Loading...
4.a. Bottineau scoping booklet_comment letterBassett Creek Watershed Management Commission 7800 Golden Valley Road | Golden Valley, MN 55427 | www.bassettcreekwmo.org | Established 1968 Crystal | Golden Valley | Medicine Lake | Minneapolis | Minnetonka | New Hope | Plymouth | Robbinsdale | St. Louis Park February 14, 2012 Mr. Brent Rusco Bottineau Transitway Project Manager Hennepin County 701 Fourth Avenue South, Suite 400 Minneapolis, MN 55415 Re: Bottineau Transitway Project Scoping for Draft EIS BCWMC #2012-5 Dear Mr. Rusco: Thank you for providing the Bassett Creek Watershed Management Commission (BCWMC) with the opportunity to review the Bottineau Transitway Project Scoping Booklet and to provide comments on the scoping for the Draft EIS. We also appreciated the invitation to attend the January 19, 2012 interagency scoping meeting. Although we did not attend the meeting, over the past few months BCWMC staff met with project representatives on three occasions to discuss the project and concerns that the BCWMC may have regarding the project. On behalf of the BCWMC, we have reviewed the Scoping Booklet and offer the following comments on the areas potentially impacted by the project that are within the BCWMC jurisdiction. General/Background Portions of two of the proposed alignment alternatives are located in the jurisdiction of the BCWMC:  Nearly all of Alternative D1, from about Russell Ave. N. in Minneapolis to the intersection of Alternative D1 and D2 near the Robbinsdale/Crystal border. Stormwater runoff from this portion of the route will discharge directly to Bassett Creek, or to Grimes Pond, North Rice Pond and South Rice Pond (which eventually drain to Bassett Creek).  A portion of Alternative D2, between about 17th Ave. N. in Minneapolis and the Robbinsdale/Minneapolis border. Stormwater runoff from this portion of the route will discharge directly to Bassett Creek. Floodplain Issues The Alternative D1 route follows the Burlington-Northern Santa Fe (BNSF) railroad corridor. A portion of this route in Golden Valley (and Wirth Park in particular) is located along the Main Stem of Bassett Creek and South Rice Lake. In Robbinsdale the route is located along Grimes Pond, North Rice Lake and South Rice Lake. The BCWMC’s 100-year floodplain elevation for Bassett Creek along the D1 route ranges from elevation 826.0 ft. (NGVD29) at the upstream end of TH 55 to 832.0 ft. (NGVD29) at the Mr. Brent Rusco February 14, 2012 Page 2 p:\mpls\23 mn\27\2327051\workfiles\plat reviews\2012\2012-5 bottineau scoping booklet_comment letter_draft_with signature.docx downstream side of Bassett Creek Drive. In addition, the BCWMCs 100-year floodplain elevation for Grimes Pond/North Rice Lake is 838.0 ft (NGVD29) and for South Rice Lake is 831.5 ft (NGVD29). During our meetings with project representatives, we discussed the potential of this project to result in filling in the Bassett Creek floodplain, generally within Wirth Park, and in Grimes Pond/North Rice Pond. As discussed, the BCWMC will not allow filling within the BCWMC-established floodplain without mitigation. Proposals to fill within the floodplain must obtain BCWMC approval and provide compensating storage (1:1 basis) and/or channel modifications so that the flood level is not increased at any point along the creek due to fill. Floodplain management policies are listed in Section 5.2.2.2 of the BCWMC’s 2004 Watershed Management Plan. Please also see the BCWMC’s submittal and design requirements for projects (“Requirements for Improvements and Development Proposals,” 2008). These documents can be found on the BCWMC website: www.bassettcreekwmo.org. Runoff and Rate Control The BCWMC regulates stormwater runoff discharges and volumes to minimize flood problems, flood damages, and future costs of stormwater management systems. The Bottineau Transitway project has the potential to significantly increase the amount of impervious surface in the Bassett Creek watershed. Alternative D1 in particular, would increase the impervious surface in close proximity to the creek itself. This will result in increased runoff rates if not controlled. Best management practices must be implemented to ensure flood profiles are not increased along Bassett Creek. Water Quality The BCWMC and its member cities have committed significant resources to the improvement of the quality of stormwater runoff reaching the Mississippi River, by reducing nonpoint source pollution carried as stormwater runoff. The BCWMC strongly encourages the County to implement best management practices to treat transitway runoff to ensure that the project does not increase pollutant- loading to adjacent water bodies. The BCWMC’s water quality policies are listed in Section 4.2 of the Watershed Management Plan. The BCWMC expects the Bottineau Transitway project design to include stormwater treatment and erosion control measures that will reduce the amount of phosphorus and sediment carried by stormwater runoff to Bassett Creek. The BCWMC also expects the county to consider measures to minimize the amount of increased impervious surfaces resulting from the project. Additional pollutants of concern to the BCWMC include chloride from road salting, fuel, oils, metals and construction runoff which could enter storm drains and downstream water resources. Adequate permanent and temporary construction BMPs must be implemented as part of the project. Please also see the BCWMC’s submittal and design requirements for projects (“Requirements for Improvements and Development Proposals,” 2008). These documents can be found on the BCWMC website: www.bassettcreekwmo.org. Maintenance Maintenance of stormwater management (water quality and flood control) features is critical to ensure proper operation. The EA should describe the maintenance measures the county proposes to undertake to Mr. Brent Rusco February 14, 2012 Page 3 p:\mpls\23 mn\27\2327051\workfiles\plat reviews\2012\2012-5 bottineau scoping booklet_comment letter_draft_with signature.docx ensure the effectiveness of stormwater management features. The EA should also identify the parties responsible for inspections, the parties responsible for maintenance, and the inspection and maintenance schedules. The BCWMC is concerned that if these operation and maintenance responsibilities are not clearly laid out, the responsibility will fall on the member cities or BCWMC to perform the duties. Erosion Control A BCWMC goal is to prevent erosion and sedimentation to the greatest extent possible to protect the BCWMC’s water resources from increased sediment loading and associated water quality problems. Temporary and permanent best management practices must be implemented to control construction and post-development runoff from the site and erosion. Erosion and sediment control policies are listed in Section 6.2 of the Watershed Management Plan. Please also see the BCWMC’s submittal and design requirements for projects (“Requirements for Improvements and Development Proposals,” 2008). These documents can be found on the BCWMC website: www.bassettcreekwmo.org. Wetland Management The BCWMC wetland goal is to achieve no net loss of wetlands in the Bassett Creek watershed in conformance to the Minnesota Wetland Conservation Act (WCA) and associated rules (Minnesota rules 8420). Minneapolis and Golden Valley are the local governmental units (LGUs) responsible for administering the WCA in their cities; BCWMC is the LGU for Robbinsdale. Potential wetland impacts were discussed during our meetings with project representatives. Wetland management policies are listed in Section 8.0 of the Watershed Management Plan. Please also see the BCWMC’s submittal and design requirements for projects (“Requirements for Improvements and Development Proposals,” 2008). These documents can be found on the BCWMC website: www.bassettcreekwmo.org. The BCWMC recognizes the challenges of meeting the corridor’s transportation needs, and providing transit alternatives in particular. The BCWMC appreciates the opportunity to provide these comments early in the process and looks forward to working with you to restore and protect the health of the BCWMC’s water resources. Again, thank you for the opportunity to review the Bottineau Transitway Project Scoping Booklet. Please feel free to contact me if you have any questions at 952-832-2813 or kchandler@barr.com. Sincerely, Karen L. Chandler, P.E. Barr Engineering Co. Engineers for the Bassett Creek Watershed Management Commission c: BCWMC Commissioners Jeannine Clancy, City of Golden Valley Lois Eberhart, City of Minneapolis Richard McCoy, City of Robbinsdale Rachael Crabb, Minneapolis Park and Recreation Board