstruction in Wetlands includes draining, dredqing,
channelizing, filling, dikinq, imgounding, and related activities an
any structures ar facilities begun ar authorized after the effective
dates of the Qrders, Nlay 24, 1977.
Orders means Executive Orders 11988, Flaadglain Management, and
11990, Protection of V�etlands.
Practieable means capable of being done within existing constrai
The test af what is praeticable depends
[[Page 85�]
���
upon trie situation and includes consideration o� all pertinent factc
� h as environment, cast and technalogy.
Preserve means to prevent alterations to natural conditions and
� aintain the values and functians which operate the floodplains or
wetlands in their natural states.
Regional Director means the Regional Director of the Federal
http:f/a257.g.at€atuaiteck_nefl'7/257/2422/Q4nov2Q031500%dc�cket.access.gpo.govlcfr 2003toc�Fr/44efr9.4.h._. 2l25/�
._.....� ..�....�.�y.........�., +y.......� i.vi .....�. i��.yivii iai vrai.i�.sa aiu.'fc-s. tJ c�l.�.iit� v1
the Disaster Recovery Manager when one is c3esignated.
Regulatory Floodway means the area regulated by ��ra��;� �tate oi
local requirements to provide for the discharge of the base floo sa
c�unulative increase in water surface elevation is no more than a
designated amount tnot to exceed ane foat as set by the NationaZ oc
Insurance Proqram}.
Restore means to reestablish a setting ar enviran�nent in which tY
natural functions of the floodplain can again operate.
SLPS means the State and Local Programs and Support Birectarate.
Structures means walled ar raofed buildings, incl�udinq �nabile hon
and gas or liquid storage tanks.
Substantial. Impravement means any repair, recanstructian or athes
impravement of a structure ar facility, which has been etamaged in exc
of, or the cost of whieh equals or exceeds, 50a af the market value c
the structure or replacement cost af the facility (including all
" public facili�ies " as define@ in the Bisas�er Relief Act of 1974}
before the repair or improvement is started, or (b) if the structure
facility has been damaged and is proposed to be restoreci, befare the
damage occurred. If a facility is a� essential. link in a larger syste
the percentage of damage will be based on the relative cast of repaix
the damaqed facility to the replacement cost of the portion of the
system which is operationally dependent on the �acil�ty. The te
" substantial improvement " does not include any alteration af �
structure or facility listed on the National Register of Histor�c �
or a State Inventory o� Histaric Places.
Support means to encourage, allow, serve, or otherwise facilitate
floodplain or wetland clevelopment. Direct supgort results from actioi
within a flaadglair� or wetlanc3, and. incii.rect snppart results from
actions outside of fZoodplains ar wetlands.
Wetlancis means those areas which are inundatect or saturated by
sur�ace or grouncl water w�th a frequency suffi.cient ta suppart, or t]
unde� noriaal hydrologie conditions does or wouZct support, a prevalenc
of veqetation or aquati.c life typically adapted for Iife in saturatec
seasonally saturateci soii conctitions. Examples of wetlands inelude, �
are not limited to, swamps, fresh and salt water marshes, estuaries,
bogs, beaches, wet meadows, slouqhs, pathales, mud �Iats, river
overtlows and other similar areas_ `£his c3efinition includes those
wetlands areas separated from their natural supply of water as a res�
of activities such as the construction of structural flood pratectio�
methods or salid-fill road beds and activities such as mineral
extraction and navigation improvements. This definition is intended
be cansistent caith the definitian utilized by the U.S. Fish and �ld:
kttp:/la257.g.akamaitech.neF!"!l257lZR22!(?4nodLQa315(IO/edocket.access_gpa.gavlcfr 2003toctqtr/44efF9.4-fl--- 21�t
f��
l
5eetion
�
•
�
�
Page 5 of 6
Ob-�6�
��
�
$ �
Section Page 6 of 6
� Ob-3b�
Service in the publication entitled Classificatian of Wetlands a�De
Water-�Fabitats of the F3nitect States (CQwardin, et al., 19777. �
[45 FR 59526, Sept. 9, 1980, as amended at 47 FR 13149, Mar. 23, 198�
5tl FR 40006, Oct. 1, 1985}
e
�
` �
t�
htfp:((a257.g.akamaitecfi.netlT/257/2422/04no�/ZOQ3�500%dacket.access.gpo.govfefr 20�3/octqtr{44cfi9.4.h... 2125/Of
Section
�
`Code o� Federal Rec3ulations]
[Title 44, Valuiae 1J
Q,b-363
[Revzsed as of October 2, 2Q03]
From the I3.S. Government Printing p�fice via GPO Access
LCIT�: 44CFR9.9]
[�'��e 92-93}
�
TITLE 44--EMERGENCY MANAGENIENT ANB ASSISTANCE
Pa�e 1 of ?
�
CHAPTER I--FEDERAL EMERGENCY MANA�EMEI�IT AGENCY, DEPARTNIENT 0� HONFEL;
SECIJRITY
PART 9--FLOOBPLAIIV MANAGEMEIVT AA�D PROTECTIC3A7 t}F FRIETT�ANBS--TaXsle of
Sec. 9.9 Ar�alysis and reevaluatian of practieable aTternatives.
(a) Purpose. (2j The purpose of this section is to expand upon t:
ectives set aut in Sec. 9.6, of this part, ir� order ta clarify an
phasize the Orders' key requirements to avoid flaodglains and wet2
unless there is na practicable alte�native.
(2) Step 3�s a preliminary determinatian as to eahe�her �he
floodplain is the only practieable Ioeation for the action. It is a
preliminary determination because it carnes early in the deci.sian-mak
process when the Agency has a Iimited a�aount of in�ornfation. If �t i
clear that there is a practicable alternative, or the floodplain or
wetlarid is itself not a practicable locatian, FEMA shall then act or�
that basis. Provided that �he Iocatzan outside tY�e flaodplairt ar wet
does not indirectly iFttpact floodglains or wetlands or suppart
development therein (see Sec. 9.10}, the remainir�q analysis set aut
this regulation is not required. I� such locatian daes indirectl�y irr
fZooctplains or wetlancls or support development therein, the remainir--
analysis set out by this regulation is required_ If the preliminary
c3eter�cination z.s to aet in the floodplain, E`EMA shall ga�he� tY�e
additional information required under Steps 4 anct 5 ancl then reeval �
a11 the data to determine if the floodplain ar wetland is the only
practicable alternative.
(b} Analysas of practicable_,alternatives. The Agency shall ident
evaluate practicable alternatives ta carryinq aut a propased act
in �loodplains or we��ands, includinq: .�/��
(1} Alternative sites outsicle the floodplain or wetland, �
(2y Alternative actions whieh serve essentially the same purpos�
http:l/a Zt}f}3lcxrtc�� Zf251C
Section
Page 2 of 3
05_.36�
the proposed action, but which have less potential ta affect ar �
a�fected by the floodplain or w�tland�; and �
(3} Na actian. The flaodplain and wetlanci site itself must be �
practicable locatian in Iiqht of the factors set out in this section.
(c} 'Fhe Agency shall analyze �he fal�owing factors �.n determininc
the practicability of the alternatives set out in paragraph (b) of tr
section:
(1) Idatural environment (tapography, habitat, hazards, etc.I:
(2j SoEial concerns {aesthetics, historical and cultural values,
land patterns, etc.};
(3} Economic aspects (costs of space, ccrnstxuction, services, anc
reZocation}; and
(4) Leqal constraints Edeeds, leases, etc.}.
(d} Actaon fo�.Iawing the ana�.ysis of practicable a�ternatives. (1
The Agency sha11 not Iocate the proposeci action in the floodplain or
a wetland if a practicable alternative exists outside the floodplain
wetland.
(2} For critical actions, the Aqency shall not locate the propasE
action in the 500-year floodplairs if a practicable alternative exist�
outside the 5�0-year floodpla�n.
(3).Even if no practicable alternatiYe exists outside the fl pI
or wetland, in order ta carry out th.e TC�1oR the flaodplain or we ar
must itself be a gracticable location in lzgh� a� tY�e rev�ew rec�irec
th�s section.
(e) Reevaluatian of alternatives. Upon deterFaination of the impac
of the proposeri action to or within the �loodpl,ain ar we�Iand ar�c3 of
what measures are necessary to comply with the requirement to minimi�
harm to and within floodplains and wetlands (Sec. 9.11), �EMA shall:
(1 } I3etermine whetl�er :
(i} The action is stilZ practicable at a floodplain or wetland s�
in light af the exposure ta floact risk and the ensuing disrugtian of
natural values;
(ii) The floodplain or wetland site is the only practicable
alternatzve;
(iii} There is a potentia� f�r 1i�itinq tY�e action to increase tl
practicability of previously re7ected non-floodplain or wetland site:
and alternative actions; and
(iv) I�Iinimization o�" harm to or within the floQdplain can be
achievect usinq all practicable means.
(2} Take no action in a floadplain nnless the impartance o� �e
flaodplain �( �
[[Page 33�]
\ \`
httplfa257_g_akamaitech.nzfP712S7l242?J04nodLQ0315Q0ledocket.access.gpagovlcfr 2003loctcEtrt44cfr4-9-h--- 2125tOf
Section
�
�te clearly outweighs the requirement of
(i} Avoid direct or indzrect sugpart
(ii} Reduce the risk of flood loss;
�
0�-3��
,�
Page 3 of 3
�.0. 11988 ta:
of fl�oodplain develapment;
(iii) Mini�nize the impact of floods o� hu.�aan safe�y, health and
welfare; anc3
(iv} Restore and preserve flood�lain values.
(3) Take no action in a wetlanc3 unless ttze impo�tance of tlie wet=
site clearly outwe�ghs the requirements af E.O. 11990 ta:
(iJ Avoid the destruction or raodification of the wetlands;
(iij Avaict direct or indirect suppart of new constrnction in
wetlands;
(iii} Minimize the destruction, loss or degradation of wetlands;
(iv) Preserve and enhance the natural and beneficial values of
wetlands.
(4) In carrying out this balancing process, give the factors in
paragraphs fe}(2} and (3) af this section, tt�e great weight intended
the Orders.
(5) ChoQSe the " no action " azternativ2 where there are na
cticable alternative actions or sites and where the floadplain or
tland is not itself a practieable alternative. In �aking �he
assessment of whether a floodplain or wetland location is itself a
practicable alternative, the practicability of the floodplain ar wet
loeation shalZ be ba�aneed aqainst the practicability af not carryin
out the action at all. That is, ev,en if there is no practicable
alternative outside of the flaodplain or wetland, the flaodplain or
wetlancl ztself must be a practieab�e locatzon in order far the actic
be carried out there. To be a practicable location, the impartance c
carrying out the action must clearly outwei.qh the requirements af tY
Orders listed in paragraphs (e}(2} and Ee?(3) of this section. Unle�
the importance of carrying out the action clearZy outweighs those
requirements, the " no action " alternative shall be sel,ected.
{6) In any case in whieh the Regional ]3i�ectar Ycas selectecl the
action " optian, FIA may not provide a new or renewecl cantract of f=
insurance for that structure.
Ef�ectzve Da�e I�Iote: At 45 FR 79Q70, Nov. 28, 198�, Sec. 9.9{e)
was temporarily suspencieci until further notiee.
�
`��
t
http://a257.g.akamaitech.ned7/257/2422/04nov2003250Q{edocket.access.gpo.govlcfr 2003foctqtd44cffl.9.h... Z/25_
Canscions Choice. Meigs Field, Ctean Air, and Illinois Action o � _ 3 6 3
Fage t of 4
searcn cr„z site: �--'
pConscious EnEigStenn€ent Pu6fication�
HONf i.�'EWS ( DIRECT4RY C C�:lEN43AR ( f1+SStFfEG €.4�7YER�TISE f ARCrGYE k FWYACY t iSBFXi'(?;S I SUBAh!�QQ;b f SETE.Nv1P
Apri! Za4f i News of the Earth
Mei�s Fie�d, C1ean �4ir, and Iil�nois �tctivrt
�y �s��� s����s�t���
In his 1349 Pfan oFChrcago, the architect Dartle! Bumhem advacated the creation o€ Five
pertinscatas a[ong the Chicaga lakeshare For pubtic parkiand. Due ta iack of fund€ng, on€y one
was buifE — FtortherFy Isiand, which para((e1s Ehe Fakeshore docvntown far abaut fhree
quarters o€ ths Eeagth of Grant Park (ninety-ane acres in aFt}, €rom the museum campus at
22th Street ta McCor�nieEc Piace, endastrtg Suretham Ha€hor_ If you didn't realize Northerly
Istand was a park, yon shauTd�t`t #e� too bad, be€ause 6t hasn't served as one since 5945,
wl�en the Chicago Park District ieased t3re property to the Chicaga Department of Pubtic
Works far an aSrporE. "ihe fease was to East fifty years, at �3 per year. The air�sort hecame
knowrt as Meigs Fetd.
�dflen ttre lease e:cg[red [n i996, 4�ayor Daley suggested ctosing IKeegs Fe{d a�d canvarting
Northerty Is[arad tn paatdand. Unfarhsnate[y, Fhen-gove€nar 3m Edgar ftacl a[her ideas, and
sued the aty to keep T9eigs fi closing (two of the main gmups who e�se tieigs Feld are
govemment o�ciats fEying to and from Sp€ingfiefid and private pi}ots}, Ztarious organizations
weighed in en bath sides, inc#udbng the state fegistature; tempers f(ared, and a lot �f inK was
spiited. Ya ea�ty 1947, f3atey artd Edgar reached a compromise: tdei4s wouEd remain open for
ftve years, and af#er that, the sfate wcsu€d agree not ta €r�tesfere witfr the eity`s ptans for
No�tfrer�y Zs[and, t3atey said he'd sEidc avsth Ftis park p6ans euen "sF they had tv be de[ayed:
"E`m not gofng to change my rntrtd.... I am firmiy comm�tted to having more open space in
Chicago a�x1 ott tlie [akefronf."
Less than a year from now, the fnaE curtain is due to fiatf on Me�gs �"re[Q: 6iven that the
afrport has been tasing Dassen9ers far years — tlte numbes of passengers usirtg Meigs Fietd
dec!€ne6 fsy 42 percent fram 1484 to 1�6 — fewt peopEe oifcer than teigh[Y-Riacetf sEate
employees and weaFiity pifofs �ho c�wn tf�eSr own plasfes wilt sf�d a tesr �rchea it ctc>sas. Gcvert
the scarciEy of open space in dawntocan Chicago, artd t+lartherlp Island`s proxirnity to the
museum campus, [}aley`s right that it makes sense to camert the penEnsuta to parkfand.
But wrhat sort o€ park sho�sfd we build an No�ttzerty Isfand? !?efey's p€an, erdorsed in I996 by
tEce Ct�y Cae�nciF and fhe Chicaqo Fark District, irkvatved bui[ding a gark arouctd tfte tftemes of
earth, wat and sky, wfth educationef exhitrits cons�eted in concert svith the neighbacing
Fetd Museum, Shedd Aqvariam, and Adles Pkane[asium. The exhibi�, ptapgruunds, and an
Art Paric wauid ring an apen eneadow; i2th Street Seach wouEd be daubfed in size; and a
lagoart would be created #or year-round fis(ting. DaEey's plans atsrr ceiled.far the Qeatian ot a
seventeen-acre �rairie, arhich vanuEd secve as the siEe for ouemight camping trips Cvr ianer-
c�ty kids, and for a garden that vrauid be accessibfa to ait visifxirs (drawing on the Cfiicagn
Botanic Gardsn's award-w'snning Enab#sng 6arden}, inchsdsng Cfiose arith mob7iEy or vis€on
fmpairments. Even sound would 6e a part of the neut park, with wave naises piped in frcsm
the take.
Last mnnth, the Lake Michigan Federation (Lt re3eased its own visiQn Eor a Northecly Zs1anQ
park. They catEed their proposed park "Sanctuary Pa#nt° because iE wou€d pro�ide a peacefi�t
htEp:!lwww.covsciousehoiee.cc�sni2fHilicel4E
���
�t}€�������
��x.<�tz�,:'� :� v
��a� n��r���+��
`�k����3+F}�
���ft�,
�#f6�f�t
F��tl�r.
�If�
��'d�it�
- _ �� f;�..
_�
6/(l+
Conscious Choiee: Meigs Field, Ctean Air, and IIlinois Action
,
'Fage 2 of 4
06-363
�en not just for Chicagoans lookFrtg to escape the hubbub o€ the city, but fo�-native pEants
• and anima(s and migrating b"srds as aretl. The name atso harks 6ack ta Burrrham's catE for the
fakeshore to be "a haven — an urban sanctuary — far peopte anci nafure.'
In the Lt�F`s vision for Sanctuary FainY, "the land and waterscage {s cam�asecl a� weF�ands,
prairies and dune ridges that mimic the ecosystems before Cnicago`s settSemertt_ Ths
different habitats attract fish, birds, and srrtall mammals. Pfantiags are primarily naiive to the
region and prov€de high-guality habitat fos these cseatures to Foca9e, spawn. nest, and Eind
shelter, white requiring fittSe maintenance..,_ �sitors frarn eround the wor[d ramble over
wettands by �xay of suspended 6oardaraEks, causing na damage to tfte fEorae and fiaunae ar
x
�rvander on "snviting pathways �v'�h accasionaf informatiQn Kiasics and benches. Smeti ha��
are provided Eor chitdren and adu[ts atike ta snorkeE and see Lake Micftigan fish, musse3s, and
other aquatic organisms. StuQents, researchers, neteire enthus�asts, and anyone toaking for
so[ace or to understand Chicago's mosf magnificent resource befase #he cfty existed — the
lakefront — revet in these remarkable surroundings."
7he current airport terminat buifding would be reused for a LaEce htichigan tiuseum, €eaturictg
exhibits on Great Eakes nature, weatEter, and shipwrectcs. Because the park is tocated scr
ciose to the museum campus, and not far from severa€ wortQ-cfass c�niverstties, it wau[cf
serve as both the pectect outdoor educatian area for the museums and as a site for
cooperative research projects on restaratfon and ecolagy. Perhaps mast impartantly; it wau[d
be a trus nature sanetuary — the onty one of sFgniFicant size a{ong Chicago s(aRefrarrt —
sheltering native piants, anirnais, and fish (inctadtng specia[iy caastrucFed undenrruater fish
habitats}, aFld aiso praviding a much-needeci reE�seFi�g po6nt �or some crt the m€�re than five
Eilion son96irds that pass through the Lake Michigan ftyway each year on their migratians
�uth.
Chicago can shosv the wnrid that nature can thrive in a viorkl-dass e{ty," sa9d Carrse 6avis,
co-chair of the Eakefi ont i'as[c Force, Ehe LSM1F's v€r(unteer group that draRed the Sanct�cary
Point g[art. "The pFan buitds an hTeyor !�a{ey's 1496 pian tv est�bEist� Chicago's prominence as
the iead€ng waterfront nature ctty on the gFobe ° If you iika the LMF`s vision for Hartherty
Island, and warit to help make it a rea(ity, You cart contact the tMF, Mayor Qaisy, and the
Chicago Park Distsict (see Resources betaw).
Goad Plews on Ctean AEr, and a F1ew Qpportunity
t*dhen [�re Supreme Court agreed iaet fall to review a federal appeals court npling an the GEean
Air Act together �vith a reiated countersuit, environmentalists feared the warst. Over the past
couple of years the canservative-dam[nated court has seemed increasingiy indined ta limit
Congress's authority over the states — its rece�t ruling tfiat c,rorkers c�tnnot sue states for -
discriminatary practices bartned by the Federat Americans u,ritfi Disabilfties Act is an exce[tent
exarn�le. If the court �ecided ta €otlosv ttzis same trecsd by gc�tting the Ciear� Air Act's
standard-setting procedures, the consequences couEd be dire foc almost every federe[
environmentat taw on the books.
At issue were the EPA's 1997 Natianaf Rmbient Air Qua3ity sEanderds tfl regu#aYe ground-ievel
ozone and �ine gactie4es, which are the prime in9fedEents in srwg and soot, respectivety. The
EPk [tad [iqhterted these stanQards based on the tate� scientific researcEt, v�rhich st€aweQ tteat
doing sa woa(d protect the heaith of up ta 125 mFf€ion at-r�sk Rmericans, inciudi�g 35 mittion
children, as weH as preve�t appraximately 1�,5340 prematura deaEhs and 350,00(T cases of
� ggrevated asthma per year. R coalition of frtdusEry gruups and ihree states [ERichigan, C�FilO
nd West Virginia — alt heavy air pat€uters) sued ta prevertt the rutes from taking effect, and
m 1999, a federa[ appeats caurt ruFed in lndustry's €avov, sayinc} that the EPA ha€f intergreted
the Ctean Air Rct "so €ausefy" thae it had uneonsteic�fianatEq usur�rec3 Congress`s fegis[ative
poever — an anatysis known as nondetegation, vvhich hasn`t been used in (egaf circ3es sinte
the time of the Plew Deal. The EPA appealed the nondetegaEion ruSing ta the U.S. Supreme
htxp://www.consciousehoice.coml2002/ceT
I. � �-i�
• i � �.��
y. �
i.� � ! tr i , .
' R'Y..�
�
CEticaao Healers
Chicago's Holistic
HeaKft Resource
Find Over 290
HeaVing Services!
tt G:*r clr.�getx2zte:s.cam
We Heiu PPH
vetitns
Free Consuft and
Quick response
From Experienced
PPtt Lavryecs
sw.vzpphx�irns,com
Tracfeer
Site ot(e�s
irtfosmation on PPH
and tfre rkug used
to treat it
ramr.Tradeer-
F�b.ocgfFree t�fo
Grow wild
�iscover how to
�srri ycxu backyard
infa a wifdtife
haven.
-rsrsw.maf.a�
Rfivertise anfhis sife
��
� 2/16�
� . - ' .
METROPOLITAN AIItPORTS C4MNIISSION
= PQ + �5 sq�
T
2 } 9
F �
s z
�i t o
n m
Q � N
F
��r o
t �
a � 9 iRPORtS .
February 8, 2006
Minneapolis-Saint Paul International Airport
6040 - 28th Averme South • Minneapolis, MN 5545Q-2799 =
, Phone�(612) 726-8100
Saint Paul Planning Commission
15 West Kellogg Boulevard
Saint Paul, MN 55102
Deaz Commissioner:
I would like to address a number of questions that have arisen during discussions of the proposed
improvements to St. Paul Downtown Airport, also Imotvn as Holman Field. My intent is to provide you
w,ith simple, straightfotwazd information that I hope will address any remaining questions or concems
you may have about the projec�
The infornration is presented in a familiaz question and answer format. It will take only about five
minutes to review all the material. I believe that will be time well spent given the importance of this
project to St. Paul Downtown Aitport, the city of St. Paul and the Twin Cities metropolitan region as a
whole.
A 2005 Economic Impact Study by Wilder Research in October 2005 highlights tfie contnburions of St.
Paul Downtown Airport to the azea economy. The study concludes that Holman Field generates $112
million azmually for the azea economy and sustains 853 full-tmie jobs.
These aze conservafive esfimates; the study does not attempt to measiffe the impact of Holman Field on
business siting dec.isions or to tally revenues azea businesses gain from their ability to use the facility for
their air transportation needs.
What we aze asldng of you is no more than counfless other property owners along the Mississippi River
have requested and been granted before: permission to protect ouz property — in this case one of the most
valuable public transportation assets in the city — from floodmg.
'Pt�ank you for your consideratfon of our site plan application, #006-000725.
Sincerely,
V�ti
t�
Vicld Tigwell, Chairwoman
Metropolitan Airports Commission
�
�
�
�
��
�
The Metropolitan Airpo�tr Commission is an af£smafive aciion employer.
mvwmspairport.com
Reli�ex Aixports: AiAr 4ica .�OXACO53I3TYlBL.AINE . CRYSTAL . FI,YING CLOUD • LAKE ELMO •
SAIIVTPAULDOWNTOWN
�:
�
•
�
�
�b-3�3
St. Paul Downtown Airport Improvement Project
Questions and Answers
Question 1: Will the airport expand as a result of the floodwall?
Answer:
No, the floodwall will have no significant impact on the airport's size, use and character.
• Tke longest runway at 5t. Paul Downtown Airport wiil be 6,509 feet, 202 feet shorter than it
is today. By comparison, the shortest runway at Miuneapolis-St. Paul Intemational Airport is
8,000 feet. For a typicat cargo plaue to take off fu12y loaded, a rwiway of at leasY 10,000 feet
is needed, far mare than is a�ailable at St. Paul Downtown Aixport.
• UPS and FedEx distribution centers are located at MSP, so even if St. Paul Downtown
Airport could accommodate their aircraft, it would be inefficient and counterproductive to fly
cargo into St. Paul Downtown Airport, huck it to MSP for sorting, and truck it back to
Holman Field for carriage to its destination.
• St. Paul Downtown Airport has only enough developable area for about a dozen more aircraft
hangars, only half of which would be in an area directly benefited by the pioposed floodwall.
The point of the floodwall is to protect existing infrastructure, not to eapand it.
• Aircraft operators at St. Paul Downtown Airport have indicated construction of a floodwall
wouid not lead to changes in the type of aircraft they use.
• St. Paul Downtown Airport is has only about one-sixth the acreage of Minneapolis-St. Paul
Intemational Airport, and neazly all the reliever airport's developable property is already fully
urilized.
�
l�
�����
St. Paul Downtown Airport ImprovementProject
Questions and Answers
Question 2: Is it premature for the city to take action?
Answer:
No, pla�ning for this pmject has been underway for a number of yeats, and we aze at a point in
which permits aze needed so we can begin construction in 2006. The environmental assessment
has been ptepazecl, reviewed and approved, and funding for the ptoject identified, so it is now
time to seek the needed permits from the city of St. Paul.
Environmental Review �
• In addition to the permits being requested from the city, technical permits aze currently under
review by the U.S. Army Corps of Engineers and the Minnesota Depattment of Natural
Resources, and the Miunesota Pollution Control Agency. Those permits are e�cpected to be
issued in Mazch 2006.
• The Department of Natural Resources will not issue a permit for mussel relocation until
construction is ready to commence, so a pemrit from the city is a prereqwisite to our
obtaining this ANR permit_ If musseLs are found in the excavation area, they will be
identified and properly relocated prior te construction.
Fundin$
• On February 7, 2006, the Federal Aviation Administration provided the Metsopolitan
Airports Commission (MAC) with a letter pledging $20.1 million to the airport improvement
project. Please note: FAA funding, together with funds from the Minnesota Depaziment of
Transportation, 3M, state bonding, and the Metropolitan Airports Commission, will cover all
eosts of the airport improvements. Although St Paul benefits economically from the airport,
the eity will bear none of the cost ofthe improvements.
• With the FAA pledge in hand, on February 8, 2006 the MAC's Finance, Development and
Environment Committee recommended proceeding with the airport improvement proj ect.
�
�
�
�
�
Ob-3�,�
�
�
�
�
St. Paul Downtown Auport Irnprovement Froject
Questions and Answers
Question 3: Will the dike increase flooding upriver from the airport?
Answer:
Absolutely noY. The U.S. Army Corps of Engineers, Federal Emergency Management Agency
and Minnesota Department of Natural Resources all have thoroughly reviewed and approved the
project's hydraulics.
On January 31, the Federal Aviation Aduiiuistration also issued a"Finding of No Significant
Impaet/Record of Decision" on the final environmental assessment for the project. The FAA
concluded the project is consistent with exisring env[ronmental policies and objecrives set
forth in the National Environmental Policy Act of 1969 and will not significantly impact the
quality of the environment.
• The Final Envirunmentat Assessment Report included response 2etters from:
Unitad States Environmental Protection Agency
United States Department of the Interior, National Pazk Service
Minnesota Department of Natural Resources
Miauesota Department of Transportadon
Minnesota Historical Society
Minnesota Pollution Control Agency
Metropolitan Council
Representative Sheldon Johnson and City Council President Kathy Lantry
Friends of the Parks and Trails
Canadian Pacific Railway
Burlington Northern Santa Fe Railroad
Tom Dimond
Climb the Wind Institute
Sue 7ennings, National Park Service
In fact, due to the enhancements the proj ect will make in the Mississippi River channel, there
will be reduced flood impacts to some properties during floods below the 100-year frequency
measure.
`��
l
flb���d
St. Paul Downtown Airport Improvement Project
' Questions and Answers
Quesrion 4: Will development of runway safery areas increase runway length?
Answer:
No, on the contrary, the airport's principal runway, 14/32, will actually be skortened, from 6,711
feet to 6,509 feet, as part of the airfield safety enhancements included in the project. The
crushable concrete heing added to zunway ends is designed to stop an aircraft in the event of an
emergency and is not usable for normal airport operations (it would be crushed by We weight of
an airplane, disabling the aircraft from moving forward).
��
�
�
�
�
�
o�-���
•
•
�
�
St. Paul Downtown Auport Improvement Project
Questions and Answers
Question 5: Will the floodwall result in increased use of the airport and more noise
for nearby residents?
Answer:
No, the floodwall will not have a noticeable impact on aviation noise azound the airport.
• Aitcraft operations at St. Paul Downtown Airport have decreased by neaz3y 60,000 annual
landings and takeoffs ger year since 1990. The reduction stems from the economic downtum
e�erienced in recent yeazs, regulatory restrictions on general aviation aircraft imposed
following 9-11-01, and teimination of a federal pmgram that paid for military veterans to
receive pilot ttaining.
The airport has only enough developable space for about a dozen hangazs, half of which
would be in the area now troubled by flooding, so there is little room for additionat aircraft
storage facilities.
• Airport use will be naturally limited by the lack of developabie acreage at the facility,
regardtess of #Iood controts.
• A 200I study of noise at bayton`s B[uff confirmed that airport noise is insignificant in
relation to background noise on a daily basis.
`"��
\
�
�
�
�
�
.'
0
�
Q
C
�
O
�
�
O
�
�
CB
�._
-..._:
V�
LL7
�
�
N
�
00
�
d?
�
N
C
O
�
N
Q
�
�=
C6
U
�
a
���3�:�
�
0
0
N
�
O
O
N
M
O
O
N
N
O
O
CV
�
O
O
N
O
O
O
N
�
�
rn
�
rn
rn
�
rn
cfl
rn
rn
�
rn
rn
�
rn
rn
�
�
�
N
6�
�
�
�
�
O
6�
�
6�
�
6�
�
�
6�
R ,
9�-
�cl�
O O O O O �O O O O O O
O O O O O O O O O O
O O O O O O O O O O
O O O O O O O O O O
O OO CO �F' N O 00 Cfl �' N
N suoi�e�aa p ��e�a�� tl
�
�
�
�b-36�
St. Paul Downtov�m Airport Improvement Project �
Questions and Answers
�
Question 6: Will the project impact wetlands?
Answer:
No, the proj ect was revised during preliminary design to ensure wetlands are not impacted. The
Iack of impacts to weflands is thoroughly documented in the recentIy approved Environmental
Assessment dated January 26, 2006.
i�� �
�
St. Paul Downtown Airport Improvement Project
Questions and Answers
Question 7: Will the sheet pile portion of the wall detract from the area's
aesthetics?
������
. �
!�
Answer:
Considerable effort is being made to ensure the appearance of the sheet pile wall does not detract
Srom its surroundings.
. EJCisting trees and vegetafion will lazgely obscure the sheet pile wall from the view of people
on the ziver.
. The MAC will plant additional vegetation on the river side of the wall to enhance the
aesthetics.
• Attached renderings of the floodwall illustrate plans for ensuring the floodwall blends with
the swrounding environment.
�
�
`��
t
�
o«
:�
!
�����.�
St. Paul Downtown Airport Improvement Proj ect
Questions and Answers
�
�
Qaestion 8: Will the beuefits for the floodwall justify the cost?
Answer: �
The benefits of the floodwall far outweigh the cost.
• St. Paul Downtown tlirport has flooded seven tnnes in as many decades. F'loods closed the
airport in 1941, 1942, 1965, 1969, 1993, 1997 and 2001,
• A single flood avent typically costs the MAC and airport users $7.2 million
• The floodwall and airfield safety enhancement project wilT bring $20.1 million in additional
federal dollars into Minnesota. These dollars come from fees paid by aviarion users, not
from the general taaL base.
• The Metropolitan Airports Commission developed a cost-benefit analysis that was reviewed
and accepted by the Federal Aviation Administration when approving funding far the
project.
��3
�� • �. :E .::
�'373/10Ub IL:2d �� -� 19�IICBl2h k R23�ae1 ��� � Jann tiiZ)DBKiPegg}� L}'ttcR Vx/14
MEMORANDUD'1
REVIEW OF HOLMAN FIELD PERIMEZfiR DIKE
F AA SN VIRONMENIAL ASSESSMENI ("EA'�
Ihe Mississippi River is a national nahual ie.wucce. Significant iesponsibilifies
fall upon the City of Saint Paul and the State to preserve and enhance the River for both
ihe local citizenty and all otheis downsheam tLai wouldbe otherwi�e aclveisely affeeted
by npstream activities. Ihis includes but is not limited to water quatitY> flyway
presecvation, floodway and flood plain pieservation, and w31d1ife and vegeWGve habitat
ieEention and aesthetics Ihe sig�uficance is appzeciated tUsough the Sfate's desigtation
of the Rivec as a Critical Atea
As IvIinnesota's own Envitonmental Rights Act (<`MERA") and subsequent csse
law inteipcetation has found, MERA ptotecfs a wide vaziety of tesouroes, inclnding but
not Iimitsd to all mineiai, animal, botanical, air, wate�, land, timbei, wil, quietude,
i�y�onal, and histoaical Lesources Scenic and aesthetic iesoucces aze also considered
nat�uat resoucces when owned by any govemmental unit oi ageney. Furtheimore,
<`pollution, imPaixment, or deshuction is ...any conduct which materially advessely
affects or is Ix�cely to affect the environment "
pespite such obligations of goveinmental entities iesponsibilities and governing
law, federal and state agencies responsible fox enviconwental teview of significant
development projects have abrogatezl the'u xesponsibilides due to fiscal cutbaclss Ihe
]ack of sfaff to review projects snch as the HoZman Field Dike E.A leaves the public and
the environment at tisk because of informational voids The void.i le�acl lo decisions that
woutd likely cause deuimentat and eadiuing eavironmental hazm fox genesations to the
River �
For instaucz, the United States Environmental Pmtecrion Agency ("EPA'�,
responsible for zeviews and comme�s on major federal actions, xesponded in the
following manner:
We did not undertake a detailed review of the [EA] document you sent to
this office, and will not be genecafing comments F�eczuse of the xeason
selected balow: ..-Eae document was given a ciusoiy review, bue oihei
workload p:ioiities pmcluded us from deta�7ed review and comment.
E�dubit i aaachecL
Similaziy, Minnesota's Polludon Control Agency ("1vIPCA") eliminated 1 d foi
staffia� for enviro�ental review of CIean Water Act Secfion 401 permits recPuc'e
tlte perimeter dike. From the U S. Corps of Engineets Notice of Application foL [Sec:.
4pq] peimit, page 3 and attached as E�ibit 2, the following is fonnd:
�
�
�
� ,�
t� �.
06-3�3
. ; 3/372I1Ub iz:ts monrman a �caaraai Jotln tiiTy00KiY2ggy LyftCfl UY/14
�
Valid Secrion 404 peimits cannot be issued for any activiLy unless water
quatity ceitification fot the activity is gtanted ot waived pucsuant to
Section 401 of the Clean Wazer Act. The state Section 401 authotity in
blinnesota is tfie Minnesota Pollution Conuol Agency.
*.*
Ihe MPCA k�as eliminated the staffing resources for#he Section 40I
certification program due to budgetaty lunitations_ Due to staff
reducrions, MPCA is intending to waive many section 401 cectification
applications with Iimited exceptions.
[Ilhe waivec of 401 certification means that the MPCA has not reviewed
federaliy pennitted projects in detail for confoimance with state watet
quality standards .
Ihe MPCA is waiving review atter previously identifying
sevetal Voluntazy Investigative and Cleanup (VIC) sites 2t Hohnan Field
� and believes the piaposed consUUCtion could encounter contaminated fill.
Much of Holman Field area has teceived fill from vazious unlmown
so�uces. We aoYe fhat Polyaromatic Hydorcazbons (PAHs) and metals
have been found ..
See E�chibit 3.
Where review by consultants was attempted, namely to ide�fy endangered oi
tlaeatened species fhe following is found in the EA:
Io detecmine the potential for the e�sistence of'raze plant and animal
communities, Wenck Associates, Inc. conducted a site visi4 in Decembei
2002
EA at p. 29. If a site visit was done in Mianesota's DECEMBER is theie any wondex
"[n]o sensiti�e resources have been identified within the APB (azea of po#enual affec:t]
fo� the ptoposed peiimetex dike project?" Id Ihere are no assirzances sensitive resoiuces
will not be hazmed.
Another void of' infomiation involves idemified endangeied species withiu the
Rivez, namely, the 1 higginis me�sseL Ihe void is due to the lack of any sampling within
the vety azea of excavation and dike consuuction azea impact
Ihe mussel survey done during 2000 and 2001, refe�red to in the EA, and
completed in part upstream and dowustream from Holman Field found
that `mussels were not abundant, It is not anticipated ia find I.higginsf
[federal and state endangered species listed] or offiex mussels in the
�
�� �
� 3/3/lUU6 11:13
O6-
monrman & tcaaraai �onn tirzyoeKaeeggy �yncn miia
Middle Poo12 reach [area of excavation for dikc] bccausc of poor watei
quality and unstabla degraded habitat
EA at p. 28-29 The sites sampled in the M'iddle Pool 2 were upshe� of Holmaa Field
(neaz oi above Ffaztiet Island) and downstceam (neaz of below Pigs Lye}. EA at Figure 7
Not one sample was taken in the azea in which the dike is to be constcucted ot whexe the
excavation is to take place. Ifieie aze no assucances an endange:ed species wi11 not he
hatmed.
Ihere aze significa� and misleading inconsistencies within the EA that
undermines wnclvsions reached. Fox instance, the EA claims bascd auccaft at Hotman
Field to be 322 in 2Q04 with 130,784 annval opeiations EA at p. 4-5. On page 7, the
EA states "[t]hete were 100 tegisteied airccaft based at jHolman] ia 2004...." On gage 4,
the claim is tbat the dike would not cause an increase m aupoLt opera6ons However, if
the nvmbei on page 7 is used, i.e ,100, the clike will likety xesult in an incr�se in haffic-
As the Metropnlifan AirFwrts Commission's own tlitport Relievex Guide predicts, `[b]y
the yeaz 2020, annuzl aiicraft operations should appra:dma!e 174,000 About 170 zixc:aft
aze ptojected m be based at tfie facility." See E�ibit 4.
(h� page 24 of the EA the document states that the dike is consisfe� with Saint
Paul's Compiehensive Plan and generally consistent with the Meiropolitan ConncIl
Transportation Plan EA at p. 25. However, Saint Paul's Comprehensive Plan (paza.
42.4) states that the City will continue to enfotce a 54 foot shoreline setback for
st�uchnes. The construction of tFse dike witl Lave as little as a zero (O} setback fot the
ordinazy fiigh watez mazk of the Rivet.
Likewise, in a Metropolitan Council letter dated August 2, 20Q5, it iefeaed to
land use compatihility criteria (paza. 5 3) while finding that upon teview of the 1992
auport developme� plan, it did not include the d�e. Pucthexmoze, the Council had not
appmved the fottg tesm comprehensive pIan npdate far the aitport that also incIuded the
dike.
Nevettheless, the one cotpoiate eutiiy that wouid most diiecfly benefit due to
alleged increase of opecations at the Mimmeapolis-Saint Paul Intetnational Aicport
Northwest aulines, has specifically stated That the dike is not aeeded and a waste of
money. Northwest stated,
"[t]o contemplate expending ^ �25 million for a dike to addtess a situation
that has beea slwwn to occis, on avemge, evecg seven yeazs while
wnsideiable cuts are being made elsewhere is wutracy to good public
policy:"
Exhibit5_ NorthwesthasnotrevetsedUvsstatementsincewiitten.
Regazcling petmits and variances required found on page 14 of the EA, the EA
faiLs to note that the Saiut Paul mning code within the Critical Area, ptomulgated to
3 b�
�
�
; �
c
��
f .. ,
�•
]j 3/3/LUU6 11:13
ntonrman & icaaraat
�onn �rzynex-�eeggy �yncn
I1/14
pzotect the Ciitical Area and the floodway, will have to be amended Tfie �A fails to
note the zoning codes de&nitively prolribit community wide �1ood conhol struchues
being huilt within the IIoodway. (Sec. 68.214(h}). No vaziance or site plan approval can
result without tneaking the law or otheiwise first amending the zoninau code m elinvnate
the prolubition. No such effort has been made
Any azguments that PLMA has control ovei designating areas as floodways in
w}uch the City has pteviously desigpated (and affotded g[eater piotections) must aasend
according to FEMA mapping is false. Fust, FEMA mapping is for flood iivsutance
pucposes only Second, and specifrcally, FEMA has stated;
Exhibit 6.
�
Youc community is responsible fot apptoving all floodplain
development... If the State, counTy, or community has adopted more
restrictiye or compiehensive floodplain management csiteiia, these czitecia
take p�ecedence ovei the minimum [National Flood Iusurance Progzam]
ctiteria.
MAC: thanugh the F,A piocess is circumventing the powers of'local govesnment,
given to ciues by the state to enforce the envuonuienfai pxotectians of tfie Mississippi
RiveT Cxiticat Area thxough the city zoning code.
Tlus memotandum was prepazed by lohn E Cnzybek, ieview� and commented on rvith
suggesrions incoipoiated by Peggy Lynch and Iom Dimond. 09 Febivazy 2006
�
���
;:E . .
�J"'3!3/LUU6 11:23 �� � RIOI1Cmett & K28CQ3L -�� � Jotln tit'ZyDeK-�PeggY LyltCll
�;Ci�n6 tTje �inD �n5titute
�.� �ax i554s
�airt �anl. $EiirtnesoTa 55116
�oi�n �- �[3P6e§
18 January 2006
Zoning Committee Membexs
5aint Paul's Planning Commission
Re: Site Plan Review and. Vaziance Request of
Ihe Metropolitan Airports Commission
THE SITE PI.AN ANll VARIANCE REQUESTS
V[OL0.TF, F.X[ST[DIC, ZONING CODE PROVISZONS
PROTECTING THE MLSSISSIPPI RIVER CRICITIAL AREA
A_ The MAC Reqaests For Site Plan Review And Variance Reqnests
Must l�e Denied Ontright Witho� Revie�v Becanse'i'hey Vio3ate Section
68.214(h) Of The Zoning Code Prohi6itmg Community-R'ide 8tructvrat
Works For Fiond Cnnhnl In The Floodway
Ihe Me4opolitan Aitpmts Cnmmissinn ("MAC'� has applied fot a site plan
review and Mississippi River Ctitical Area vaziances to widen a portioa of fhe River
cliannel m conshuct a flo�d-pmtection levee and floodwall system. Ihe MAC seeks
to accomplish 8us developm�t tluaugh the avoidance of Saint Pau1's laws that
piovide for shict and specific regulatioas prohibiting 400d control Ievees within the
floodway. In short, the MAC as a state entity hopes to supeisede Focal goveinmentat
c�ntrol over develogment cleady within the City's domain and authoiity
Saint Paul's zoning code section 68.214(h) states:
Stcuchaat works fot flood control that will change the coutse, ciarent or
ctoss-section of proteded weNands, oi public watexs shall be subject to tho
prnvisions ofM'utnesota Stahtfes, Chapter 103 G CommunitY-x'fde
structural wo�ks fo� flood conhai intended ta remove meas from the
regutatory ftoodpIain siw[I not be allawed in the }loodway. (Italios added)
The Zoning Committce StaffReport ("the RepoiP� states,
Ihe Compensatory Excavation must be done because part of the levee
wauld be built ut an azea cucrently desigiated RCI (Floodway) .. thc
Compensatory Excavation wonid enable this azea to be reclassified from
RCl to RC2 {Ftood Ftutge) as follows Ihe Compensatoty F�ccavation to
widen the river channel would bc done first. Wfien it is completecl, MAC
11�,4
��
��
��? �
l �
�
•
� 3/3/ZUUb 11:L3
monrman x Kaaraat
�ottn c:rzyoetc-�reggy �yncn isiia
would cequest FE,MA fo adjust it's {sic} flood maps to move the boundwy
ofthe Floodway a few hlmdred feet close� to the rive� shme If this is
ctone, ull ofthe Zevee would be ou[ ojlhe Floott'way (Italics added)
1 . ,, •
Ihe MAC's acimiLS thal its effenis to reclassify floodway lands tluough administrative
piocedures aze to avoid specific wniag code protections affocded to the floodway
In addition, Section 61 b�0 also states in ielevant part that, "[a]Ithough vaziances
mag be used to modify permissible melhocls of Ilood pro[ec6on, no variance shall have
the effeet of allowing in arry disbict uses prohibited in that disbict .." (Italics added).
MAC fiuther admits ihal ils pcimary abjeclive is to modify protected floodway and
tloodplain lands to cause a ptohibited use ia the floodway. Saint Paui's �nning code is
very pazticulaz with regard to piotecfions of the IIuudway. ihe effoits of MAC to
cucumvent those piotections through vaziances of a pioject specifically integTated to the
cons[ruction of' a levee should be denicxi.
Ihe MAC's effort pucsuant to its vaziance requests is to uullify local
guvernmentai conh ol and protections over an azea within the CriNcal Area that is
� exclusively that of the City's. The MAC 1luough its admissioas, makes no excuse or
pretense of its oveiall abjecrive, and shows contempt foc the City's tegutatory statutes.
Therefoie the applica4ion, including tha �ita plan ieview and vaziance cequests should be'
denied.
S. The Application For Site Plan Review and Variance Requests Must Be
Denied Because It Is Based On The MAC's Envixonmental Assey�ment to
Whick a Final Declax�atioa Has Not Been Made
�
Fusf, tfia foxmal responses to tfie wiitten comments to the Envaonmental
Assessment ("EA") for the Holman Field Levee i�ave not been finali�� published, or
otheiwise publicly disclosed. Second, the responsible goveinmental unit ("RCrtP') has
noY made any final declazation based on the yet incomplete EA on whether an
environmental impact study ("EIS"} is necessazy. Ihiid, aftei that declazaYion, if
negative, ffiere is a petiod of appeal of that decision avxilable to opposi6on paifies.
I'heiefore, the exhaustian of administrative and legal cemedies has not occussrd
Ia addition, the MAC's application is wholly based on the very arguments thaY the
EA is based and contested within that p[uiicular process. 1 hecefore, the application
process foi a site plan xeview and vaziance requests is tn cucumvent Yhe F.A process.
Pioe:e3uially, this raises issues of ptoceduial due process_ Ihe Zoning Committee itself
would also now be subject to iidicule as a local govemmentai unit frying to supersede the
federal regulation� lhat govecn the EA proce�s.
Ihus, lhe Zoning Commiuee would be nullifying federal environmental
pcoYecrions if it heazs artd decides the MAC's appHcation.
� � �
������
]j !/3/1UU6 12:13
monrman & KaaraaE �onn UrzyoeK+reggy �yncn - -� iaiia �-
Ihere a[e ficYnai issues tegarding the appflcation that is based on ihe MAC's EA
to which the applicalion dc� address nor fiilIy present to the Zoning Committee. To fhat
end I submit to this Committee a copy of my comments to the EA presented in Angust
2005 to which no fomial response, as is required, has heen made to dafe. Ihe Zoning
Commiltee iLit takes any action buY to deny the MAC's site pFan and vaziances request
cvitl be acting in an infotmational vaid regarding this complex icsue
Iherefore, based on the azguments sef-forth here and integraring my arg�e�s of
August 5, 2005 as part of the rewnt beLore the Zoning Commitxee, I irspectfully iequest
the devial of alI requests o£the MAC regazdmg its site plan and variance requests.
Sinceiely,
John E, Cnzybek
��
�
` �
�:.
�
���� ,
-� �
•�
Y 3/3/1UUb 11:U1
MOrii'�8R & K23C421
�onn erzyoetcireggy Lyncn " -
U1/14
�timb t3�e �inD �fn5titute
�n�jn � �t3Ybe�
P O. Box 16548
Saint Pani, Mmnesofe 551 t6
(651}952-0945
08 February 20Q6
REVIEW OF HOLMAN FIF.LD PERiMEIbR DIKE
MAC'S VARIANCE REQUEST SHOULD BE DENIED
�
THE STTE PLAN AND VARIANCE REQUESTS
VIOLATE EXi,S'FING ZONING CODE PROVISIONS
PROTEC3'ING THE NIISS75SIPPI RNEI2 CRICITL4I, AREA
A. The MAC Requests For Site Plan Review And Var�ance Requests
Must be Denied OuEiight Wifhout Review Because Tfiey Viulate Sectiun
68.214(h) Of The Zoning Code Prohibiting Cummunity-Wide Struetuial
Works For F7ood Control In The Floadway
The Metropolitan Auports C�mmission ("MAC"} has apglieci foi a site plan
review and Mississippi River Ctirical.Srea vatiances to widen a poxtion of the Rivet
channel to conshuct a flood-protec:tion levee and Roadw•atl system. Ihe MAC seeks
to accomplish this development ttuough the avoidance of' Saint Paul's laws that
pmvide for suict and specife iegulations pzohibiiing Aood control Fevees within the
floodway In shoxt, the MAC as a state entity hopes to supeisede local govemmental
wnuol over developmenl cleazly wi4hin the Cily ciomnin and aulhoiity.
Saint Paul's zoning code section 68 214(h) sta#es:
Suuchua! works fot flood conirol that will change the course, ciurent or
ecoss-section of ptotected wetlands, oc public wateis shall be subject to the
provisions of Minnesota Statutes, CI}apTei 103.G. Communiiy-wide
strucfural works for flood conhol intended to remove areas from the
regulatory Jloodplain shall not be allowed in the floodway_ (Italics added)
Ihe Zoning Committee StaFf Repoi t("the Report") states,
�
Ihe Campenutoiy Excavation musf be done because patt ot the levee
would be bztilt in an uea cuuently designated RCl (Ffoodway) . the
Compensatory Excavation would ettable this azea to be teclassified from
RCl to RC2 (Flood Fiinge) as follows Tfie Compensatory Excavation to
�D
; sisiz�ue i�:ui
ntonrman a tcaaraat �onn �rzybetc-�reggy �yncn
t t �
widen the river channet would be done first. When it is completed, YfAC
would request FEMA to adjust iYs (sic) flcx�d maps to move the boundmy
af'the Flooclway a few hur�dred jeet cZoser to the rive� shore. If this is
done, all of the levee would be aut of the Floodway (italics added)
The MAC's admits that its effoFts to teclassify floodway lands through adminisuative
proceduies aze to avoid speci&c zoning code protectious afforded to the floodway.
In addition, Sectivn 61 _604 also states in ielevant pazt that, "[a]lthough vaziances
may be used to modify peimissibie methods of'flood piotection, no vm imzce shall have
the effect of ailowing in arry dis[ric[ uses prohibited in that district. ."(Itatics added).
MAC fiuther adwits that its piimaiy objective 'is to modify protected floodway and
fltiodplain lands to cause a prohibited use in ihe IIoodway Saint Paul's zoning code is
vety paziiculaz with regazd to protections of tfie floodway.
Any azguments tUat FEMA has control over designating azeas as floodways in
which the City has pteviously designated (and atfoided gzeatet pcotections) must amend
according to FEMA mapping is faLse. First, FEMA mapping is for flood insurance
purposes only_ Second, and specifically, FEMA has stated:
Your community is iesponsible for nppiuving all flaodpFain
development.. If the State, county, or com�uunity lias adnpted mote
iestrictive or compxehenyive floodplain manageme.nt criteria, these ctiteria
take precedence ov� the minimum [Narional Flcx�d In.surance I§o�am]
ctiteria.
Exfiibit 6 attached.
Ike efforts of MAC to circumveal [hose jmotections tluough vaziances of a
ptoject specifically integrated to the construction of a levee should he denied.
FAA E1�iVIRONMENTAL ASSESSMENT ("EA")
B. The EA Fails to Ansever Basic Environment issuec
and'Fhus is Nun-Supportive to MAC and
Therefore its Variance Reqnest Must be Denied
Ihe Mississippi River is a national natural resoiuce. Significani r�omibiliries
Fill npan the City of Saint Paui and the Siale to preserve and enbance the Rivei foi both
the local citizeury and atl others downstream that would he otherwise adverseiy affected
by upstream activiiies. Ihis includes but is not limited to water quality, IIyway
presexvation, floodway and flood plain greservation, and witdlife and vegetative habitat
retention and aesthetics. The signiGcance is apgceciated thcough the State's desigpation
of the Rivei as a Cxitical Area.
U3l14
�.
�
��
��
o�-���
••
� 3i.tizuue it:u1 -- eaonrman x� tcaaraat"
�onn urryneK-�reggy �yncn
U4114
C. The EA Fails to Meet Basic Precepts of Mmnesota's Envit oamental Rights
Act, Coatains Significant Vnids of informarian and Governmental
Agencies Fail to Adequately Iteview What the City is Obiigated to Profect
Uader the Crifical Area Zoning Code
As Minnesota's own F:nvitnnmer�tat Rights Act ("MERA'� and subsequent case
law inteipretation has found, MERA protects a wide vaziety of iesoucces, incIuding but
not lunited to all mineral, animal, botanical, au, watei, land, timber, sofl, quietude,
recreational, and histocical resotuces. Scenic and aesthetic resoucoes are also conside:ed
nafutal tesoutces when owned hy any goveinmental unit ot �geucy Futtheimoie,
"pollution, unpairment, ox destcucrion is any conduct which mateiially adve:sely
affects ox is likely to affectthe envitonment"
�
Despite such nbligarions of' goveinmental en6ties responsibilifies and govetning
law, fedeial and state agencies cesponsible for environmental review of'significani
development projects have abtogated their Tesponsihilities due to fiscal cutbacks. Ihe
lac:k of s€aCf'to revie�v p�ojects such as the Holmazi Field Dike EA leaves the pubfic and
the snvuonment at risk because of'informational v�ids. The voids lead to decxsions that
would likely cause deuimental and endwing envuonmental haim fox geneiations to the
River
Fot instance, the i.Jnited States F,nvironmental Protecfion Agency ("EPA'�,
iesponsible for reviews and comments on major fedexat actions, iesponded in the
following mannet:
We did not undextake a detailed review of the [F.A] document you sent to
Lhis ofCice, and will not be geneiating comments hecause of'the:eason
selected below: Ihe document was given a cutsory teview, but othet
woxkload piiotities precluded us from detailed review and comment
Exhi6it 1 atfached.
r
Similarly, Minnesota's Pollution Comrol Agency ("MPCA") eliminated its
stati"ing for envuonmental ceview of Clean Watet Act Section 401 permits required foi
the peximeter dike From tha T I S. Cotps of' Engineers Notice of Application for [Sec.
4d4] pecmit, page 3 and attached as Fxhibit 2, the following is found:
Valid Section 404 permits cannot be issued foi any activity unless water
quality certification for the activity is ganted or waived pursuant to
Section 401 of the Clean Water Act The state Section 401 authoxity in
Minne.cota is the Minnesota Pollttrion Control Agency.
�*�
The MPCA has eliminated the staffing xesources for the Section 401
� certification prog:am due to budgetazy limitations. Due to staff'
��
�
7f 3F3/LUU6 IlcUl
Monr�ae a tcaaraat ' " �ann Urzy�K->Feggy �yncn' - u�tia
�b-3b3
reductions, MPCA is inteudiug to waive many section 401 certification
applications with iimited exoeptions.. _
[I]he waiver of'461 certification means that the MPCA h2s not reviewed
fedetally peimitted piojects in detail for confoxmance with state watet
quality standatds _ _
Ihe MPCA is waiving ceview aftet previnusly identifying
See E�chibit 3
several Voluntaxy Investigafive and CTeanup (V[C} sites at Haiman Field
anci believes ihe proposed constmction could encounter contamivated fill
Much of Hofmaa Field azea has received fill from various unlmown
sources We nole ihat Polyacomatic Hydoreazbans (PAHs) and metals
l�ave been found . _
Where teview by consultants was attempted, namely to identify endangered ot
threatened species the Folluwing is fouad in the EA:
Io deteimine the potenEiat foi the existence of caze plant and animal
commuuities, Wenek Associafes, Inc. conducted a site visit in December
2002
EA at p 29. If a site visii was clune in Minnesota's DECF.MBER is there any wondet
"[n]o sensitive resoiuces have been identified within the APE [area of patential affect]
fat the pLOposed perimeler clike pruject?" Id. Ihere ace no ����*�nces sensitive resources
will not be I�xmed
Another void of infotmation involves identified endangered species within the
Rivet, namely, the 1 higginis mussef Ihe void is due to the lack oP any sampling within
the vety area of excavation and dike consttuction area impact
Ihe mussel survey done duxing 2Q00 and 2001, referred Yo in the EA, and
completed in pazt upst�eam and dowustceaui from Holman Field found
tUat "mussels were not abundant it is not anticipated to find l.higginsi
[feciecal and slate enda¢gered species listed� oi othec mussels in the
M�iddle PooI 2 reach [azea of excavarion far dike] hecause af pooE watec
quality and unsYable degtaded habitat
..
�
EA at p_ 28-29. Ihe �ites sampled in the 11TddFe Poo12 weie upslream of Holman Field
(near or ahove Hazriet isiand) and downSEream (neaz of below Pigs Eye). EA at Figtue 7.
Nol one sample was taken in the acea in wLich the dike is to be constxvcted or where tha
excavation is to take place. There ue no assurances an endangered species will not.be
ha[med.
U�
4 �
�
��
# .i/3/IUilb 11:U1
Monrman a xaaraal
.IOnn Urzycetc-�reggy Lyncn ueiia
Ob-36�
ihere are significant and misIeading inconsistcncics within thc EA that
undeimines conciusions reached. For instauce, the EA claims based airctatt at Holman
Pield fo be 322 in 2004 with 130,784 annual operations. EA at p. 4-5. On gagc 7, thc
EA states "[tjhere weie 100 iegistered aircraft based at [Holman] in 2004 _.." On page 4,
the claim is that the dike would not causc an incrcasc in airport operations However, if
the numbet on page 7 is nsed, i.e., 100, the dike wiIl likely result in an increase in uai�c.
As ttce Metropolitan Auports CoT+�*++;c�on's own Auport Rcficvcr Guide predicts, `[bJy
the yeaz 2020, annual aircraft opetations should apptoximate 174,006. About 170 airciaft
aze pcajected to be based at the facility." See Eachibit 4
On page 24 of the LA the document states that the dike is consistent with Saint
Paul's Comprehensive Plan and generally consistent with the Metropolitag Council
Itansportation Plan. EA at p. 25. Howevet, Saiat Paul's Comprehensive Pian (paza
4 2.4) states that the City will continue to enforce a 50 foot shoieline setback foc
steuchues_ Ifie consixuction of'the dike will have as little as a zeio (0) sctback fox thc
oidinazy irigh water mazk of the Rivet
Likewise, in a MetropoliYan Councillzttei dated August 2, 2005, it refened to
land use compatibility ciite:ia {paza 5.3) while finding t�at upon review of the 1992
� aitpcm development plan, it did not include the dike. Fiuthexmore, the Council had not
approved the long texm compiehensive plan update far the aitport t1�at also included the
diice
Nevectheiess, the one coipotate enrity that would most d'uectIy benefit due to
alleged increase of' opesations at the Miuneapolis-Saint Paul Intemational Aixport,
Northwest aulines, has specifically stated that the dike is nat needed and a waste of
money. Northwest stated,
"[t]o contemplate expending $25 million fot a dike to adcixess a situaTion
that has been shown to occur, on avesage, eveiy seven yeazs while
conside:able cuts aze being made etsewheie is contra�y to good public
policy'>
fiachibit 5 Norfhwest has not ieversed this statement since vnitten
Regazding pexmies and vaziances iequued fouttd on page 14 of'the EA, the�EA
fails to note ihat the Saint Paut zoning code within the Ciifical A:ea, promulgated to
protect the CTitical Aiea and the floodway, will have to be amended. Ihe EA faits to
note the zoning codes definitioely ptohibit community wide flood control stiuctures
being built withiu the floodway- (Sec. 68 214(h)) No vaziance oi site plan apptoval can
xesult without breaking the Faw ot otheiwise fust amending the zoning eodc to climinafc
the prohibition No such efFort has been made.
Ikuough the variance and EA pcocess the MAC is citcumvenring the powers of
�
�'
��
� R
�
��°'�L',� �
]j 3/.i/1VUE it:u n�onrman � Kaaraa� �onn urzyoetc-�reggy �ynar ui�ta
•
local govemment, given to cities by the shate to enforce the environmenfal protections of
the Mississippi River C:itical Area tluough the city zoning cade- Secause of the
inadequacy of MAC's supporting argiunents foz vaiiances, Ihey must be DENIED_
Sincerely,
Iohn E Gtzybek
�
0
��
�- �
„;
•�
City of Saint Paul
Planning Commission Resolution
File Number OS-18
Date Febraar�24, 2006
WfIEREAS, the Metropolitan Aiports Commission, File#06 000725, has submitted for a site plan
for review under the provisions of 61.400 of the Sunt Paul Legislative Code, for the establishment
of a flood protection system and compensatory excavation on properry located at property address
644 Bayfield St , II, Iegally described as Lampreys Addirion To Saint Paul Ex Leases & Ex Nati
Guard Air Base; Part E Of Ry Of Fol; Part Of Govt Lots 7-11 In Sec 4& Govt T,ot 4& 12 & E 1/2
Of 13 Tn Sec 5 T28 R22 & Sl/2 Mol Of Blks 10- 12 & All Of Bllcs 1-9 F Ambs Add & Sl/2 Mol
Blk 5& Ali Of Blks; and
WHEREAS, the Zoning Committee of the Planning Commission, on January 19, 2006, held a public
hearing at which all persons present were given an opporiunity to be heard pursuant to said
application in accordance with the requirements of §61303 of the Saint Paul Legislative Code and
considered the applicarion again at their next meeting on February 2, 2006 ; and
06-363
5 �e ��e
WHEREAS, the Saint Paul Plazuinig Commission, based on the evidence presented to its Zoning
� Committee at the public hearing as substantially reflected in the minutes, made tha following
findings as required under the provisions of §61.402(c) that the site plan is consistent with:
I. The city's adopted comprehensive plan and development or pYOject plans for suh-areas of the
city.
The Land Use Chapter of the Comprehensive Plan, Policy 7.6.1 states: "MSP and Holman
Field airports are both very important to Saint Paul's economy and quality of Iife. The City
supports maintaining and improving them in their present locations with full attenrion to
noise mitigarion.” The proposed levee/floodwall project is consistent with this policy.
�
The Mississippi River Corridor Chapter of the Comprehensive Plan, Objective 5.1 states:
"Continue commercial and industrial uses of river corridor Iand and water, consistent with
the Saint Pa1 Land Use Plan." As stated above, the Land Use Plan supports maintaining and
improving Holman Field in its present location. Objecfive 6.5 states: "Encourage protection
and restaration of river corridor cultural resources, inciuding historic structures, culturally
significant landscapes, and archaeological and ethnographic resources." As noted
previously, the floodwalUlevee project wi11 protect tfle historic Admiuistration Building from
flooding to the 100 year event. Policy 4.2.2 states, in part: "The City will encourage use of
nafive vegetation ar othex compatible floodplain vegetarion in redevelopment projects.
Where appropriate, when redeveloping or stabilizing the river's edge, soil bio-engineering
techniques and native plantings will be used 'm combination with more traditional engineered
solutions...." The proposed compensatory excauation will use native plantings to stabilize
the river's edge. The sheet pile flood wall will be located so as to retain e�sting vegetarion
to the greatest extent possible.
��7
06-363
2. Applicable ordinances of the City of Saint Paui. The following ordinance sections apply:
Sectzon 68.402. regulates protection ofshorelands, floodplains, wetlands and bluffs in the
River Corridor:
(a) Generally. Development shall be conducted so that the smallest practical area of land be
developed at any one time and that each area be subjected to as littde erosion or^ flood
damage as possible during and after development.
(b) Placement ofstructures.
(1) The following minimum setbacks for each class of public waters as described in
Minnesota Regulations NR-82 shall apply to all structures except those specified as
exceptions in subsection (7) below.
a. For natural environment waters at least two hundred (200) feet from the normczl high
water mark for lots not served by public sewer and at least one hundred fifty (I50) feet from
the ordinary high water mark for lots served by public sewers. Ttus section is not applicable.
b. For general development waters at Zeast seventy-fzve (75) feet from the normal high water
mark for lots not served by public sewer- and at least fifty (50) feet from the ordznary high
water mark for lots sepved by public sewer. The applicant has requested a variance of this
standard (see Findings H.1 to H.5).
(2) No commercial or industrial development shall be perntitted on slopes greater than
twelve (12) percent. The applicant has requested a variance of this standazd. (see Findings
H.1 to H.5)
(3) No residential development shall be permitted on slopes greater than efgkteen (18)
percent. This section is not applicable.
(4) Bluff development shall take place at least forty (40) feet landward of all blufflines. This.
section is not applicable.
(5) Transportation, utility and other transmission service facilities and corridors shall avoid:
a Steep slopes;
b. Tntrusions into or over streams, valleys and open exposures of water;
a Intrusions into ridge crests and high points;
d. Creating tunnel vistas;
e. Wedands;
f. Forests by ruuning along fringe rather than through them. If necessary, to route through
forests, utilize open areas in order to minimize cutting;
g. Soils susceptible to erosion, which would ereate sedimentafion and pollution problems;
h. Areas of unstable soils which wouid be subject to extensive slippages;
i. Areas with high water tables; and
j. Open space recreation areas
This secfion is not applicable since the airport is an e�sting use.
��
�
�
�:
��
. 06-�6�
(6) At river crossing points, public facilities, crossing corridors and other rights-of-way shall be
consolidated, so that the smallest area possible is devoted to crossing. This secrion is not
applicable.
('n Exceptions:
a. Location ofpiers and docks shall be controlled by applicable state and local regulations.
b. Comrrcercial, industrial or permitted open space uses requiring locarion on public waters may
be closer to such waters than the setbacks specified in the standard set out in subsection (3)
above. This section is not applicable.
(c) Grading and filling.
(1) A minimum amount offilling shall be allowed when necessary, but in no case shall the
following restrictions on filling be exceeded. Furthermore, fill oppor-tunities shall be fairly
apportioned to riparian landowners. The developer shall evaluate ownership patterns,
configuration and the bottom profzle of each wetland basin before fill opportunities are
apportioned.
(2) Grading and filling in shoreland areas (when allowable) or any other substantial alteration of
� the natural topography shall be controlled in accordance with the following criteria:
a. The smallest amount of bare ground shall be exposed for as short a time as feasible.
b. Temporary ground cover sha11 be used.
c. Methods to prevent erosion and trap sediment shall be employed.
d. Fill shall be stabilized.
These standards are met. The size of the compensatory excavation azea has been reduced by the
applicant to ensure that the smallest amount of ground shall be exposed. Silt fence and other
measures as needed will be used to prevent erosion and trap sediment. The new shoreline will be
stabilized with riprap and native vegetation
(3) Only fcll free of chemical pollutants and organic wastes shall be used. At such time as the,
levee can be constructed, the applicant wili ensure that fill used to construct the levee will meet
this condition.
(4) Total filling shall not cause the total natural flood storage capaciry of the wetland to fall
below the natural volume of r�unoff from the wetland and watershed generated by a 100 year
storm, as defined by the National Weather Service. After the affected portion of the airport
property is removed from the Floodway by FEMA, the fill for the levee as well as the sheet pile
floodwalls and temporary floodwalls will meet this conditiott.
(5) Solid waste disposal and Zandfill shall not be permitted in the River Carridor Dist�-ict. The
applicant is not xequesting these uses.
�
(6) Development shall fit existing topography and vegetation with a minimum of clearing and
grading. The applicant is proposing a minimum development that will protect the airport to khe
�
�b���=
100 year flood event. In times of greater flooding, the airport will be closed. This minimal flood
protecfion development meets this coadil3on.
(7) No rehabilitation slopes shall be steeper than eighteen (18) percent slope. The applicant has
requested a variance ofthis standard. (see Findings A1 to H.5)
(8) Dredging of a shoreland or wetland shaZl be aZlowed only when it will not have adverse effect
upon the wetland. Dredging when allowed shall be limited as follows:
a. Ft shall be located in the areas of minimum vegetation.
b. It shall not signifzcantly change the water flow characteristics.
c. The size of the dredged area shall be limited to the absolute minimum.
d. Deposit of dredged material shall not result in a change in the current flow, or in deshuction
of vegetation or fish spawning areas, or in water- pollution.
(C.F. No. 03-241, � 2, 3-26-03) These standards are met by the application_ Existing vegetafion
in the area of compensatory excavation is u�inimal, and the shoreline has become severely
eroded in places. The excavation is intended to improve water flow chazacteristics in this part of
the channel. The size of the azea affected by the compensatory excavation has been kept to the
absolute m;,,;mum, and the applicant has stated that the exca�ated material_will be tested and
disposed of properly.
Sec. 68.403. Protection of wildlife and vegetation.
Development shall be conducted so as to avoid intrzrsion into animal and plant habitats.
(a) No alteration of the natural environment or removal of vegetation shall be permitted when
sueh alteration or removal would diminish the ability of dependent wilddife to susvive in the
River Corridon The compensatory excavafion and levee construction aze not in an area that is
ciurently habitable by wildlife. The sheet pile floodwall will be located next to the existing
airport road, and the e�sting riverwazd vegetation wIll be retained for wildlife habitat and
screening of the sheet pile from the river.
(b) No wetland os bluffline vegetation shall be removed or altered except that required for the
placement of structures. No wetland or bluffline vegetafion will be affected by fhis project.
Shoreline vegetafion wili be retained, replaced, or added where possible.
(c) Clear cutting shall be prohibited except as necessary for placing approved public roads,
utiliries, structures and parking azeas. No clearcutting is associated with this project.
(d) Natural vegetation shall be r-estored after any construction project. The applicant will
restore native vegetation to the shoreline. No natural vegetation exists in the azea of the airport
where the levee will be located. Vegetation riverwazd of the sheet pile floodwall will be retained
where possible.
(e) Watering areas necessaty for plant survival shall be maintained or provided. No special
requirements are anticipated for plants in the area.
��
�
�
���
06-363
��
�
( fl Development shall not cause extreme fluctuations of water levels or unnatural changes in
water temperature,. water quality, water- currents or movements which »zcry have an adverse
impact on endangered or unique species of birds or- wildlife. No fluctuations in wastez leveis or
temperature or water quality will result from this project. Changes to water currents or
movements will not have an adverse impact on birds or wiidlife.
3. Presef-vation of unique geologic, geographic or historically significant characteristics of the
ciry and environmentally sensitive areas.
The site plan is consistent with the preservafion of environmentally sensitive azeas. 'The
Compensatory Excavafion will affect 3,000' of shoreline near the south end of the airport.
However, the condition of much of the existing shoreline, which was created with fill, is not
stable: it is steep and being undermined by erosion. There is a row of shrubs approxunately
12' tall at the top of the bank and the area behind it is non-native grass that is mowed. The
shoreline after the Compensatory Excauation would stabilize the shoreline by using a
minimal amount of rip rap and planting native grasses.
The sheet piling that will be built paza11e1 to Bayfield Street about 6' from the edge of the
paued roadway. Because it would be so close to the street, it would have a minimal affect on
existing vegetation and would not be visible from the river because it will be screened by the
existing vegetarion.
The site plan is consistent with the preservation of historically significant characteristics of
the city. The terminal building has been nafionally designated as an historic building and the
flood walll levee would help protect it from periodic flooding.
4. Protection of adjacent and neighboring properties tlarough reasonable provision for such
matters as surface water drainage, sound and sight buffers, preservation of views, light and
air, and those aspects of design which may have substantial effects on neighboring Zand uses.
The site plan is consistent with this finding. The levee will not increase the level of the river
during flood conditions. At one time there were concerns that the levee woutd increase the
level of the river, but this will not happen if the Compensatory Excavation is done to widen
the river channel and increase its capacity.
The levee will not be noticeable from the river. The sheet piling will be well screened by a
exisfing trees and shrubs along the shoreline.
The Flood Protection System will not cause an increase in air traffic at the airport that
would have substantial effects on neighboring land uses or unreasonably diminish
established propzrty values within the surrounding area.
�
5. The arr�angement of buildings, uses and facilities of the proposed development in order to
assur-e abutting property and/or its occupants will not be unreasonably affected.
2 r1
�� ;� ... :+ �
The site plan is consistent with this finding. The proposed Compensatory Excavation and
levee will not affect abutting property. '
�..
6 Creation of energy-conserving design through landscaping and Zocatian, orientation and
elevatFon ofstructures.
The site plan is consistent with this finding.
7 Safety and convenience of both vehicular and pedestrian traffic both within the site and in
relation to access streets, including traffzc circulation features, the locations and design of
entrances and exits and parking areas within the site.
The site plan will haue no impact on vehicular or pedestrian tra£fic and is consistent with this
finding.
8 The satisfactory availability and capacity ofstorm and sanitary sewers, including solutions
to any drainage problems in the area of the development.
The site plan is consistent with this finding. MAC is currently making improvements to the
sewer and drainage system for the airport that will accommodate the proposed levee.
9. Sufficient Zandscaping, fences, walls and parking necesscr�y to meet the above oBjectives.
The site plan is consistent with this finding. Native species would be planted in the area of
the Compensatory Excavation where the shoreline would be widened. The e�sting
shoreline in this area has shrubs along the shoreline and non-native grass. IviAC wants to
limit the replacement �lanting to native grasses because of concerus that planting new shrubs
would provide habitat for birds that could cause a hazazd for aircraft.
Almost all of the e�sting landscaping along the shoreline where the sheet piling is proposed
would be retained would be sufficient to screen the piling from view.
10 Site accessi8ility in accordance with the provisians of the rlmericans with Disabilities Act
(ADA), including parking spaces, passenger loading zones and accessible soutes.
The site plan will have no impact on handicapped accessibility and is consistent with fhis
finding.
11. Provtsion for erosion and sediment control as spec�ed in the "Ramsey Erosion Sedzment
and Control Handbook."
�
�
�
Silt fence will be installed where needed prior to work beginning on the project to ensure that �
sed'unent does not get to the river or a neazby wetland. Staff will require a more detailed
plan for sediment control for the Compensatory Excavafion prior to a pennit for this work
ZIZ
� Ob-363
, being issued. The project must also obtain an NPDES pemut from theMPCA that will also
address these issues.
NQW, TFIEREFORE, BE IT RESOLVED, by the Saint Paul Plauning Commission, under the
authority of the City's I,egislafive Code, that the application the Metropolitan Airports Commission
for site plan review for the establishment of a flood protection system and compensatory excavation
at 644 Bayfield Street is hereby approved, subject to the following condirions_
1. Work on the Compensatory Excavation cannot begin until MAC obtaius all other required
approvals including those from the Army Corps of Engineers, Minnesota Pollurion Control
Agency and the Mimiesota Department of Natural Resources.
2. Work on the Levee / Flood Control System cannot be begin until MAC obtains all required
approvals as specified in Secfion 2.3 of the Fina1 Environxnentai Assessment (December 2005).
As part of these approvals, FEMA must issue a Letter of Map Revision for the boundary of the
floodway and the City Council must approve a revision to the River Corridor Zoning Map
based on FEMA's actions so that a portion of the airport where the levee would be built is
rezoned from RCl (Floodway) to RC2 (Flood Fringe).
�
moved by Morton
seconded by
in favor 15
against 4 McCall LU Gordon Kramer
Mailed: February 27, 2006
I:�AMANDAMERG�ZONING\SAV E\5592182094.DOC
approve site plan
�
Zf3
Vana ��.
_ � �-���
City of Saint Paul
Planning Co�ssion Resolution
File Number: OS-17
D�te: Februarv 24, 2006
WIIEREAS, the Metropolitan Airporfs Commission has applied for variances from the strict
application of the provisions of the River Corridor Zoning Overlay District per Sections 68.402
and 68.601 of the Saint Paul L.egislative Code pertaining to development on e�sting slopes
steeper than I2%, establishment of new slopes steeper than 18% and deve2opment less than 50
feet from the Ordinary Aigh Water Level for Compensatory Excavation and a Flood Protection
System in the Il zoning district and RCl and RCZ River Corridor Overlay Dishicts at 644
Bayfield St ; and
WHEREAS, the Zoning Committee of the Plauuing Commission, on January 19, 2006, held a
public hearing at which atl persons present were.given an opportunity to be heard pursuant to said
application in accordance with the requirements of §61.303 of the Saint Paul Legislative Code and
considered the application again at their next meeting on February 2 2006; and
WHEREAS, the Saint Paul Plaiuiing Commission, based on the evidence presented to its Zoning
Committee at the public hearing as substantially reflected in the minutes, made the folIowing
findings:
The variance meets all of the required findings per Section 61.601:
1. The property in question cannot be put to a reasonable use under the strict provisions of the
code.
The airport had to close for a total of 210 days during and after the floods in 1965,1969,
1993, 1997 and 2001. Costs to tenants at the airport for the 2001 flood (a 75 year flood)
were $3.8 million plus additional costs due to delays at the Minneapolis-Saint Pau1 airport
caused by flights having to be diverted there from Holman Field.
A levee/floodwall system to pmtect the airport fzom flooding is a reasonable use that cannot
be constructed under the strict provisions of the code:
- The levee cannot be built without first doing the Compensatory Excauation and it is not
possible to do this exca�ariott without affecting slopes on the e�sting shoreline that are
steeper than 12%. The ezcisting shoreline was created with fill that was used to �reate the
airport and typically has steep slopes in excess of 50%.
- Most of the new, relocated shoreline would have slopes less steep than 18%, bringing the
shoreline more into compliance with current standards. Howevez, steeper slopes are needed
in certain locations where room is limited, such as near the end of the runway. But even in
these areas, the new shoreline will be less sYeep than the existing.
aae 1 ca s
��
�
�
� ��
S
�
��
pb-3��
- Levees are typically built with side slopes of 30%. Requiring side siopes of 18% as
required by the River Corridor Ordinance would is impractical and would not provide any
benefit.
- The location of the sheet pile portion of the levee is detennined by the location o£ existing
Bayfield Street and the existing hanger building. It is not practical to locate this portion of
the levee fitrther from the shoreline.
2. The plight of the land owner is due to circumstances unique to this property, and these
circumstances were not created by the land owner.
Holman Field was created in the floodplain of the Mississippi River in the late 1920's by the
City of Saint Paul. The MAC took over ownership and operafion of the facility in August,
1944. The plight of the landowner is due to the unique circumstance of owning an exisring
airport in a location subyect to periodic flooding and the location of the streets, hangers and
runways. This situation was not created by the current land owner.
The factors that require variances are existing conditions that were not created by the owner.
These include the location.
r ,
u
3. The pr-oposed variance is in keeping with the spirit and intent of the code, and is consistent
with the health, safety, comfort, morals and welfare of the inhabitants of the City of St. Paul.
The variances for the Compensatory Excavation are consistent with the spirit and intent of
the code. The existing shoreline was created with fill that was used to create the airport. The
existing shoreline slopes are greater than 50% and are subject to erosion. The proposed
shareline, which would have a more stable slope and would also be stabilized with native
vegetation, is in keeping with the spirit and intend of the code.
The variances for the levee and floodwall are consistent with the spirit and intent of the code.
The slope restrictions and distance requirements are intended to control erosion and
development impact on the river from individual buildings, not from flood control projects.
The side slopes for the earthen levee will not have an impact on the character of the river.
The reduced setback from the river for the sheet pile portion of the project will not impact the
character of the river because it will be screened by existing vegetation and will not be visibie
$om the river.
�
4. The proposed variance will not impair an adequate supply of light and nir to adjacent
property, nor will it alter the essential character of the surrounding area or unreasonably
diminish estdblished property values within the surrounding area.
The levee will not have change the visual chazacter of the area. The sheet piling will be
hidden from view from the river by the existing trees and other vegetation. T'he temporary
levee will not be visible except when it is erected during flood conditions. The earthen �evee
d3s 2 G3 5
2 J�
� �z.
�����
wili be sef back from the river and will blend in w�th the surrounding area.
If the compensatory excavarion is done, the levee will not raise the level of the river during
flood conditions.
The compensatory excavation will not change the essential character of the shareline. There
aze currently problems with erosion along the shoreline and the proposed planting with native
grasses and limited use of rip rap will reduce the erosion and stabilize the shoreline..
The Compensatory Excavarion and the Flood Protection System and its impact on the river
must also be reviewed and approved by other agencies including the Army Corps of
Engineers, Mivnesota Pollution Control Agency and the Mimiesota Depari7nent of Natural
Resozuces.
The Flood Protection System will not cause an increase in air traffic at the auport that would
unreasonably diininish established properiy values witivn the surrounding area.
5. The variance, if granted, would not permit any use that is not permitted under the provisions
of the code for the property dn the district where the affected Zand is located, nor would it
alter or change the zoning district classification of the property.
The compensatory excavation will not change the use of the proper[y. However, the levee is
not permitted currently since portions of it would be Iocated in the Floodway, and tevees are
only pernutted in the Floodway "where the intent is to protect individual structures." Once
the compensatory excavation has been completed and approved by FEMA and FEMA has
issued its LOMR, the City will be notified that the #Ioodway boundary has changed- At that
time, the City Council will be asked to rezone fhe area removed fram the floodway from
Floodway (RCl) to Flood Fringe (RC2) which is necessary for a levee to be permitted.
Therefore, the variance for the levee should be condirioned on rezoning the area from RCl to
RC2.
6. The request for variance is not based primarily on a desire to increase the value or income
potential of the parcel of Zand.
The request for variance is based primarily on a desire by MAC to be able to keep Holman
Field open and operating during periods during and after flood conditions as a service to its
tenants.
��
�
In addition to the findings above, the variances also meet the following findings Per Sec. 68.601.
Required for variances in the River Corridor Overlay District:
(a) Elpplications for variance to the provisions of thts chapter may be filed as provided in section �
61.600. The burden of proof shall rest with the applicant to demonstrate conclusively that such
d3s 3 G3 5
lw � k?
pb-363
1 �
�
variance will not result in a hazard to life or property and wi11 not adversely affect the safety, use
or stability of a public way, sZope or drainage channel, or the natural envir'anment; such proof
may include soiZs, geology and hydrology reports which sha11 be signed by registered
professional engineers. T�ariances shall be consistent with the general purposes of the standards
contained in this chapter- and state Zaw and the intent of applicable state and national laws and
programs. Although variances may be used to mod�pet�nissible methods offlood protection,
no variance shall have the effect of altowing in arry district uses prohibited in that district, permit
a lower degree of flood protection than the flood pYOtecrion elevation for the par-ticular ared, or
permit tt lesser degree offlood protection than required by state law.
The variances for slopes and for placement of sheet pile within 50 ft. of the ordinary high water
mark of the river will not result in a hazard to life or properiy once FEMA has approved the
compensatory excavafion and issued the L,etter of Map Revision. At that time, the flood
protection project will be out of the Floodway and will not cause an increase to the regional flood
as determined by FEMA in its Condifional Letter of map Revision dated 6/14/O5. The
compensatory excavafion will not adversely affect the safety, use, or stability of a public way,
slope, or drainage channel, or the natural environment. The compensatory excavation will create
a more natural shoreline that will be stabilized in part with natural vegetation. This work wiil
increase the stability of the slopes and enhance the natural environment in the area of the
excavation. The variznces for slopes and location of the sheet pile is consistent with the general
purposes of this chapter, state law, and the intent of state and national laws and programs that
permit letters of map revision to accommodate changing circumstances and the desires of
property owners and to protect developments from flooding. Because the levee/floodwall project
will not be approved unril after the affected properly has been taken out of the RCl-Floodway,
the variances will not allow any uses prohibited in the RC2 Flood Fringe district, and will result
in protection of existing development to the 100 year flood event as required by state 1aw.
NOW, THEREFORE, BE TT RESOLVED, by the Saint Paul Planning Commission that the
provisions of Secrions 68.402 and 68.601 are hereby waived to allow Compensatory Excavation
and a Flood Protection on properiy located at 644 Bayfield 5t ; and legally described as
Lampreys Addition To Saint Paul Bx Leases & Ex Nati Guard Air Base; Part E Of Ry Of Fol;
Part Of Govt I,ots 7-11 In Sec 4& C3ovt I,ot 4& 12 & E 1(2 Of 13 In Sec 5 T28 R22 & S1(2 Mol
Of Blks 10- 12 & Ail Of Blks 1-9 F Ambs Add & S 1!2 Mol Blk 5& All Of Blks; in accordance
with the appiication for variance and the site plan on file with the Zoning Administrator, subject
to the following condirions:
Work on the Compensatory Excavation cannot begin unril MAC obtains all other required
approvals including those from the Army Corps of Engineers, Minnesota Poilution Control
Agency and the Minnesota Department of Natural Resources.
�
2. Work on the I,evee / Flood Control System cannot be begin until M,AC obtains all required
approvals as specified in Section 2.3 of the Final Environmental Assessment (December
�dse 4 Gs 5
2��
!��-3�3
20Q5). As part of these approvals, FEMA must issue a Letter of Map Revision for the
boundary o£ the floodway and tke City Council must approve a revisio� to the River
Corric3or Zoning Map based on FBMA's actions so that a portion of the airport where the
Ievee would be built is rezoned from RCl (Floodway) to RC2 (Flood Fringe).
MOVED BY: Morton
SECONDED SY:
IN FAVOR: 15
AGAINST: 4(McCall, Lu. Gordon, Kramer):
MAILED: February 27, 2006
I:IAMANDAMERG�ZONAIGVSAVEl5989287Q17.DOC
approve variance
_d3s 5 G3 5
��
�
s
�/ U
��
�
��
ZONING COMMITTEE STAFF REPORT � �� � ��
FILE # 06 000725 and 06 000752
1. APPt{CANT: Metropolitan Airports Commission
HEARING DATE: 1119/06
2. TYPE OF APPLICATION: Site Plan Review and River Corridor Variances
3. LOCATIOAf: 644 Ba�e1d St
4. PIN & LEGAL DESCRIPTION: 042822320001 Lampreys Addition To Saint Paul Ex Leases & Ex
Natl Guard Air Base; Part E Of Ry Of Fol; Part Of Govt Lots 7-11 ln Sec 4& Govt Lot 4& 12 & E
1i2 Of 131n Sec 5 T28 R22 & S1/2 Mot Of Biks 10-12 & Afl Of Blks 1-9 F Ambs Add & S1/2 Mol
Bik 5& All Of Blks
5. PLANNING DISTRICT: 3
PRESENT ZONING: 11 and RC1/RC2
�
6. ZONING CODE REFERENCE: 68.225; 68.402; 68.403; 68.6�1; 61.402
7. STAFF REPORT DATE: 1/11/06
8: DATE RECE{VED: 12/29105
BY: Tom Beach and Patricia James
DEADLINE FOR ACTION: 2/27l06
A. PURPOSE: The Metropolitan Airports Commission is applying for Site Plan Review and River
Corridor Variances to widen a portion of the river channei and construct a flood-protection levee
and floodwall system. Variances are needed from the River Corridor Overlay Standards and
Criieria found in Section 68.402:
- Excavation proposed a(ong the shoreline to widen the River Channel wou(d imQact existing
slopes steeper than 12% (68.402.b.2) and some of the proposed shoreline slopes are steeper
than 18% (68.402.c.7)
- The earthen levee would have side stopes steeper than 18°l0 (68.402.c.7)
- The shest pile portion of the levee would be constructed within, 50' of the ordinary high water
mark 68.402.b.1.b)
B. PARCEL SIZE: The area of the proposed improvements is approximately 33 acres.
C. EXISTING LAND USE: Airport
D. SURROUNDING LAND USE:
North: Mississippi River and industriaV (f1)
East: Mississippi River (Industrial across the river) (12)
South: Wetlands, vacant land and industrial (11, 12)
West: Airport related uses and other industrial (11)
F. HISTORY/D{SCl4SS{ON: The Metropolitan Airports Commission (MAG) is proposing to
construct a levee and floodwall system around Hoiman Field to protect it during a 100- year flood
event. (See attached plans/aerial photos.) The top of the Ievee and flood walls would be
approximately 8 to 9 feet higher than the elevation of the airport. It woutd consist of three parts:
• The north part of the flood protection sys#em would be a sheet pile wal{ neas the river bank. It
would extend for approximately 5500 feet. It would be constructed near the edge of the
existing airport road that runs along the river and would avoid most of the existing shoreline
�
Ob�3��
vegetation. •
An earthen dike between runways 31 and 32 that would extend approximately1200 feet. This •
section would he approximately 600' the.river. `
The remainder of fhe levee would be a temporary waii thaf wouid only be erected when a flood
was predicted. tt would extend approximately 2900 feet. At its closets point, at the end of the
main runway, it would be approximately 200' from the shore.
As a part of this project MAC is also proposing to excavate approximately 155,000 cubic yards of
material along a 3,000'-long section of the rivershoreline near fhe end of runway 32 in order to
widen the river channel approximately 75'. This is being dorte to compensate for the impact of the
levee during flood condifions: if this compensatory excavation is done, the leveelfloodwall would
not increase the 100-year flood elevation above ifs curzent level. Most of the fill that is removed
would be taken off the site. The shoreline would be planted with native vegetation. MAC is
proposing to use native grasses for the new vegetation. lt wants to avoid using trees and shrubs
that might aftract birds which can be a hazard to aircraft. The existing shoreline is subject to
erosion and MAC's plan calls for using a limifec! amount of rip rap to stabilize the shoreline.
The Compensatory Excayation must be done because part of the levee wouid be built in an area
that is currently designated RC1 (Floodway). The River Corridor regulations only allow levees in
the Floodway "where the intent is to profect fndividua( sfructures° (Section 68.213.f} and the
Compensatory Excavation would enable this area to be reclassified from RC1 to RC2 (Flood
Fringe) as follows. The Compensatory Excavation to widen the river channel would be done first.
When it is completed, MAC would request FEMA to adjust it's flood maps to move the boundary of
the Floodway a few hundred feet closer to the river shore. If this is done, all of the levee would be
out of the Floodway. (FEMA has already given pre(iminary approval for the changing the floodway
boundary in the form of a Conditional Letter of Map Revision dated 6/94/05. (See attached,) �.
htowever, FEMA cannot give fnal approval until the Compensatory Excavafion has been
completed.) After FEMA issues its Final Letter of Map Revision (LOMR), it will notify fhe City that
the Floodway/Fiood Fringe boundary has peen changed and that the City should revise its River
Corridor Zoning fvtaps to reflect the changes in the FEMA maps and reclassify the area RC2
(Flood Fringe) from RC1 (Floodway).
G. DISTRlCT COUNCIL RECOMMENDATION: The West Side Citizens Organization had not sent
a position on the levee project by the time the staff report was mailed out.
RNER CORR/DOR VARIANCES ..................................................................................:
The pro}ect requires the foitowing variances from the River Corridor Overlay Standards and Criteria
found in Section 68.402:
- Compensatory Excavation proposed along the shoreline to widen the River Channel would impact
e�tisting slopes steeper than 12% (68.402.b.2) and some of the slopes proposed for the new ,
shoreline are steeper than 18%0 (68.402.c.7)
- The earthen levee wou(d have side slopes steeper fhan 18% (68.402.c.7} and the sheet pile
portion of the levee wauld be constructed within 5o' of the ordinary high water mark 68.402.b.1.b)
H. FINDINGS:
Ail variances must meet the following findings per Section 61.601:
1. The property in question cannot be put to a reasonab/e use under fhe sfrict provisions of the
�
�J
�
code. � � _ � � �
The airport had fo close for a tota{ of 210 days during and after the floods in 1965, 1969, 1993,
1997 and 2001. Costs fo tenants at the airport for the 2001 flood (a 75 year flood) were $3.8
million plus additionai costs due to delays at the Minneapolis-Saint Paui airport caused by
fiights having to be diverted there from Hotman Fiefd.
A levee/floodwall system to protect the airport from flooding is a reasonable use that cannot be
constructed under the strict provisions of the code:
- The levee cannot be built without first doing the Compensatory Excavation and it is not
possible to do this excavation without affecting slopes on the existing shoreline that are
steeper than 12%. The existing shoreline was created with fill that was used to create the
airport and typicalty has steep slopes in excess of 50°l0. �
- Most of the new, relocafed shoreline wouid have slopes less steep than 18%, bringing the
shoreline more into compliance with current standards. However, steeper slopes are
needed in certain locations where room is limited, such as near the end ofi the runway.
But even in these areas, the new shoreline will be less steep than the existing.
- Levees are typically built with side slopes of 30%. Requiring side slopes of 18% as
required by the River Corridor Ordinance would is impractical and would not provide any
benefit.
- The location of the sheet pile portion of the levee is determined by the location of existing
BayPield Street and the existing hanger building. It is not practical to locate this portion of
the levee further from the shoreline.
2. The plight of the land owner is due fo circumstances unique to this property, and these
circumstances were not created by the land owner.
Holman Field was created in the floodplain of the Mississippi River in the late 1920's by the Ciry
of Saint Paul. The MAC took over ownership and operation of the facility in August, 1944. The
plight of the landowner is due to the unique circumstance of owning an existing airport in a
location subject to periodic flooding and the location of the streets, hangers and runways. This
situation was not created by the current land owner.
The factors that require variances are existing conditions that were not created by the owner.
These include the location.
3. The proposed variance is in keeping with the spirit and infent of the code, and is consisfenf with
the health, safety, comfort, morals and welfa�e of the inhabitants of the City of St. Paul.
The variances for the,Compensatory Excavation are consistent with the spirit and intent of the
code. The existing shoreline was created with fifl that was used to create the airport. The
existing shoreline slopes are greater than 50% and are subject to erosion. The proposed
shoreline, which would have a more stable slope and would also be stabilized with native
vegetation, is in keeping with the spirit and intend of the code.
The variances for the levee and floodwall are consistent with the spirit and intent of the code.
The slope restrictions and distance requirements are intended to controf erosion and
� development impact on the river from individual buildings, not from flood control projects. The
side slopes for the earthen levee will not have an impact on the character of the river. The
reduced setback from the river for the sheei pile portion of the project wifl not impact the
character of the river because it will be screened by existing vegetation and wiil not be visible
from the river.
4. The proposed variance will not impair an adequafe supply of light and air fo adjacent properfy,
� 2F i
��?-°����
nor wilJ it alter the essential character of the surrounding area or unreasonably diminish �
established property values within fhe surrounding area. �
�,
The tevee wiii not have change the visual character of the area. The sheet piling will be hidden
from view from the river by the existing trees and other vegetation. The temporary levee will not
be visible except when it is erected during flood conditions. The earthen (evee will be set back
from the river and will blend in wifh the surrounding area.
If the compensatory excavation is done, the levee will not raise the Ievel of the river during flood
conditions.
Tfie compensatory excavation will not change the essential character of the shoreline. There
are currentiy problems with erosion along the shoreline and the proposed planting with native
grasses and limited use of rip rap wiil reduce the erosion and stabilize the sfioriine..
Tfie Compensatory Excavation and the Flood Protection System and its impact on the river
must also be reviewed and approved by other agencies including the Army Corps of
Engineers, Minnesota Pollution Control Agency and the Minnesota Department of Natural
Resources.
5. The variance, if granted, wou(d not permit any use that is not permitted under the provisions of
the code for the property in the district where the affecfed land is /ocafed, nor would it alter or
change the zoning disfrict class�cafion of the property.
The compensatory excavation will not change the use of the property. However, the levee is
not permitted currentiy since portions of it would be located in the Ffoodway, and levees are
onty permitted in the Floodway °where the intent is to protect individual sfructures." Once the
compensatory excavation has been completed and approved by FEMA and FEMA has issued
its LOMR, the City will be notified that the floodway boundary has changed. At that time, the
City Council will be asked to rezone the area removed from the floodway from Floodway (ftC1)
to Flood Fringe (RC2) which is necessary for a levee to be permitted. Therefore, the vanance
for the levee should be conditioned on rezoning the area from RC1 to RC2.
6. The requesf for variance is not based primarily on a desire to increase fhe value or income
potential of the parcel of land.
The request for variance is based primarily on a desire by MAC to be able to keep Holman Fie(d
open and operating during periods during and after flood conditions as a service to its tenants.
In addition to the findings above, variances in the River Cortidor must also meet the
foilowing findings per Sec. 68.601.
(aj Applications for variance to the provisions of this cirapter may be filed as provided in section
61.600. The burden of proof shall rest with fhe applicant to demonsfrate conclusnrely that such
variance wiil not result in a hazard to tife or property and will not adversely affect the safety, use or
stabilify of a public way, slope or drainage channel, or fhe natura( environment; such proof may
include soils, geo(ogy and hydrology reports which shall be signed by registered professional
engineers. Variances shall be consistent with the general purposes of the sfandards contained i�
this chapfer and state law and the infent of applicable state and national laws and programs.
Although variances may be used to modify permissible methods of flood protection, no variance
shall have the effect of ailowing in any district uses prohibited in fhat districf, permit a /ower degree
of flood profection than the flood profection elevation for the parficular area, or permit a lesser
�
��
degree of tlood protectio� than required by state law.
06-3�3
The variances for siopes and for placemen4 of sheet pile within 50 ft. of the ordinary high water
mark of the river wifl not result in a hazard to life or prapefij once FEMA has approved the
compensatory excavation and issued the Letter of Map Revision. At that fime, the flood protection
project will be out of fhe Floodway and will not cause an increase to the regionai flood as
determined by FEMA in its Conditional Letter of map Revision dafed 6/14/05. The compensafory
excavation wi41 not adversely aifect fhe safety, use, or stability of a public way, slope, or drainage
channel, or the natural environment. The compensatory excavation will create a more natural
shoreline that will be stabilized in part with nafurai vegetation. This work wiil increase the stability
of the slopes and enhance the naturai environment in the area of the excavation. The variances
for s4opes and locafion of the sheet pile is consistent with the general purposes of this chapter,
state law, and the intent of state and nationai laws and programs that permit letfers of map
revision to accommodate changing circumstances and the desires of property owners and to
protect developments from flooding. Because the levee/floodwail project wi{f not be approved unti{
after the affected propesty has been taken out of the RC1-Floodway, the variances will not allow
any uses prohibited in the RC2 Flood Fringe district, and will result in protection of existing
development to the 100 year flood event as required by state law.
� 1. STAFF RECOMME[VDATION FOR THE VARIANCE: Based on these findings, staff recommends
approval of the variances for the Compensatory Excavation and the Levee subject to the foliowing
conditions:
Work on the Compensatory Excavation cannot begin until MAC obtains all other required
approvals including those from the Army Corps of Engineers, Minnesota Pollution Control Agency
and the Minnesota Department of Natural Resources.
Work on the Levee / Flood Control System cannot be begin until MAC obtains all required
approvals as specified in Section 2.3 of the Finai Environmental Assessment (December 2005).
As part of these approvais, FEMA must issue a Letter of Map Revision for the boundary of the
floodway and the City Council must approve a revision to the River Corridor Zoning Map based on
FEMA's actions so that a portion of the airport where the levee would be buiit is rezoned from RC1
(Floodway) to RC2 (Flood Fringe).
SlTE PLAN REVIEW ......................................................................................................................
� Site pian review is required for "any filling, excavation or tree removal that disturbs an area greater
than 10,000 square feet "(Section 62.402.14)
J. FINDINGS: Section 62.108(c) of the Zoning Code says that in "order to approve the site plan,
the planning commission shall consider and find that the site pian is consistent with" the findings
{isted beiow.
Z 23
�6-3b�
1. The city's adopted comprehensive plan and development or project plans for sub-areas of the ••
cify.
The Land Use Chapter of the Comprehensive Plan, Policy 7.6.1 states: "MSP and Holman
Field airports are both very important to Saint Paul's economy and quality of I'rfe. The City
supports maintaining and improving them in their present Iocations with full attention to noise
mitigafion " Tfie proposed tevee/ftoodwa(t project is consistent with this policy.
The Mississippi River Corridor Chapter of the Comprehensive Plan, Objective 5.1 states:
"Continue commercial and industrial uses of river corridor land and water, consistent with the
Saint Pal Land Use Plan:' As stated a6ove, the Land Use Plan supports maintaining and
impraving Nolman Fietd in its present location. Objec6ve 6,5 states: "Encourage protection
and restoration of river corridor cultural resources, including historic structures, culturally
significant landscapes, and archaeological and ethnographic resources.° As noted previously,
the floodwall/levee project will protect the historic Administration Building from flooding to the
100 year event. Policy 4.2.2 stafes, in part: `"fhe Cify wi(( encourage use of native vegefation
or other compatible floodplairt vegetation in redevelopment projects. Where appropriate, when
redeveloping or stabilizing the rive�'s edge, soil bio-engineering techniques and native
plantings wiil be used in combination with more traditionai engineered solutions... ° The
proposed compensatory excavation will use native plantings to stabilize the river's edge. The
sheet pile ftood wati wiil be located so as to refain existing vegetafion to the greatest extent
possible.
2. Applicable ordinances of the City of Saint Paul. The foilowing ordinance sections apply: �
Section 68.402. regulates protection of shorelands, floodplains, wetlands and bluffs in the
River Corridor.
(a) Generally. Development shall be conducted so that the smallest practical area of land be
developed at any one fime and that each area be subjecfed to as little erosion or flood damage
as possible during and after development.
(b) Pfacemenf of structures.
(1) The following minimum setbacks for each c/ass of public waters as described in Minnesota
Regulations NR-82 shall apply to all structures except thase spec�ed as exceptions in
subsection (7) below.
a. For natural environment waters at least two hundred (200) feet from the normal high water
mark for lots not served by public sewer and at least one hundred fifty (150) feet from the
ordinary high water mark for lots served by public sewers. This section is not applicable.
b. For genera/ development waters at least seventy-five (75) feet from the normal high water
mark far lots not senred by public sewer and at leasf fifty (50) feet from the ordinary high wafer
mark for lots served by public sewer. The applicant has requested a variance of this standard
(see Fndings H.1 to H.5).
(2) No commercial or industria! development shall be permitfed on slopes greater than twelve
(92) percent. The applicant has requested a variance of this standard. (see Findings H.1 to
H.5) �
(3) No residential development shall be permitted on slopes greater than eighteen (?8)
percent. This section is not appliqble.
(4) Bluff development shall take place at least forty (40) feet landward of all blufflines. This
2 z �f
� section is not applicable. � � � � � �
(5} Transportation, utility and other transmission service facilities and corridors sha11 avoid:
a. Steep slopes;
b. intrusions into or over streams, vaileys and'open exposures of water; ;
c. Intrusions into ridge crests and high points;
d. Creating tunnel vistas;
e. Wetiands;
f. Forests by running along fringe rather than through them. If necessary, to route
through forests, utilize open areas in order to minimize cutting;
g. Soils susceptible to erosion, which would create sedimentation and pollution
problems;
h. Areas of unstable soils which would be subject to extensive slippages;
i. Areas with high water tables; and
j. Open space recreation areas
This section is not applicable since the airport is an existing use.
(6) At river crossing points, public facilities, crossing corridors and other rights-of-way shall be
consolidated, so that the smallest area possible is devoted to crossing. This section is not
applicable.
(7) Exceptions:
a. Location of piers and docks sha// be controfled by applicable state and local regulations.
� b. Commercfal, industrial or permitted open space uses requiring locafion on public waters
may be claser to such wafers fhan fhe sefbacks speci�ed in fhe standard set out in subsection
(3) above. This section is not app4icable.
(c) Grading and filling.
(9) A minimum amount of fiIling shafl be allowed when necessary, but in no case shall the
foilowing restrictions on filiing be exceeded. Furthermore, fiil opportunities sha�i be farrly
apportioned to riparian landowners. The deve%per shail evaluate ownership patterns,
configuration and the bottom profile of each wetiand basin before fill opportunities are
apportioned.
(2) Grading and filling in shoreland areas (when ailowabie) or any other substantial atteration
of the natural topography shall be controlied in accordance with the following criteria:
a. The smailest amount of bare ground shall be exposed for as short a time as feasible.
b. Temporary ground cover shall be used.
c. Methods to prevent erosion and trap sediment shall be employed.
d. Fill shail be stabilized.
These standards are met. The size of the compensatory excavation area has been reduced
by the applicant to ensure that the smallest amount of ground shall be exposed. Silt fence
and other measures as needed will be used to prevent erosion and trap sediment. The new
shoreline will be stabilized with riprap and native vegetation
(3) Only fill free af chemical pollutants and organic wastes sha!/ be used. At such time as the
� levee can be constructed, the applicant will ensure that fill used to construct the levee wilf ineet
this condition.
(4) Tofai filling shall not cause the fotal natural flood storage capacity of fhe wet/and to fail
be/ow the nafural volume of runoff from the wetland and watershed generated by a 100 year
sform, as defined by fhe Nafiona/ Weather Service. After the afEected poRion of the airport
property is removed from the Fioodway by FEMA, the fill for the {evee as weN as the sheet pile
2 Z-�
; . , a�
floodwails and temporary floodwalls will meet this condition.
(5) Solid waste disposa! and landfdl sha/! not be permitted in fhe Rnrer Corridor Disirict. The
applicant is not requesting these uses.
(6) Development shafl frt exisfing topography and vegetation with a minimum of clearing and
grading. The applicant is proposing a minimum development that will protect the airport to the
100 year flood event. In times of greater flooding, the airport will be closed. This minimal flood
protection development meets this condition.
(7) No rehabilitation siopes shall be sfeeper than eighteen (78) percent slope. The applicant
has requested a variance of Yhis standard. (see Findings H.1 to N.5)
s
(8) Dredging of a shoreland or wetland shall be alfowed on/y when it will not have adverse
effect upon the wetland. Dredging when allowed sha�l be limited as follows:
a. !f shall be located in the areas of minimum vegetafion.
b. It shall not significanfly change the water flow characteristics.
c. The size of the dredged area shall be limited fo fhe abso/ute minimum.
d. Deposif of dredged material sha0 not result in a change in the current flow, or in destruction
of vegetation or fish spawning areas, or in water pollution.
(C.F. No. 03-241, § 2, 3-26-03) These standards are met by the application. Existing
vegetation in the area of compensatory excavation is minimal, and the shoreline has become
severely eroded in places. The eiccavation is intended to improve water flow characterisfics in
this part of the channel. The size of fhe area affected by the compensatory excavation has
been kept to the absolute minimum, and the applicant has stated thaY the excavated material �
wiil be tested and disposed of properly.
Sec. 68.403. Protection of wild!!fe and vegetation.
Development sf�all be conducted so as to avoid intrusion into animal and plant habitats.
(a} No alteration of the nafural environment or removal of vegetation shall be permitted when
such alteration or removai would diminish the ability of dependent wildlife to survive in fhe
River Corridor. The compensatory excavation and levee construction are not in an area that is
currently habitable by wildlife. The sheet pile floodwall will be located next to the existing
airport road, and the existing riverward vegetation will be retained for wildlife habitat and
screening of the sheet pile from the river.
(b) IVo wetland or bluffline vegetatron shall be removed or, altered except that required for the
placement of structures. No wetland or blufftine vegetation will be affected by this projecf.
Shoreline vegetation will be retained, replaced, or added where possible.
(c) Clear cutting shaff be prohibited except as necessary for pfacing approved pu6lic roads,
ufifities, sfrucEures and parking areas. IVo clearcutting is associated with this project.
(d) Naturai vegetation shall be restored after any consfruction projecf. The applicant will
restore native vegetation to the shoreline. No natural vegetation exists in the area of the
airport where the levee will be located. Vegetation riverward of the sheet pile floodwali will be
retained where possible.
(e) Watering areas necessary for plant surviva! shal! be maintained or provided. No special
requirements are anticipated for plants irt the area.
(fl Development shall nof cause exfreme flucfuafions of water levels or unnatural changes in
wafer temperafure, water quality, wafer currents or movements whic(� may have an adverse
�
���
06-363
��
�
impact on endangered or unique species ot Birds or wildlife. No fluctuafions in waster fevels or
temperature or wafer quality wifi resu{i from tfiis project. Changes to water currents or
movements wi{I not have an advetse impact on birds or wildlife.
3. Preservation of unique geo(ogic, geographic or historica!(y sign�cant characteristics of the city
and environmentally sensitive areas.
The site plan is consistent with the preservation of environmentally sensitive areas. The
Compensatory Excavation wiil affect 3,000' of shoreline near the south end of the airport.
However, the condition of much of the existing shoreline, which was created with fitt, is not
stable: it is steep and being undermined by erosion. There is a row of shrubs approximateiy
12' tatf at the top of tfie bank and the area behind it is non-native grass that is mowed. The
shoreline after the Compensatary Excavation wou4d stabilize the shoreline by using a minimal
amount of rip rap and planting native grasses.
The sheet piling that wiil be built parailel to Ba�eld Street about 6' from the edge of the paved
roadway. Because it would be so ciose to the street, it would have a minimal affect on existing
vegetation and would not be visible from the river because it wiil be screened by the existing
vegetation.
The site plan is consistent with the preservation of historically significant characteristics of the
city. The ferminal buiiding has been nationafly designated as an historic buifding and the flood
wall/ tevee would hetp psotect it from periodic flooding.
4. Protection of adjacenf and neighboring properfies through reasonable provision for such
mafters as surface water drainage, sound and sight buffers, preservation of views, light and
air, and those aspects of design which may have substantial effects on neighboring land uses.
The site plan is consistent with this finding. The levee will not increase the levei of the river
during flood conditions. At one time there were concems that the levee woufd increase the
tevel of the river, but this wilf not happen if the Compensatory Excavation is done to widen the
river channel and increase its capacity.
The levee will not be noticeable from the river. The sheet piling will be well screened by a
existing trees and shrubs along the shoreline.
5. The arrangement of buildings, uses and facilities of the proposed development in order to
assure abutting property and/or its occupants will not be unreasonably affected.
The site plan is consistent with this finding. The proposed Compensatory Excavation and
levee will not affect abutting property.
6 Creation of energy-conserving design through landscaping and (ocation, orientation and
e%vation of structures.
The site pian is consistent with this finding.
�
7 Safety and convenience of both vehicular and pedestrian traffic both within the site and in
relation to access sfreets, including tratfic circulation ieatures, the locations and design of
entrances and exits and parking areas within fhe site.
The site plan will have no impact on vehicutar or pedestrian traffic and is consistent with this
finding.
�
t .. .
8 The satisfactory availabilify and capacify of storm and sanitary sewers, including solufions fo
any drainage problems rn the area of the development. E
7he site plan is consistent with this finding. MRC is currently making improvements to the
sewer and drainage system for the airport that wiA accommodate the proposed Ievee.
9. Su�cient landscaping, fences, walls and parking necessary to meet the above objectives.
The site plan is consistent with fhis finding. Native species wouid be planted in the area of the
Compensatory Excavafion where the shoreline would be widened. The existing shoreline in
this area has shrubs along the shoreline and non-native grass. MAC wants to limit the
replacement p(anting to nafive grasses because of concems that planting new shrubs would
provide habitaf for 6irds that could cause a hazard for aircraft.
Almost alt of the existing landscaping along the shoreline where the sheet piling is proposed
would be retained would be sufficient to screen the piling ir.om view.
10 Site accessibiliiy in accordance with the provisions of the Americans with Disabitities Act
(ADA), including parking spaces, passenger loading zones and accessible routes.
The site plan will have no impact on handicapped accessibilify and is consistent with this
finding.
11. Provision for erosion and sediment control as spec�ed in the "Ramsey Erosion Sediment and
Control Handbook"
Silt fence will be installed where needed prior to work beginning on the project to ensure that
sediment does oot get to the river or a nearby wetland. Staff will require a more detailed plan
for sediment control for the Compensatory Excavation prior to a permit for this work being
issued.
K. STAFF RECOMMENDATION: Based on the findings above, the staif recommends approval of
the site plan to allow Compensatory Excavation and a Levee/ Fiood Control System as shown ort
the attached site plan at 644 Ba�eld Street subject to the following conditions:
Work on the Compensatory Excavation cannot begin until MAC obtains alI other required
approvals inctuding fhose from the Army Corps of Engineers, Minnesota Pollution Control Agency
and the Minnesota Department of Natural Resources.
��
�
Work on the Levee / Flood Control System cannot be begin, until MAC obtains all required
approvals as specified in Section 2,3 of the Final Environmenta! Assessment (December 2005).
As part of these approvals, FEMA must issue a Le#er of Map Revision for the boundary of the
floodway and the City Council must approve a revision to the River Corridor Zoning Map based on
FEMA's actions so that a portion of the airport where the levee would be built is rezoned from RC1
(Floodway) to RC2 (Flood Fringe).
ATTACHMEN7S
Letters from MAC (12/9/05 and 12J29/05)
CLOMR tetter from FEMA
Lette� in opposition
Plans
Photos
�
�� �
. . .. St Paui F?otivntativn Airgort� . . ...
P�rc�}�r�sec� �heet Pi�e t?vervie�
�� -: -�:.>.�_ �.. �._�- �. ..��.7..a.��:r:�.:�: ;�.;
���
:,�1
���
4 � . � � i{yy �L'� � �A
v
�r
�i `-
�:. ♦ � "g. �'
k l S ,
.^ x
� ro p s 3 *�
� � �
3
1 �a °' � �`. . "w� :
.. � : , A �a ��
� d
t
� i N �^� �+�, ``� ' r
§
w�4��•, � i � �
'`�:o �. ." a, .; t.
� i t
�
�.
r
v
,�
r��
�
�
�� � �
��; ,� �`�� �
� ,
;"�h ! ."��=.�.`�ti'�.�` g
r,.
�E; ���
9 ` �� t t ..
� � � k
� s
M �
�� j € �
S �, �
.3 .
h
� Y
6°
� W
�
�. � - x .:. xe. s .
S _i
K �
't
#r� ' �
w � 3 �"�
� $ �
�� � '.� "� �'
i
�� � �
�"�i � a
m;
g �: _
: '
� a s�J�
' ° ._ # .
»i:. . �'#�s.*'. .. . - ..
� 4 . !.,� ';d;A
p
F 't
L � ' (Q ` pv°, > � , '�_
.. . . „ '. a x.
� �.
.
: rt e
�-
� � � , �a
.� . ,ps� � t.
h YA ��� r�. ��
1
� . � v i�t �., �.� �Y'�.. "'v ' Y � �'
. t�h. �d � rw .��, '
.. � t `1 ` . � : 4.' .
i��'.�«�:n'�`�e.° ;� �. '
� r .�
ra
�^.5';i . ... . .
`�+'rr :���wr � a �' � � � Yt a '� �' � ``�k��'� ,�� �{ � � ,..
i`: ' ,;'F � t i � t c. "� ,��Y x �. �' � �„3af�,�'�'� � . . ,_
i �
c �`s���r''.�x �u. � � x . -P'`a'�, �
� � �� 6 � � + `
y�w n a�
,n�� t i �, `� � T,�'.'." �i �'L 4 '�'`k � � � ` .
�Is'x:.4 1 � ` ' � � . t = . C .
g � y � K i y
�'� ;'c"^ a `.,'``�� x "i `� �� . ' ,�- �� ��� ` .
�� Y -
� �� �# e; � . ���i'+`,(�t� �tF �yu 4: ,'�•�� ty ���> w
'4(` x�� � ������`k�y������„'� q ��li .��i'� T . �S �(�� � r �P2� K u.�° a,� , -
� � 7�J d"� ��t � ��t ���� �� � i t � � � ' .
; ''� si ra�'!,s� . ., � n � p�; �.�- �� � � �
`� � �� � `� a,: s^�^"h "`.��e �'� f f f 'e�+ rc ,td' $r�`,nr d �,'�d � � � s e i. ^
'� r N' 4 k }� ++0a�e,. µ
3 { a $' �`�`? �. ��y �'�� ��„��}��' ory�'�4 -3� ,� s. . �k , �,f a� �
"�„�s ' �?'�1� ' � $F,� ����' � � n � t S� ' �,' '�i�' . � �� , � _ i � [. c . .
,�yp �` r� -r r 3 r 'v r , .C.'z ; � �-. ' ,� �'.�_.
' �� � � 4 F r �'�^�'' "� r ; 4 , � �'�" �'� � r � �",''�' °j�� `� ,« ' .
r�` ��"t�y �'�t' ���� t�A k ��: t } ` ��� � r i'� xea�F �'�� � .�:y t�f� .�.. . . � �.
., ,.,��,-� �k , � "'��.. ,.awNi7d,��'�,a' fsww'��t,�'r.'�.. r.G. �... .,,. #Ls, t � `;1t6 ��'� , . . . Ul��i�: t r��tl.s� , _ .. L:.._.._......:
�,{ P� te
��
�J
� � vC,� c IrK'�idN
� ��},,�,P (eve�,
_
�
�
P
k
N
Cf�
W
�:.
n.�
G
�/a
�Ya vSea �evee W ou I� '� i t� i h-� �+s-��� wa 11
G � �1 1 Ll � �-2✓f �Y CS.0 �a t�i N �.+ 1�-71' � ^ O�S' 'G�g, � VN 1 �
�l �.
� - J - - �
Sr�� p���, I��� w��Ea I� bti��� r.��,� ��,
a � C�°f � S-k..rrz�
�a�,r a3 r�. wd9 :�v,y�,;w,,. .
� � �u r+rnaxi�' ,y �, �, � , ,
Ebqg a �} vj "
eY �G n y.p, � T �:J� 1�,"t'- 4Yn� ..
!+ xwfK 'e �.d%4! �.�3 i. .
�,� .,,_��p�n�Akv �., firw�' c�'� nbt,i� rai��, .
i aY
� 4 yxs��„ uut..,� , . .
,. „°"v� _ ?" .. .
K ��Y� ^ � q �r . ; ,
k �" ,� �� �., �. �� JF s .
� � !7' 4 �` _ } r � t��
� I.9 � . � 69 ^,
�f i t�. q�, �r�,. r`y�` � . � �
� frt � .�L�� fs �::,� ' + " ' ,A
, .., . _ o..�" s
�, � i v � r � ' ,
x a
i �,
a t
� b `4 �'
r w r } z. �
, `5 - ��fi� ��" � - -
� r nr �'' bt u� r�"�*h,sJ����}"� -.. � � �. r ' �� �:' 1 1 ' ( �4di . ��bIGF��y'^
�
�,t.�nt ""�1"�. S�k'. . � 1 1 .,� � ai I �"Q� '�'�
�_.. '�� u&,t'�k...s�ss„�wm,L.,. . :1 � i .
. . . � .. c a.� : . {. ,,.
�
� I���," ;
. - -� r �e.�...t.,��� 5 1��� iw�i.m._..._._ie..e.�YdJ��.du;v
� ,aM1rz w . `v�Y � � e :' `,_� � G
� J� r��G���� ` .. .� g vYd
r �� � u r�'*^-��� ,�'
a �Yt.i� �c � + ( n�r � � ' . �1 �, n -
; �o.W
. f�" �+I�M1 '
��I .y� • �� � �l . SW'�� V � , .
a� � v � ���
1, 6 t ti �1 ` ' �3...
�k. + /�,�} F �'��i7$<v,"��f�� � y r�kin"�� .
l� .1 � � �� A h��� <''Xk°av?rvEp��°p'nm;
� 1 ;,uar�n e ar�'nrn��al' <<` �����,.
��t��i�"���dr4l���� � �fi��+� � tii��G�
+�i r2 , �+, � o �,� �, �g.? � , � �
, s
� 1�����'� t � a°s;�;� , � �.
; , � , � I
ri i, �
,�� . �� , �, ; � �� `: r '
� b d, . 1 li. �t �� 1 �1 �
1 � 1 � 1
)r ' / 4i .o- � { � '.
rl �h)P O.ryI/l � 1 l)1 � � • "k
/� .. u S� { 1 , � � � 6 1 � �! '� " 4 r
v
� � r � a �� \ I
f��� Y � � � , iS{tl,��jk�� '���
� 'e` �6�0`r 'I�� e � i t�' �dg��t
����.�t�� >> ir A �� ° r u�� i s� kr�i��� �,
!
i i� � 1
� a
�����i�i1F�P� Q Hi , �il� ���d� �,���I .' 4 � Z i�}�.-��� �il _.
�"F� �
4) , �
♦1
f �'il���i` �
i1e �
j� ry 4��I ..
�� � � � �ZYP '� , �P : _
JK flH a �� �� p �
� ' �r� �� ��,� al`� s�;
� � y ,�
, , ,
/ h
��� � � � �� . �
E. ��� �V �� � y F 'nf �' ° . .!.��'d�� � r ;1
lt4� �r � z
� � ,
, , �
P �i�� i �� t,x �
+'� � J w 9� �� � J �4�T . �°iU + Y 5
� � F� ��''.` � '�' 4t�
p I � 1 J �1@rv ��
��m � e���'�4�� . CS���'+�\V:AY����d�"�'�� cr� u 4 ! rf � p ^ * � � � . �:i
,�
� .�
�,
f�
i
�::
az ;
,
a ,t
�
�
'' ' ; � i :
_�{�tb .
��. .
��;:
£
. � r,
_�
� _,.
���,.��
- r �,
�p. �<
`uS£ , fr � #.�
�j'' .
£�
$ �'
n 't]".
l i'
FE
r "�
_ �
j
-_ +
t�'..
a
€:
�'�
�
4
s *
�_ :
�a.
�3
5
'f
»�n„
9
`
s � E :
� ;
�� I
i �"y +
K � ;[,
��
���
�k' i
� � t
_. � ..F'� , x .
�� ._
� ' z
: i
��i
. -.�` -�� � ..
♦
� �? l '
X � �'
i r�
� ' y � . .
�, I t
�, `:
!; c
�
�
�Y�'`�.� '+--'� F' ,
,� � � � � �
���� �� . � �z
. ^' ,, �
r+t r �
��� x� T ���
�"r'J1�-;" � ��`t�
ffi��� A p
c �� �
� .s a�
� �i
��� � n
��.� �:
. ```� � � -
�—������ : EE €
�� y ��-, li �. .
t,. '�.:...
���� . h
.,-� �. .. ,' , . ..
`A �r:��. . .
�
� � '. i �� � � ,_
�h y
S�' r : 1 �'� i .
�
�� 1 5
�� 3 �
� 5F y { � iq£ e
��� � � iS `E'� ' t" S
t �
L`
���� � �� � � � #
T
"x � b
�� �� 1 � } �'�,n�&_
,r s q , � n ,�- _ � `�.'
�„ �- - ' ( � _ .,�xe .
a -;� �+�. e - r i; �
s" q, k �' n y`q �, ,: '
�'�_ � � s'� g � < �,�: �"
� � �
�'- 1� ��,�� �"'�� ; �
�' �,
`�`��:: �� '� E , � v * � � - .�,� 4 , : .i
. . a`�v,� , f,�' �3- , t�� c ..
,
,� ;� •.f ,
t ,� ;,, «:
� y�� £ Y [y. l
i .. +� :vS �ZR t
� ,' {
� 4 f � � �[�'�1
g � F �}.
' t�' {�t � �j }� 7`
�. � � ��f a
� ,
� E .,�f �r�F r f �jt � t.
{ r � : �
� .��� a.' ��� �
7 � 4 — s�, v,.M � '` 8
� +��- 4 �� � '� 0�' ; � � a '. �� �
� � b �' i I��� - � a � `
+ �" �i t a �, 'ti °' �4 .
` � � �� �'�°� �; �' �'- i F
r ,/# v ,! t,;� � � st
i l8 y �� �, 1
� l. V �t. �S�„ t ` f
� � 1k �Yk 7
i��`
. ! Y'-i}; � .
� f
j a
� y �
�-
� E
..- ;,
�� � -' Y ��..
�r w
. �� j� � � ��.
c a
_ Fi� k �. � �"
� 3
�� �
�� � � s .
.�"� - � ,� , .
- � -� � � a �� •t
t� �: b
�� ' _ . -. � �-
��
,p �4� �
P� ai� '� . ��"
� .. ... - y *i :
�� �.
� '' �
� Y ��
� � y 1; �
�� '� 4 4i
� }
��
�
v � �
II �� {
� }
�
-, ' � ! i � . �� 7 � ..
f � � �
- ` g.:
i � ,
� _ t ��� f .
�` � _ R i
x�.. �'s��.
� � i �
. � � �k
� r �� �y��'.. . .� ' � � .�:
r
3
D�-3G �
MOVE TO GRANT THE APPEAL AND DENY THE FOLLOWING VAT2IANCES
GRANTED BY THE PLANNING CONIlVIISSION TO THE M.A.C.:
1. Excavation of slopes steeper than 12% [Leg. Code § 68.402(b)].
2. Excavation of slopes steeper than 18% [Leg. Code § 68.402(c)(7)].
3. Construction of earthen levee with slopes steeper than 18% [Leg. Code § 68.402(c)(7)].
4. Construction cvithin 50 feet of ordinary high water mark [Leg. Code § 68.402(b)(1)(b)].
BASED UPON THE FOLLOWING REASONS:
(a) The property in question can be put to a reasonable use under the strict provisions of
the code;
The airport at Holman Field has been in operation since 1929 without the protection of a
floodwall. Holman Field operates today without the protection of the floodwall. The
property has been and conrinues to be put to a reasonable use under the strict provisions
of the code. Excavation of steep slopes and encroachment of a floodwall within the
ordinary high water mazk aze therefore unnecessary to put the property to a reasonable
use.
Airports, by the very nature of their complex operations, are susceptible to closures
related to extemal factors such as inclement weather. It is reasonable to assume a limited
amount of closure related to natural occurrences. This does not mean that the property
cannot be put to a reasonable use under the strict provisions of the code.
(b) The plight of the landowner is not due to circumstances unique to the property, and
these circutnstances were not created by the landowner;
Holman Field is located immediately adjacent to the Mississippi River in a floodplain.
Flooding within the floodplain is not unique. Flooding and high water levels are
common circumstances for any property along a river., Therefore flooding is not unique
to the Holman Field property.
Holman Field's location on the floodplain is well know as MAC assumed operations at
Holman Field in 1943. It is not reasonable to expect that the site will be free from
flooding at a11 times. In fact, even with construction of the proposed floodwall, MAC
lrnows that the property will not be free from flooding during events with greater than a
100 year flood intensity level.
Because there is nothing unique about this floodplain property, there is no reason to grant
slope variances or allow construction within the ordinary high water mark.
(c) The proposed variance is not in keeping with the spirit and intent of the code, and is
inconsistent with the health, safety, comfort, morals and welfare of the inhabitants of the
city;
dG-3��
The City opted the River Corridor Dverlay District and its subclassifications provide
comprehensive floodplain and river bluff management for the city in accordance with the
polices of Minnesota Statutes (Chapters 103 and 116G).
The proposed variances are inconsistent with L.eg. Code §68.101(1), (2), (3), (5), (6), and
(8) as fully described in the Council reasons for denyina the planning commission's site
plan approval which shall also be incorporated and restated herein by reference.
The proposed variances will not protect and preserve the Mississippi River Corridor as a
unique and valuable resource for the citizens of the city and the state; rather, they will
allow significant, lasting, potentially detrimental changes to the river for the benefit of
the MAC and its tenants.
The significant scope of this project, if the variances are granted, including the removal
of 560 acres from the Mississippi River floodplain and the excavation of 155,000 cubic
yazds of riverbank, will damage to the Mississippi River Corridor and its natural
ecological funcUOns.
A 9,635 foot wall of sheet metal that rises 8-14 feet above the surrounding terrain and
constructed within 50' of the ordinary high water mark cuts this portion of the river off
from any connection to a continuous trail system and eliminates an essential element
from federal, state, regional and local recreation plans.
The flood wall will be detrimental to the natural and aesthetic character of the river. The
floodwall will impede views from within the river and from natural areas, such as the
Bruce Vento Nature Sanctuary and Niounds Park. The variances, which will allow for
slopes greater that 18% and construction within 50' of the ordinary high water mark, will
make it difficult, if not impossible to provide vegetation or other natural elements that
would mitigate the aesthetic blight.
The variances are also inconsistent with the spirit and intent of adopted plans for the
River Corridor as noted in the Council's reasons for denying the site plan which shall be
set forth in the resolution memorializing this decision including:
A) The Mississippi River Corridar Plan Chapter of the Saint Paul Comprehensive Plan
including the plan's following strategies and objectives:
Strategy 1: Protect the River as a Unique Urban Ecosystem
Objective 4.2: Preserve and restore native plant and animal habitats
Objective 4.3: Protect and preserve floodplain and wetland areas in the
City
Strategy 3: Enhance the City's Quality of Life by Reconnecting to the River
Objective 61: Enhance opportunities for recreational use of the riverfront
by local visitors and tourists, utilizing parks, open space and physical
access to the river
Objective 6.2: Preserve and improve existing views to the river and bluffs,
and develop new ones
Q� -���
Objective 6.3: Provide a continuous, safe pedestrian and bicycle trail
along both sides of the river that is connected to the city and regional trail
system
Objective 6.5: Encourage protection and restoration of river corridor
cultural resources, including historic structures, culturally si�nificant
landscapes,and archeolo� caland ethnographic resources
Strategy 4: Use Urban Design to Enhance the River Corridor's Built Environment
Objective 7.2: Consistent with an urban setting, the design of new
buildings should reflect the river corridor's natural chazacter and respond
to topography by preserving critical public views
B) The variances are also is inconsistent with the following objectives in the Land Use
Chapter of the Saint Paul Comprehensive Plan for reasons more fully stated in the
Council's reason for denying the site plan.
Objective 4.1: Saint Paul on the Mississippi Development Framework
Implementation
Objective 6.2: River Corridor Development
Objective 7.1: Mississippi National River and Recreation Area (NIIVRRA) Tier II
Status
Objective 7.2: Topographic Features and Sensitive Resources
Objective 7.6: Airports and Airport Noise
Objective 7.8: Visual Beauty
C) The application is inconsistent with the Summary and General Policy Chapter of the
Saint Paul Comprehensive Plan including the following General Policies:
GPl: Ten Principles for City Development
GP2: Topography and Natural Environment
GP3: Water Resources
GP15: River Corridor
GP18: Open Space and River Connections
D) The application is inconsistent with the Parks and Recreation Chapter of the Saint
Paul Comprehensive Plan including the following objectives:
Objective 1: Encourage protection, preservation, and regeneration of the city's
open space and natural resources
Objective 2: Expand physical and visual access to the River
Objective 3: Develop pazk and open space connections
E) The application is inconsistent with the Saint Paul on the Mississippi Development
Framework including the following goals:
Chapter 1 Environmental Context
Goal 1: Strengthen Saint Paul's identity by reinforcing its topography and
natural environment
Goal 2: Protect, restore and reinforce native vegetation
D6 -3�3
Goa13: Develop creative desia altematives for river edge treatments
Goa14: Intensify the use of natural storm water management solutions
Chapter 4 Public Realm
Goal 1: Provide easily recognizable and accessible connections between
downtown Saint Paul, the riverfront and the city-wide and regional open
space trail systems
Goal 2: Recob ize and take full advantage of the historic and recreational
s b°nificance of Saint Paul's pazkway and trail corridor system
Goal 3: Build on existing initiatives to establish an urban greening policy
for downtown, riverfront and river bottom areas
Goal 8: Protect and enhance the environmental and aesthetic quality and
integrity of Saint PauPs natural features
F) The application is inconsistent with the National Pazk Service Mississippi National
River and Recreation Area (MNRRA) Comprehensive Management Plan including the
following concepts:
• Balance and integrate sustainable use and resource preservation needs
• Preserve and restore natural appearance of shorelines and bluffs; protect
habitat; protect historic areas; preserve economic resources; provide setbacks
and screen new uses with vegetation
• Emphasize river-related and river-enhancing uses; minimal change to existing
development
• Provide a continuous linear open space and trail where practical; acquire
sensitive areas and emphasize resource protection
• Balance resource protection and use; increase pollution reduction efforts;
preserve biological diversity; protect cultural and economic resources;
facilitate and coordinate research
The proposed variances are inconsistent with the said sections as fully described in the
Council reasons for denying the planning commission's site plan approval which shal]
also be incorporated and restated herein by reference.
In addition, the MAC's site plan and variance applications are inconsistent with the
following additional City ordinances: I.eg. Code § 61.301(a) and I.eg. Code § 301(b).
Both ordinances pernut, in pertinent part, a"person having an ownership or leasehold
interest in the subject land ...(contingent included)" to apply to the City for a site plan
review (§ 61301(a)) or a variance (§ 61301(b)). The appellanYs generally have called
the MACs ownership of the land needed for this project into question. The City has
researched the appellanYs claim and has concluded that the MAC lacks an ownership or
leasehold interest in at least some of the land which MAC proposes to develop with the
floodwall. In particulaz, the MAC has not demonstrated an ownership or leasehold
interest, contingent or otherwise, in the lands where the MAC has proposed to make
"compensatory" excavations. The ownership records available to the City show the land
under the ownership of the Saint Paul Port Authority. Therefore, the MACs application
for site plan review as well as its application for variances fails to meet the general
D�-3�.3
application and review procedure required under I,eg. Code §§ 61.301(a) and .301(b).
Because the land in question abuts the Mississippi River and land alon� the river as well
as the river itself is subject to movement, a report on the title of all the lands necessary
for this project, including but not limited to a survey of ail the land on which the
floodwall will be located, is necessary to establish MACs ownership in order to comply
with the general application and review procedure required under Leg. Code §§
61301(a) and .301(b).
(d) The proposed variance will not impair an adequate supply of light and air to adjacent
property, but it will alter the essential character of the surrounding area or unreasonably
diminish established property values within the surrounding area;
There was significant testimony from surrounding neighbors regazding the effects of
airport noise on the essential chazacter of the surrounding area and property values as
they relate to the request for variances for the construction of a perimeter dike at Holman
Field.
It is reasonable to conclude that increased air traffic, and therefore increased noise, at
Holman Field related to the granting of the variances for the construction of the perimeter
dike will have a negative impact on the property values of surrounding impacted
neighborhoods. This conclusion can be based on the following information:
MAC has provided no specific information indicating that air traffic will not
increase at Holman Field if the aiiport is considered secure from flooding. Noise
zone maps in the 1992 and 2002 Airport Comprehensive Plans show an increase
in the noise zone from 1998 projected out to 2020 with the proposed construction
of the perimeter dike.
The 2000 Airport Comprehensive Plan also predicts an increase in the areas that
would be affected by airport noise. The area affected by 60DNL is projected to
increase by 248 acres in 2020. The azeas affected by 65DNL are projected to
increase by 141 acres. The area affected by 70 DNL is projected to increase by
57 acres and the area affected by 75DNL is projected to increase by 65 acres.
• MAC's projections also indicate a change in the mix of aircraft that would use the
airport if the perimeter dike were constructed. Jets will go from 27% of traffic
operations in 1998 to 33% of operations in 2020. Multi-engine aircraft are
projected to go from 17% of traffic operations in 1998 to 24% in 2020.
The MAC Dayton's Bluff Noise Monitoring Summary 10/15/2001-10/22/2001
relies on a"noise averaging." Certain "noise averaging" methods are considered
controversial because they tend to assign noise categories inconsistent with
communities' actual noise status.
• MAC has not proposed any plans to mitigate increased airport noise in the
neighborhoods that will be affected and airport noise mitigation is incompatible
with the Dayton's Bluff Historic District Guidelines.
d� ��
Granting variances to excavate steep slopes and erect a floodwall will also alter the
essential chazacter of the azea. The variances to construct a flood wall will have a
detrimental effect on the ecological functioning of the river; a negative effect on the
aesthetic nature and views from the river and surrounding properties; and limit the
recreational opportunities envisioned by River Corridor Overlay District.
MAC has provided no plan to address the visual effects of a 9 foot, sheet-metal wall that
will rise 9 feet over grade for 5,531 feet along the river bank. They have indicated that
the wall will be screened by existing scrub trees and shrubs along the shoreline.
Objective 6.2 of the Mississippi River Corridor Plan indicates that the City should work
to preserve and improve existing views to the river and bluffs, and develop new ones. It
recognizes that various forms of public visual access to the river consist of scenic river
views, extended view corridors, overlook points, observation platforms, bridge crossings,
bridgeheads and bluff stairways. It recognizes that views both from the river and over
the river aze important public amenities and should be protected.
• No plan has been submitted to address the visual impact of a rusting sheet metal
wall on views from the river and surrounding property.
• No plan has been submitted to address vandalism to the sheet meta] wall which is
likely to be an attractive nuisance.
• No plan has been submitted to discuss the visual impacts of 5,000 square feet of
rip rap from the river and surrounding property.
(e) The variance, if granted, would not permit any use that is not permitted under the
provisions of the code for the property in the district where the affected land is located,
nor would it alter or change the zoning district classification of the property;
The property for which the variances are requested is cunently zoned RC1. Sec. 68.214
(h) of the zoning code, which indicates the standards for conditional uses in the RCl
Floodway District, states:
"Community-wide structural works far flood control intended to remove azeas
from the regulatory floodplain shall not be allowed in the floodway."
Therefore, the floodwall is not an allowed use in an RC1 district. Granting the variances
for the compensatory excavation is not allowed in the district where the affected land is
located and the granting of the variances would alter and change the zoning district
classification of the property.
(t) The request for variance is based primarily on a desire to increase the value or income
potential of the parcel of land.
MAC's interest in seeking the variances for the construction of a floodwall is based on a
desire to ensure the airport remains free from floods. A more attractive airport increases
�� -��3
the number of tenants and air traffic increased traffic and tenants create more revenue for
thymic.
CONCLUSION: For all of these reasons, which will be more fully set out in a resolution
memorializing this decision, I move to grant the appeal and deny the pernrission granted
by the planning commission.
OG -.�� �
Reasons for denial of the Site Plan
(1) The city's adopted comprehensive plan and development or project plans for sub-areas of the
city.
The Planning Commission erred in determining that the site plan is consistent with the city's
comprehensive plan and development of project plans for sub azeas of the city. The city has
done extensive planning over the past decade for the river corridor, which is considered a
valuable, irreplaceable asset. As was stated eloquently by Steve Johnson of the National Pazk
Service at the public hearing before the City Council on April 5, 2006,
"The Mississippi River is more than 2,300 miles long, but when Congress decided to
make a portion of the river part of the national park system, it chose only this place, a 72
mile segment that includes Saint Paul. Of all of the length of one of the world's greatest
rivers, only here is there the convergence of outstanding geology, history and natural
resources worthy of national pazk system designation."
The importance of this resource to the citizens of Saint Paul is reflected in the many strategies
and objectives related to the river corridor outlined in the city's comprehensive planning
documents. The planning commission did not adequately review all pertinent references to the
protection and enhancement of the river corridor and therefore erred in determining that the site
plan is consistent with the comprehensive plan and development of project plans for sub areas of
the city.
A) The City Council finds that the application is inconsistent with the Mississippi River
Corridor Plan Chapter of the Saint Paul Comprehensive Plan including the plan's following
strategies and objectives:
Strategy 1: Protect the River as a Unique Urban Ecosystem
Objective 42: Preserve and restore native plant and animal habitats
• This objective states the importance of preserving and restoring native plant
and animal habitats to create a connected greenway for migrating songbirds
and improve the ecology of the Mississippi valley in Saint Paul.
• The construction of a 5,531 foot sheet metal wall that will have little setback
from the river bank in some azeas will remove native plant and animal habitats
and preclude any form of habitat restoration.
• MAC has indicated that they plan to replant the other areas along the
floodwall with native grasses and plants which are not conducive to attracting
birds, as these are inconsistent with airport operations. This is inconsistent
with the goal of creating a connected greenway for migrating songbirds and
other wildlife.
• Questions have been raised about the adequacy of MAC's terrestrial survey
for endangered species which was conducted during December. To date, no
detailed report on the survey has been made available to the City Council, the
Planning Commission, or other interested agencies. No aquatic survey has
been done to date and questions have been raised about the possibility of the
D� --���
site of the compensatory excavation including habitat for Higgins Eye Pearly
Mussels, a federal and state identified endangered species.
This objective includes a strategy which indicates that the city will continue to
enforce the 50 foot shoreline setback for structures and will support efforts to
restore the shoreline to a moae nahxral chazacter within 100 feet of the river to
facilitate wildlife movement and improve aesthetics.
Objective 4.3: Protect and preserve floodplain and wetland azeas in the City
The area of the proposed floodwall and compensatory excavation aze currently
zoned R-1 floodway, and while Holman Field is viewed by some as a non-
ecologically functioning floodplain, it srill provides important floodplain
functions including providing for flood storage and conveyance, reducing
flood velocities, reducing peak flows, reducing sedimentation and moderating
temperature functions. While MAC has indicated that the compensatory
excavation will mitigate some of these concems, changes to one feature can
alter the entire system in significant ways. Vegetation loss and excessive
runoff within a floodplain can cause increased erosion and sedimentation,
which may cover spawning areas and bury food sources. Loss of vegetation
also removes sources of shelter and food for wildlife and human structures
may present barriers to migration and reproductive activity. The Mississippi
River Corridor Plan contemplates these concerns, indicates that our
understanding of these natural features continues to evolve, and therefore calls
for cazeful planning and management.
There have been several wetland areas identified which aze in close proximity
to the proposed location of the floodwall. At one time, the plan for the
floodwall involved the filling of one wetland, however, MAC now indicates
that the floodwall will not disturb any wetlands, but will run adjacent to
identified wetlands. MAC has not provided a survey to the City Council to
identify the exact location of the floodwall nor the exact location of wetlands,
so it is not possible to ascertain whether the MAC's assertions are correct.
There have been no reports provided by the MAC to the City Council to
indicate the effects of the floodwall on adjacent wetlands. For instance, how
does the change of river flow impact the adjacent wetland azeas and their
ability to support nahual flora and fauna. Without more specific information
about steps to protect these valuable azeas, it is impossible for the Council to
ascertain the impact of the floodwall on adjacent wetlands.
Strategy 3: Enhance the City's Quality of Life by Reconnecting to the River
Objective 6.1: Enhance opportunities for recreational use of the riverfront by local
visitors and tourists, utilizing pazks, open space and physical access to the river
• This objective highlights the picturesque, natural environment of Saint Paul's
river corridor which provides desirable open spaces for city residents and
tourists to play and relax.
• A sheet pile wall of 5,531 feet in length rising up to 22 feet above the water
would cut off physical access to the river and maz the aesthetic nahual beauty
that amacts recreational use of the riverfront by visitors and tourists.
��_ .�� .�
Objective 6.2: Preserve and improve existing views to the river and bluffs, and
develop new ones
This objective highlights the importance ofvisual access to the river and
recognizes the importance of various forms of visual access including
extended view corridors, overlook points, observation platforms, bridge
crossings, bridge heads and bluff stairways.
The proposed sheet metal wal] of 5,531 feet in length, rising up to 22 feet
above the water wiil profoundly change how people on the water see Saint
Paul. It will also detrimentally affect an important view corridor and
significantly affect views from the Samuel Morgan Trail, the Bnxce Vento
Nature Sanctuary, Indian Mounds Pazk and other public lands.
Objective 6.3: Provide a continuous, safe pedestrian and bicycle trail along both
sides of the river that is connected to the city and regional trail system
This objective contemplates a continuous, safe pedestrian and bicycle trail on
both sides of the river to provide the public increased access to the river
corridor. Plans for near the airport include on-street bike lanes.
The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water will effectively cut off any access to the river from planned
bicycle and pedestrian trails.
Strategy 4: Use Urban Design to Enhance the River Corridor's Built Environment
Objective 7.2: Consistent with an urban setting, the design of new buildings
should reflect the river corridor's natural character and respond to topography by
preserving critical public views
• This objective recognizes that in the river corridor, scale becomes important
as it relates to topography, views and the surrounding urban fabric. It calls for
the preservation of public views both of the river from the city and from the
river back to the city.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water will be out of scale with the surrounding topography and will
completely block views both of the river from the city and from the river back
to the city.
Objective 73: Design Study for River Corridor Redevelopment Sites
While the specific redevelopment sites anticipated by this study do not include
Holman Field, the study's goals were to consider the scale of new
development and to create design guidelines that met the spirit and intent of
MNRRA and Critical Area Requirements. The study indicated that ideally
new development should provide greater public access to the river, preserve
significant public views, improve storm water and the urban forest on site, and
reinforce and complement the surrounding urban fabric.
The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water will cut off public access to the river, impede significant
LIG-.��
public views of the river and from the river, diminish the possibility of natural
urban forest restoration on the site, and be out of sync and scale with the
surrounding wban fabric.
B) The City Council finds that the application is inconsistent with Land Use Chapter of the Saint
Paul Comprehensive Plan including the plan's following objectives:
Objective 4.1: Saint Paul on the Mississippi Development Framework Implementation
• This objective calls for, among other things, re-greening of the downtown river
valley; bringing people to the riverbanks and bluff lines; connectivity, or
complementarity of each land use with others neazby; and designing streets to
accommodate transit, bikes and pedestrians as well as cazs.
• The proposed sheet metal wa11 of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will preclude the re-greening of the downtown
river valley and be in conflict with plans to create a connected greenway for
migrating songbirds and improve the ecology of the Mississippi valley in Saint Paul.
• The proposed sheet metal wail of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will prevent connection with the riverbanks
and provide an impediment to views of the biuff lines from the river.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback is designed to cut off connectivity with the
river and does not complement the adjacent land uses of the Bruce Vento Nature
Sanctuary, the Samuel Morgan Trail, and Indian Mounds Pazk.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback wili preclude the connection with the river of
planned on-sTreeT bike lanes neaz the airport. Plans call for conYinuous, safe
pedestrian and bicycle trail on both sides of the river to provide the public increased
access to the river corridor.
Objective 62: River Corridor Development
This objective indicates a community intention to "return to the river" in contrast to
recent decades where the river's ecology and dramatic geography were lazgely
ignored by industrial development. This objective calls for a high priority on
appropriate management of the river corridor with changes consistent with
enhancement of the corridor's natural ecology; improved public access and
recreational uses throughout the corridor; continuarion of industrial uses with
modifications or additions to industrial use when they have no adverse impact on
water quality or air quality for the corridor and adjacent neighborhoods and when
they do not substantialiy impair the visual chazacter of the corridor from adjacent
neighborhoods or from the river itself; and new development in the floodplain or
within 300 feet of the ordinary high water mazk should have a relarionship to the
river, a need for river location and/or enhance the river environment.
The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback and the removal of 155,000 cubic feet of river
bank is not consistent with enhancement of the corridor's natural ecology.
D� -�� �
The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will preclude increased public access to the
river and hamper the ability to enjoy the visual beauty of the river for recreationa7
purposes.
• The addition of this proposed sheet metal wall of 5,531 feet in length, rising up to 22
feet above the water with as little as 0 feet of setback will substantially affect the
visual chazacter of the corridor from adjacent neighborhoods and from the river itself.
• The cost/benefit analysis (CBA) dated November 4, 2005 conducted by HNTB for
MAC lists the projected number of operations at Holman Field increasing m annual
aircraft operations from 134,377 in 2008 to 256,280 in 2057. This increase in
operations is provided as justification for the cost of the project. This increase in air
traffic related to the creation of the floodwall will have an impact on air quality for
adjacent neighbors and could potentially have an adverse impact on water quality for
the river.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback and the removal of 155,000 cubic feet of river
bank is cleazly within the floodplain and within 300 feet of the ordinary high water
mark. The proposed floodwall will sever a relationship with the river and will not
enhance the river environment ecologically or aesthetically.
Objective 7.1: Mississippi National River and Recreation Area (MNRRA) Tier II Status
• This objective calls for continued enforcement of bluff, shore land and wetland
protection measures which prohibit development on steep slopes, require setback
from bluff lines and water, and limit alteration of the natural environment. The
objective also calls for preserving native plants, wildlife and archeological sites,
carefixl planning for a 300 foot shore line zone; increasing natural landscaping along
shorelines, blufFs and bluff crests; reducing storm water runoff and chemical runoff;
identifying incentives for industrial land on the river to be used by businesses that
need a river location; increasing tourism and recreational uses of the river and
improving public access to the river.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback is inconsistent with the enforcement of the
prohibition of development of steep slopes and in fact the proposed wall is seeking
variances for impacting and creating slopes greater than 18%.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback and the removal of 155,000 cubic feet of river
bank would clearly encroach on the 300 foot shoreline zone.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback and the removal of 155,000 cubic feet of river
bank will interfere with increasing the natural landscaping along the shoreline.
• Holman Field airport is not an industrial use that needs a river location. While the
airport has been located in the river corridor for many years, there is nothing specific
to its operation that requires expansion in a river location.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as litfle as 0 feet of setback will sever public access to the river and reduce
the aesthetic enjoyment of the river for tourists and recreational users of the river.
�6 -���
Objecfive 7.2: Topographic Features and Sensitive Resources
This objective indicates that the City will integrate its land use plans with the work of
the DNR's metro regional Greenways and Natural Areas Collaborative. The
collaborative has identified high quality native habitat remnants and is seeking
funding to link the remnants into greenways which will provide continuous habitat
comdors to support nafive plant species and wildlife and improve park and trail
systems. Holman Field is chazacterized as "Very High" sensitivity.
This objecrive also calIs for the reconnection of neighborhoods to the Mississippi
River visually with natural landscaping along ravine edges and along bluffs facing
the river valley; the restoration of surface water systems including ponds, wetlands
and streams; completion of the parkway and trail system to provide access to the river
valley; Realtors and neighborhood mazketing groups to highlight beauuful views of
the river from adjacent communiries.
The construction of a 5,531 foot sheet metal wal] that wil] have little setback from the
river bank in some azeas will remove native plant and animal habitats and preclude
any form of habitat restoration.
MAC has indicated that they plan to replant the other azeas along the floodwall with
native grasses and plants which aze not conducive to attracfing birds, as these are
inconsistent with airport operations. This is inconsistent with the goal of creating a
connected greenway for migrating songbirds and other wildlife in this sensitive area
of the river.
There have been several wetland azeas identified which aze in close proximity to the
proposed location of the floodwall. At one time, the plan for the floodwall involved
the filling of one wetland, however, MAC now indicates that the floodwall will not
disturb any wetlands, but will nzn adjacent to identified wetlands. MAC has not
provided a survey to the City Council to identify the exact location of the floodwall
nor the exact location of wetlands, so it is not possible to ascertain whether the
MAC's assertions are correct.
There have been no reports provided by the MAC to the City Council to indicate the
effects of the floodwall on adjacent weUands. For instance, how does the change of
river flow impact the adjacent wetland azeas and their ability to support natural flora
and fauna. Without more specific information about steps to protect these valuable
areas, it is impossible for the Council to ascertain the impact of the floodwall on
adjacent wetlands.
The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will preclude completion of the pazkway a trail
system anticipated for the river and sever access to the river.
The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will have a negative visual impact on the river
and will hamper efforts to mazket the beauty of this resource in adjacent communities.
Objective 7.6: Airports and Airport Noise
• This objective recognizes the importance of Holman Field to Saint Paul's economy
and quality of life. It indicates that the City supports maintaining and improving
them in their present locations with full attention to noise miti�ation.
D� - ��.3
•"Changes in use that might alter the noise zones for Holman Field would be of
concem to the Citv because of the proximity of residential azeas including sites for
new development" (7.6.4)
• From the documentation provided by MAC, it appeazs that the creation of a levee at
Holman Field is designed to provide a flood-proof environment so that increased air
traffic will make use of the airport. MAC has provided no information about noise
mitigation efforts to protect the surrounding neighborhoods from this increased
tr�c as a result of the levee.
• MAC has provided no specific information indicating that air tr�c will not increase
at Holman Field if the airport is considered secure from flooding. In fact, the
cost/benefit analysis (CBA) dated November 4, 2005 conducted by HNTB for MAC
lists the projected number of operations at Holman Field increasing in annual aircraft
operations from 134,377 in 2008 to 256,280 in 2057. This increase in operations is
provided as justification for the cost of the project.
• MAC indicates that a benefit of the new dike would be an"Increase in safety at
Minneapolis-St. Paul International Airport (MSP) by allowing St. Paul Downtown
Airport to fulfill its intended system role of relievine MSP of significant levels of
eeneral aviation traffic." (Perimeter Dike St. Paul Downtown Airport Briefing Paper,
April 11, 2002)
• Included in the Planning Commission record is a letter from Dorsey & Whitney LLP,
writing on behalf of Northwest Airlines, November 13, 2002, who state flatly "If the
dike is constructed, Holman Field will be more attractive to potential customers since
it may provide a stronger measure of flood protection." They also fault the EAW for
the perimeter dike for failing to assume that there will be no increase in airport use
following completion of the project. In fact they state: "This assumption is
completely unwarranted, particularly in light of Holman Field's role as a reliever
airport, and pending proposals to limit the use of other reliever airports. The EAW
runs counter to the evidence, and any reliance thereon is arbitrary, capricious or an
abuse of discretion." (Dorsey & Whitney LLP letter to Gary Warren, November 13,
2002)
• While airport noise at Holman Field decreased slightly during the 1990's with the
phase- in of stage 3 aircraft and changes to the military fleet, airport noise is on the
rise again. Noise zone maps in the 1992 and 2002 Airport Comprehensive Plans
show an increase in the noise zone from 1998 projected out to 2020 with the proposed
construction of the perimeter dike.
• The 2000 Airport Comprehensive Plan also predicts an increase in the areas that
would be affected by airport noise. The area affected by 60DNL is projected to
increase by 248 acres in 2020. The areas affected by 65DNL aze projected to increase
by 141 acres. The area affected by 70 DNL is projected to increase by 57 acres and
the area affected by 75DNL is projected to increase by 65 acres. These projections
show an increasing area that will be affected by airport noise.
• MAC's projections also indicate a change in the mix of aircraft that would use the
airport if the perimeter dike were constructed. Exhibit 2C in the MAC 2000
Comprehensive Plan indicates that jets will go from 27% of traffic operations in 1998
to 33% of operations in 2020. Multi-engine aircraft are projected to go from 17% of
traffic operations in 1998 to 24% in 2020. Jets and multi-engine aircraft are
considered to generate more noise than other aircraft.
Q� ���
The MAC Dayton's Bluff Noise Monitoring Summary 10/15/2001-10/22/2001
relies on a"noise averaging" method to make the determination that noise levels from
operations associated with the St. Paul Downtown Airport aze not of a significant
nature. The P�anning Commission record inctudes a copy of a report The Impact of
Airport Noise on Residential Real Estate, by Randa11 Bell, MAI. As Mr. Ball points
out, certain "noise averaging" methods are considered controversial because they tend
to assign noise categories inconsistent with communities' actual noise status. (pg.
319-320) Instead, he concludes that "single event dBL should be considered
carefully" in determining appraised value. (pg. 321) The Dayton's Bluff Noise
Monitoring Summary regulazly recorded operations creating 76.8 dBL to 88.1 dBL.
MAC has not proposed any plans to mitigate increased airport noise in the
neighborhoods that wi11 be affected and airport noise mitigation is incomparible with
the Dayton's Bluff Historic District Guidelines.
Objective 7.8: Visual Beauty
This objective indicates that many features of the natural environment and the built
environment enhance a sense of place and contribute to well being as long as they
remain prominently visible. It indicates that tha City will support the preservation of
views and vistas and identifes major view points and comdors including the river
corridor at Holman Field.
The proposed sheet metal wa11 of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will completely block views both of the river
from the city and from the river back to the city. It will detrimentally afFect an
important view comdor and significantly affect views from the Samuel Morgan Trail,
the Bruce Vento Nature Sanctuary, Indian Mounds Park and other public lands.
C) The City Council finds that the application is inconsistent with the Summary and General
Policy Chapter of the Saint Paul Comprehensive Plan including the following General Policies:
GPl: Ten Principles for City Development
• These 10 principles, originally develoged as part of the "Saint Paul on the Mississippi
Development Framework" ca11 for evoking a sense of place; restoring and
establishing the unique urban ecology; improving connectivity; ensuring that
buildings support broader city goals; buiIding on existing strengths; preserving and
enhancing heritage resources; providing a balanced network for movement; among
other goals.
•'Fhe proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will not evoke a sense of place that reflects the
city's natural beauty and exceptional heritage.
• The proposed sheet metal wa11 of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will not allow for the re-establishment of a
naturaI system on the river and provide connected corridors for migrating species.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will not improve connectivity. In fact, it will
preclude any connection with the river.
d�-3G3
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as littie as 0 feet of setback does not support the broader city goals of re-
connecting with river and enhancing this important resource.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will not allow the city to build on the strength
of the river as a natural recreational and marketing resource.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback does not preserve and enhance the visual and
recreations resources available in the river corridor.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will not provide an opportunity to complete
the system of trails along the river corridor that would provide a balanced network for
movement.
GP2: Topography and Natural Environment
• This policy indicates that Saint Paul will strengthen its identity by reinforcing its
topography and natura] environment. It calls on supporting polices from the Land
Use and Parks and recreations chapters including implementation of the land use
themes for "Saint Paul of the Mississippi Development Framework;" creation of new
access to the riverbanks and bluff lines; promotion of the Great River Park;
conformance of policies and ordinances with the Mississippi National River and
Recreation Area Management Plan; restoration of greenway and natural habitat
linkages; reconnection of neighborhoods to the river with natural landscaping and,
where possible, restoration of surface water in tributary corridors; appropriate
development of sites with river valley views and protections of views where
appropriate; conformance of development with Mississippi River Corridar Critical
Area Regulations; continued development restriction, and acquisition where
appropriate, for protection of bluffs; and protection of views and vistas that offer
connection with the natural environment, as well as views of appropriate landmazk
features of the built environment.
• As has been indicated in the many examples cited above, The proposed sheet metal
wall of 5,531 feet in length, rising up to 22 feet above the water with as little as 0 feet
of setback is inconsistent with these supporting policies.
GP15: River Corridor
This policy indicates that Saint Paul will continue to give high priority to the
transformation of the River Corridor from a predominantly heavy industrial past to a
renewed center for activity and enjoyment of Saint Paul's natural setting. Supporting
policies include continuation of appropriate improvement and development of the
River Comdor as a priority, making sure changes aze consistent with the
enhancement of its natural ecology; improvement of public access and recreational
uses throughout the corridor; restriction of new development in the floodplain (or
within 300 feet of the water) to those entities which have a relationship to the river,
need a river location, or can enhance the river environment; transportation
investments that emphasize pedestrian opportunities and strengthen neighborhood
O'� -���
connections; development consistent with Critical Area standazds and the River
Corridor Plan.
• As has been indicated in the many examples cited above, The proposed sheet meYal
wa11 of 5,531 feet in length, rising up to 22 feet above the water with as little as 0 feet
of setback is inconsistent with these supporting policies.
GP 18: Open Space and River Connections
This policy indicates that in comdor planning and development, close attention mast
be paid to environmental qualiTy and Saint Paul must take advantage of opportunities
to enhance and extend the open space network formed by the river corridor, bluffs,
pazks and parkways. Neighborhood connections to the Mississippi River Corridor
will be enhanced through appropriate trail and road connections, infrastructure design
and land use planning and regulation.
As has been indicated in the many examples cited above, The proposed sheet metal
wall of 5,531 feet in length, rising up to 22 feet above the water with as little as 0 feet
of setback is inconsistent with these supporting policies.
D) The application is inconsistent with the Pazks and Recreation Chapter of the Saint Paul
Comprehensive Plan including the following objectives:
Objective 1: Encourage protection, preservation, and regeneration of the city's open
space and natural resources
This objective recognizes that Saint Paui's open space, natural, and historic resources
provide many benefits including softening the built environment, providing habitat
for plants and wildlife, and improving overall environmental quality. The objective
also recognizes that open and natural space is vulnerable to unwarranted use and
degradation. It calls for a conscious and concerted effort to protect and preserve open
space, natural space, and ecological systems, recognizing that they have regional
impact.
Included in this objective are policies to develop management and protection
strategies for endangered species and/or sensitive habitats; provide adequate and
consistent enforcement of regulations to protect water quality, wetlands, native
habitats and the river corridor; and opening a cleaner and more friendly river to
swimmers and other recreational users.
The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback is inconsistent with softening the built
environment; providing habitat plants and wildlife; improving overall environmental
quality; preserving open space; and protecting ecological systems.
Questions have been raised about the adequacy of MAC's terrestrial survey for
endangered species which was conducted during December. To date, no detailed
report on the survey has been made available to the City Council, the Plauniug
Commission, or other interested agencies. No aquatic survey has been done to date
and quesrions have been raised about the possibility of the site of the compensatory
excavation including habitat for Higgins Eye Pearly Mussels, a federal and state
identified endangered species.
��—.3� 3
There have been several wetland areas idenrified which aze in close proximity to the
proposed location of the floodwall. At one time, the plan for the floodwal] involved
the filling of one wetland, however, MAC now indicates that the floodwall will not
disturb any wetlands, but will run adjacent to identified wetlands. MAC has not
provided a survey to the City Council to identify the exact location of the floodwall
nor the exact location of wetlands, so it is not possible to ascertain whether the
MAC's assertions aze correct.
There have been no reports provided by the MAC to the City Council to indicate the
effects of the floodwall on adjacent wetlands. For instance, how does the change of
river flow impact the adjacent wetland azeas and their ability to support natural flora
and fauna. Without more specific information about steps to protect these valuable
azeas, it is impossible for the Council to ascertain the impact of the floodwall on
adjacent wetlands.
The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will cut of access to the river and be a visual
impediment to the enjoyment of natural space for tourists and recreational users of
the river.
Objective 2: Expand physical and visual access to the River
• This objective recognizes the Mississippi Itiver as Saint Paul's foremost natural,
historical, and recreational resource. It indicates that increasing downtown riverfront
access has been consistently identified as a priority for riverfront redevelopment and
should continue to be pursued.
• Included in this objective are policies which indicate that the city should pursue
opportunities to provide public access to the riverfront in a manner that is
aesthetically compatible with the riverfront and protects environmentally sensitive
areas; encourage riverfront development that is environmentally compatible and
fosters a park-like riverfront character; preservation and enhancement of significant
river and downtown skyline views; limitations on building heights and setback
encroachment in areas that would obstruct public access and views to the river.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback is not aesthetically compatible with the
riverfront and no evidence has been presented which indicates that it will protect this
environmentally sensitive azea.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback is not environmentally compatible with the
river and will not foster a pazk-like river-front character.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will not preserve ox enhance significant river
or downtown skyline views.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will encroach on the river bank and will
obstruct public access and views to the river.
D�-��3
Objecrive 3: Develop pazk and open space connections
• This objective recognizes that pazk and open space connections provide a means for
moving between pazks, moving within parks, and getting to parks in a safe,
convenient and enjoyable manner.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet above the
water with as little as 0 feet of setback will preclude the planned connection of bike
trails through the Holman Field area and impair visual connection with the river and
surrounding park land such as the Bruce Vento Nature Sanctuary, the Samuel H.
Morgan Trail and Indian Mounds Park.
E) The City Council finds that the application is inconsistent with the Saint Paul on the
Mississippi Development Framework including the following goals:
Chapter 1 Environmental Context
Goal I: Strengthen Saint Paul's identity by reinforcing its topography and natural
environment
• This goal recognizes the importance strengthening Saint Paul's identity by
reinforcing its topography and natural environment. Objectives include
approaching development decisions with a view to establishing balance
between built and natural azeas; developing and undertaking strategies to
restore the heaIth of Iocal ecosystems; idenrifying and reinforcing key
elements of the naturai setting that contribute to the chazacter of the city
including the river and the blufFs; reinforcing Saint Paul's topography as a
natural asset and renewing connections with the Mississippi River, urban
forests, and floodplain reaches.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water with as little as 0 feet of setback will appeaz out of balance
with the surrounding topography and natural environment.
• The proposed floodwall will not enhance or restore the local ecosystem and
by MAC's own design, will hamper critical migration corridors for birds and
other wildlife. Removing over 155,000 cubic feet of river bank will not
enhance the local ecosystem and will not allow an opportunity to restore the
local ecosystem.
• The proposed sheet metai wall of 5,531 feet in length, rising up to 22 feet
above the water with as little as 0 feet of setback wiil present an imposing
siructure, in conflict with the surrounding topography and hampering public
connection with the river.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water with as little as 0 feet of setback will change the remaining
floodplain chazacter of this azea and will preclude any restoration of the azea
to a more natural ecosystem.
DG - .3�.�
Goa12: Protect, restore and reinforce native vegetation
• This goal recognizes the importance of native vegetation azeas to the health of
the river and the variety of animal habitats that aze challenged by urban
development. The goal calls for increased preservation and restoration of
native plant and animal habitats to establish a healthy urban ecology that
contributes to a sense of place, improves quality of life, and set a context in
which other strategies of the framework can be implemented.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water with as little as 0 feet of setback will present little
opportunity for the enhancement of native vegetation that supports wildlife
habitats.
• The proposed floodwall will not enhance or restore the local ecosystem and
by MAC's own design, will hamper critical migration corridors for birds and
other wildlife.
• MAC has failed to provide a detailed plan for restoring native habitat along
the riverbank and the proposed sheet metal wall of 5,531 feet in length, rising
up to 22 feet above the water with as little as 0 feet of setback will not allow
for habitat restoration in many areas.
Goa13: Develop creative design alternatives for river edge treatments
• This goal recognizes the importance of the river's edge for accessibility and
attzactiveness. It calls for blending hard and soft edge treatments; using soil
bio-engineering techniques and plantings to increase the strength of the river
banks; re-establishing a littoral zone where the shoreline meets the river's
edge; and improving the overall visual/aesthetic chazacter of the shoreline and
river edge.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water with as little as 0 feet of setback will hamper public
accessibility to the river's edge and create a visual impediment to the view
corridor.
• With little to no setback for the proposed floodwall, there is no opportunity to
blend from hazd surface to soft edge treatments and no opportunity to
establish bio-engineering techniques or plantings to create a natural
appearance to the river front.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water with as little as 0 feet of setback will not improve the overall
visual/aesthetic character of the river edge.
Chapter 4 Public Realm
Goal 1: Provide easily recognizable and accessible connections between
downtown Saint Paul, the riverfront and the city-wide and regional open space
trail systems
DG��6�
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water with as little as 0 feet of setback will sever connections with
the riverfront and preclude efforts to link the river to a regional trail system.
Goal 2: Recognize and take full advantage of the historic and recreationaI
significance of Saint Paul's parkway and trail corridor system
This goal recognizes opportunities to link the existing pazkway and trail
system with an focus on linking regional trail systems with the downtown
core and the river.
• The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water with as little as 0 feet of setback will sever connections with
the riverfront and preclude efforts to link the river to a regional trail system.
Goa13: Build on existing initiatives to establish an urban greening policy for
downtown, riverfront and river bottom areas
• 1'his goal seeks to build on initiatives such as those undertaken by Crreat River
Greening to develop a greening policy for Yhe riverfront and river bottom
areas.
The proposed sheet metal wall of 5,531 feet in length, rising up to 22 feet
above the water with as little as 0 feet of setback will not allow for adequate
oppommities to landscape and restore natural habitat along the riverfront.
This will reduce unified efforts to create continuous green corridors for
migration and habitat.
Goa18: Protect and enhance the environmental and aestheric quality and integrity
of Saint Paul's natural features
• This goal ca11s for the reconnecting natural features as part of the city green
structure to provide an opportunity for the public to experience the nahual
world within downtown Saint Paul. This goal states "The fractured condition
of existing remnant natural azeas makes this a challenging, but essential goal."
• This goal also recognizes that a prominent and thriving system of natural
features has tremendous value, both environmentally and aesthetically. It also
recognizes the value of natural azeas for recreational and educational
opportunities.
• The proposed sheet metal wa11 of 5,531 feet in length, rising up to 22 feet
above the water with as little as 0 feet of setback will sever any opportunity to
reconnect this section of this river with sustainable natural habitat. It will also
hamper efforts to create a unified, natural aesthetic on the riverfront as it
blocks views both to and from the river.
• The removal of over 155,000 cubic feet of river bank will irreparably change
the riverbank and alter the integrity of this natural area.
�G-���
F) While the National Pazk Service Mississippi National River and Recreation Area (MNRRA)
Comprehensive Management Plan is not an adopted city plan, the city references the document
frequentiy in our planning documents and it serves as the governing document for management
of the recreation azea which includes Holman Field. The City Council believes that it is
important to recognize the Comprehensive Management Plan as a guiding document and finds
that the application is inconsistent with the MNRRA Comprehensive Manaaement Plan
including the following concepts:
• Balance and integrate sustainable use and resource preservation needs
• Preserve and restore natural appeazance of shorelines and bluffs; protect habitat;
protect historic areas; preserve economic resources; provide setbacks and screen new
uses with vegetation
• Emphasize river-related and river-enhancing uses; minimal change to existing
development
• Provide a continuous lineaz open space and trail where practical; acquire sensitive
areas and emphasize resource protection
• Balance resource protection and use; increase pollution reduction efforts; preserve
biological diversity; protect cultural and economic resowces; facilitate and
coordinate research
(2) Applicable ordinances of the city.
The planning commission's resolution approving the Metropolitan Airports Commission (MAC)
site plan to widen a portion of the river channel and construct a levee is inconsistent with the
foilowing City Ordinances which aze noted in the Planning Commission's Resolution.
Leg. Code § 68.402 regulates protection of sharelands, floodplains, wetlands and bluffs in the River
Corridor. The planning commission erred with respect to its findings under Leg. Code §
68.402(b)(1)(b):
(b) Placement of structures.
(1) The following minimum setbacks for each class of public waters as described in Minnesota
Regulations NR-82 shall apply to all structures except those specified as exceptions in
subsection (7) below.
b. For general development waters at least seventy-five (75) feet from the normal high water
mark for lots not served by public sewer and at least fifiy (50) feet from the ordinary high water
mark for lots served by public sewer. The applicant requested a variance of this standard. The
planning commission's findings approving the vaziance are set forth in H.1 to H.S. The
commission's finding is in enor based upon the CounciPs reasons for denying the said variance
as set forth elsewhere in this resolution.
The planning commission erred with respect to its findings under Leg. Code § 68.402(b)(2):
(2) No commercial or industrial development shall be permitted on slopes greater than twelve
(12) percent. The applicant has requested a variance of this standard. The planning
D� ��.
commission's fmdings approving the variance are set forth in H.1 to H.S. The commission's
finding is in error based upon the Council's reasons for denying the said variance as set forth
elsewhere in this resolution.
The planning commission erred with respect to its findings under the following sections of Leg.
Code § 68.402(b)(5)(a)(b)(d). The commission determined that the noted sections were not
applicable to the application.
(5) Transportation, utility and other transmission service facilities and corridors shall avoid:
a. Steep slopes;
b. Intrusions into or over streams, valleys and open exposures of water;
d. Creating tunnel vistas.
The planning commission erred in its determination. The Council finds that the site plan proposes
work on slopes in excess of 18% which is prohibited under the code, that the visual appeazance
of the floodwall will intrude over the river and that the floodwall will create a"tuTmel" vista up
and downstream when viewed from upon the river.
The planning commission erred in its findings under Leg. Code § 68.402(c)(7). The planning
commission erred in approving the site plan based upon the MAC's request to vary the
provisions under Leg. Code § 68.402(c)(7).
(7) No rehabilitation slopes shall be steeper than eighteen (18) percent slope. The applicant
requested a variance of this standazd. The planning commission erred when it granted the
variance of this standazd in findings H.1 and H.5 of its resolution. The Council's finding of
error in the planning commission's findings is set forth in the Council's reasons to deny the
requested variances under H.1 and H.S.
The planning commission erred in its findings under Leg. Code § 68.403(a):
Sec. 68.403. Protection of wildlife and vegetation. Development shall be conducted so as to
avoid intrusion into animal and plant habitats.
(a) No alteration of the natural environment or removal of vegetation shall be pernutted when
such aiteration or removal would diminish the ability of dependent wildlife to survive in the
River Corridor. The planning commission found that the compensatory excavation and levee
construction aze not in an area that is currently habitable by wildlife. T'he Council finds that the
record is lacking to support such a conclusion on the part of the planning commission. The
planning commission further found that existing vegetation could be retained for wildlife habitat
and to screen the sheet piles from view. The Council finds that retention of existing vegetation
is contrary to the polices found throughout the Comprehensive plan that ca11s for reestablishing
native plants and vegetation along the river. Retaining vegetation without lmowing its type and
origin and whether the vegetation is suitable for wildlife habitat and screening sheet pile is
inconsistent with the City's river policies.
The planning commission ened in its findings under Leg. Code § 68.403(d)
(d) Natural vegetation shall be restored after any consiruction project. The planning commission
found that the MAC must restore narive vegetation to the shoreline and noted that no natural
O�- ��.�
vegetation exists on the actual airport proper w here a portion of the levee will be located. The
planning commission went on to say that `begetation riverward of the sheet pile floodwall will
be retained "where possible." This is an error in that it grants too much discretion to the MAC to
determine whether it is possible to retain native vegetation. Throughout the comprehensive plan
it is a stated goal to retain native vegetarion. If the MAC encounters situations where native
vegetation cannot be retained, it is incumbent upon the MAC to present the situation to the City
and allow the City to determine whether the native vegetation can be retained and by what
means. Crranting approval to the MAC to retain native vegetation where possible provides too
much discretion to the MAC.
In addition, the MACs site plan and variance applications are inconsistent with the following
additional City ordinances: Leg. Code § 61301(a) and Leg. Code § 301(b). Both ordinances
permit, in pertinent part, a"person having an ownership or leasehold interest in the subject land .
..(contingent included)" to apply to the City for a site plan review (§ 61301(a)) or a vaziance (§
61301(b)). The appellant's generally have called the MAC's ownership of the land needed for
this project into question. The City has researched the appellant's claim and has concluded that
the MAC lacks an ownership or leasehold interest in at least some of the land which MAC
proposes to develop with the floodwall. In particular, the MAC has not demonstrated an
ownership or leasehold interest, contingent or otherwise, in the lands where the MAC has
proposed to make "compensatory" excavations. The ownership records available to the City
show the land under the ownership of the Saint Paul Port Authority. Therefore, the MAC's
application for site plan review as well as its application for variances fails to meet the general
application and review procedure required under Leg. Code §§ 61.301(a) and .301(b). Because
the land in question abuts the Mississippi River and land along the river as well as the river itself
is subject to movement, a report on the title of all the lands necessary for this project, including
but not limited to a survey of all the land on which the floodwall will be located, is necessary to
establish MAC's ownership in order to comply with the general application and review
procedure required under Leg. Code §§ 61301(a) and .301(b).
(3) Preservafion of unique geologic, geographic or historically significant characterisfics of the
city and environmentally sensitive areas.
The Metropolitan Airports Commission (MAC) site plan to widen a portion of the river
channel and conshuct a levee is inconsistent with preservation of the unique geologic,
geographic or historically significant characteristics of the city and environmentally
sensitive azeas.
The Mississippi River is recognized by the City of Saint Paul as one of our most unique
geologic, geographic and historically significant chazacteristics. This is borne out in
extensive references to the river in our Comprehensive Plan documents and in other
adopted development frameworks inciuding the Saint Paul on the Mississippi Design
Framework. This is also recognized in our zoning code with a chapter devoted solely to
the River Corridar. As can be seen from the extensive review of Saint Paul planning
documents cited above, all of these documents call for additional protection of ttiis
important natural and social resource and see the river as integral to the city's future
development. Nowhere in this vast array of planning documents does the city
contemplate a 5,531 foot sheet metal wall rising 22 feet above the river that will block
0����
access to the river's edge and impair the view corridor from adjacent property and the
river itself.
In addition to Saint Paul's recognition of the Mississippi River's significant
chazacteristics, both the State of Minnesota and the National Pazk Service have
designated the river as having geologic, geographic and historic significance and have
enacted legislation (Federal Public Law 100-696 — November 18,1998, Tifle VII,
Mississippi River and Recreation Area, Minnesota Statutes Chapters 103 and 116G) and
rules (Mississippi River and Recreation Area Final Comprehensive Management Plan
and MEQC54) and completed extensive planning to preserve the significant
chazacteristics of the river.
Clearly, the river is a cherished, one-of-a-kind resource for our City, our State and our
Nation, and as such, projects that will affect the river corridor deserve increased scrutiny
by the Planning Commission and City Council.
Removing 155,000 cubic yards from the river bank and constructing a floodwall that will
stretch for 9,635 feet in length, remove 560 acres from the floodplain, be driven 50 feet
deep into the river bank, and cover the river bank with over 5,000 yazds of rip rap is not
consistent with preservation efforts and goals outlined in the City's comprehensive plan
and zoning code. Nor is it consistent with the preservation efforts and goals outlined by
the State's Department of Natural Resources or the National Pazk Service's Goals for the
Mississippi River National River and Recreation Area.
(4) Protecfion of adjacent and neighboring properties through reasonable provision for such
matters as surface water draivage, sound and sight buffers, preservation of views, light and air,
and those aspects of design which may have substantial effects on neighboring land uses.
The Metropolitan Airports Commission (MAC) site plan to widen a portion of the river
channel and construct a levee is inconsistent with protection of adjacent and neighboring
properties. MAC has failed to demonstrate that the widening of the river and the
construction of a levee will not have a detrimental effect on sound, sight, preservation of
views, and neighboring land uses for neighboring groperties.
A) Sound Buffers
From the documentation provided by MAC, it appeazs that the creation of a levee at
Holman Field is designed to provide a flood-proof environment so that increased air
traffic wili make use of the airport. MAC has provided no information about noise
mitigation efforts to protect the surrounding neighborhoods from this increased traffic as
a result of the levee.
• MAC has failed to provide specific information indicating that air trafFic will not
increase at Holman Field if the airport is considered secure from flooding. In fact,
the cost/benefit analysis (CBA) dated November 4, 2005 conducted by HNTB for
MAC lists the projected nuxnber of operations at Holman Field increasing in annual
�� -�G 3
aircraft operations from 134,377 in 2008 to 256,280 in 2057. This increase in
operations is provided as jusrification for the cost of the project.
MAC indicates that a benefit of the new dike would be an"Increase in safery at
Minneapolis-St. Paul International Airport (MSP) by allowing St. Paul Downtown
Airport to fulfill its intended system role of relieving MSP of s�onificant levels of
general aviation traffic." (Perimeter Dike St. Paul Downtown Airport Briefing Paper,
April 11, 2002)
Included in the Planning Commission record is a letter from Dorsey & Whitney LLP,
writing on behalf of Northwest Airlines, November 13, 2002, who state flatly "If the
dike is consh Holman Field will be more attractive to potential customers since
it may provide a stronger measure of flood protection." They also fault the EAW for
the perimeter dike for failing to assume that there will be no increase in airport use
following completion of the project. In fact they state: "This assumption is
completely unwarranted, particulazly in light of Holman Field's role as a reliever
airport, and pending proposals to limit the use of other reliever airports. The EAW
runs counter to the evidence, and any reliance thereon is arbitrary, capricious or an
abuse of discretion." (Dorsey & Whitney LLP letter to Gary Warren, November 13,
2002)
While airport noise at Holman Field decreased slightly during the 1990's with fhe
phase- in of stage 3 aircraft and changes to the military fleet, airport noise is on the
rise again. Noise zone maps in the 1992 and 2002 Airport Comprehensive Plans
show an increase in the noise zone from 1998 projected out to 2020 with the proposed
construction of the perimeter dike. No additional noise studies have been conducted
to show that an increase in air traffic will not impact adjacent properties.
The 2000 Airport Comprehensive Plan also predicts an increase in the areas that
would be affected by airport noise. The area affected by 60DNL is projected to
increase by 248 acres in 2020. The azeas affected by 65DNL aze projected to increase
by 141 acres. The area affected by 70 DNL is projected to increase by 57 acres and
the azea affected by 75DNL is projected to increase by 65 acres. These projections
show an increasing area that will be affected by airport noise. No additional noise
studies have been conducted by 1VIAC to show that the increase in air traffic will not
impact adjacent properties.
MAC's projections also indicate a change in the mix of aircraft that would use the
airport if the perimeter dike were constructed. Exhibit 2C in the MAC 2000
Comprehensive Plan indicates that jets will go from 27% of traffic operations in 1998
to 33% of operations in 2020. Multi-engine aircraft aze projected to go from 17% of
traffic operations in 1998 to 24% in 2020. Jets and multi-engine aircraft are
considered to generate more noise than other aircraft. No additional noise studies
have been conducted by MAC to show that this change in aircraft use will not impact
surrounding properties.
The MAC Dayton's BluffNoise Monitoring Summary 10/15/2001-10/22/2001
relies on a"noise averaging" method to make the determination that noise levels from
operations associated with the St. Paul Downtown Airport are not of a significant
nature. As The Impact ofAirport Noise on Residential Real Estate, by Randall Bell,
MAI points out, certain "noise averaging" methods are considered controversial
because they tend to assign noise categories inconsistent with communities' actual
noise status. (pg. 319-320) Instead, he concludes that "single event dBL should be
considered carefully" in determining appraised value. (pg. 321) The Dayton's Bluff
Q�-.��3
Noise Monitoring Summary regulazly recorded operations creating 76.8 dBL to
88.1dBL.
• MAC has not proposed any plans to mitigate increased airport noise in the
neighborhoods that will be affected and airport noise mitigation is incompatible with
the Dayton's Bluff Historic District Guidelines.
B) Sight Buffers
MAC has provided no plan to address the visual effects of a 9 foot, sheet-metal wall that
will rise 9 feet over grade for 5,531 feet along the river bank. They have indicated that
the wall will be screened by existing scrub trees and shrubs along the shoreline.
Without a specific landscape plan, the council is skeptical that the existing vegetation
will survive the construction necessary to install the floodwall. Without a specific
landscape plan the councii is also skeptical that the existing vegetation is sufficient to
buffer the visual affects of the flood-wall on views from the river and the surrounding
property, including the Bruce Vento Nahue Sanctuary and Mounds Pazk.
• No plan has been submitted to address the visual impact of a rusring sheet metal
wall on views from the river and surrounding property.
• No plan has been submitted to address vandalism to the sheet metal wall which is
likely to be an atlsactive nuisance.
• No plan has been submitted to discuss the visual impacts of 5,000 square feet of
rip rap from the river and surrounding property.
C) Preservation of Views
Objective 6.2 of the Mississippi River Corridor Plan indicates that the City should work
to preserve and improve existing views to the river and bluffs, and develop new ones. It
recognizes that various forms of public visual access to the river consist of scenic river
views, extended view corridors, overlook points, observation platforms, bridge crossings,
bridgeheads and bluff stairways. It recognizes that views both from the river and over
the river aze important public amenities and should be protected. MAC has failed to
provide adequate evidence that the flood wall will not negatively impact visual access to
and from the river.
No plan has been submitted to address the visual impact of a rusting sheet metal
wall on views from the river and surrounding properiy.
No plan has been submitted to address vandalism to the sheet metal wall which is
likely to be an attractive nuisance.
No plan has been submitted to discuss the visual impacts of 5,000 squaze feet of
rip rap from the river and surrounding property.
OG- 3�3
(5) The amangement of buildings, uses and facilities of the proposed development in order to
assure abutting property and/or its occupants will not be unreasonably affected.
The site plan is consistent with this find'mg.
(6) CYeation of energ,y-conserving design thmugh landscaping and location, orientation and
elevafion of struMures.
This finding is not applicable to this project.
('n Safety and convenience of both vehicular and pedesirian tr-affic both within the site and in
relation to access streets, including traftic circulation features, the locations and design of
entrances and exits and pai�g areas within the site.
The site plan will have no impact on vehiculaz or pedestrian traffic and is consistent with this
finding.
(8) The satisfactory availability and capacity of storm and sanitary sewers, including solutions to
any drainage pmblems in the area of the development.
The Council notes that while MAC is creating an extensive sub-drain system to handle excess
water from the high water table, questions remain unanswered about the treatment of runoff and
potential pollution on the site. MAC does not have the required MPCA permits for the creation
of the sub-drain system or the construction of the floodwall. MAC has not done the necessary
soil and water testing to determine potential pollution hazards to the river.
(9) Sufficient laudscaping, fences, walls and parldng necessary to meet the above objectives.
MAC has not provided a plan that is sufficient to meet the objectives noted above. As stated
previously, MAC has not submitted a landscaping plan that will address the visual intrusion of
the floodwall. Relying on existing scrub trees and bushes to ameliorate the visual blight of a 9
foot, sheet metal wall that is over 5,531 feet in length is inadequate.
(10) Site accessibility in accordance with the provisions of the Americans with Disabilities Act
(ADA), including parlcing spaces, passenger loading zones and accessible routes.
The site plan will have no impact on handicapped accessibility and is consistent with this
finding.
(11) Provision for erosion and sediment control as specified in the "Ramsey Erosion and
Sediment Control Handbook."
MAC has not provided a detailed plan for sediment control for the compensatory excavation.