HomeMy WebLinkAbout[05] EAW - Distribution Center crJY stJOSEPH Council Agenda Item 5
MEETING DATE: November 16,2018
AGENDA ITEM: EAW—Declaration of Negative Impact
SUBMITTED BY: Engineering/Administration
BOARD/COMMISSION/COMMITTEE RECOMMENDATION: The EDA has been working with a
developer for a project to be located near I-94 and has recommended the Council initiate the EAW
Process
The City Council on September 17,2018 approved for publication and distribution an EAW for a
proposed distribution center to include up to 745,000 square feet.
BACKGROUND INFORMATION: MN Rules 4410.4300 Subp. 14A requires that an EAW be
prepared for Industrial/Commercial facilities over 300 square feet. The City is the Regulating
Governmental Unit(RGU)for the process and is responsible for the content of the document,distribution,
publication and response for all comments regarding the contents in the EAW. The cost of the EAW is
borne by the developer.
The document was published on October 1, 2018 in the EQB Monitor which started the 30 day comment
period. At the same time copies of the EAW were distributed to the agencies required by MN Rules. The
comment period ended on October 31,2018 and the following comments were received:
• October 2, 2018 Greg Bechtold, Stearns County
• October 16,2018 Elizabeth Tegdesch, MPCA
• October 16, 2018 Colleen Whaley, US Army Corp of Engineers
• October 31, 2018 Becky Horton, DNR
• October 31, 2018 Katie Breth, Stearns County Soil and Water
• October 31,2018 Gina Dullinger
An additional comment from MN Dept of Administration, State Historic Preservation Office was received
after the deadline but will be incorporated. All of the comments have been addressed within the final
document.
Upon the City Council considering the document complete,the final action is adopting a resolution
approving the St.Joseph Distribution Center Environmental Assess Worksheet(EAW),Finding no need
for an Environmental Impact Statement(EIS).
ATTACHMENTS: Final EAW Document with comments addressed
Comments Received
Resolution 2018-056 Approving the EAW
REQUESTED COUNCIL ACTION: Upon conclusion that all comments have been addressed,
authorize the Acting Mayor and Administrator to execute Resolution 2018-056 Approving the St.Joseph
Distribution Center EAW Finding no need for an EIS.
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CITY OF ST. JOSEPH
Resolution No.2018-056
A RESOLUTION APPROVING THE
ST.JOSEPH DISTRIBUTION CENTER
ENVIRONMENTAL ASSESSMENT WORKSHEET (EAW)
FINDING NO NEED FOR AN
ENVIRONMENTAL IMPACT STATEMENT (EIS)
WHEREAS Minnesota Rules 4410.4300 Subp. 14.A.requires that an EAW be prepared for Industrial,
Commercial and Institutional Facilities in excess of 300,000 square feet for a third or
fourth class city; and
WHEREAS On September 17,2018 an EAW for the St Joseph Distribution Center,which is designed
to include up to 745,000 square feet of warehouse/distribution space,was approved for
publication by the St.Joseph City Council; and
WHEREAS Beginning on September 26, 2018, copies of the EAW were distributed to all persons and
agencies on the official Environmental Quality Board(EQB)mailing list and other
interested parties; and
WHEREAS On October 1,2018,the EAW was publicly noticed in the EQB Monitor, commencing
the 30-day public comment period;and
WHEREAS On October 1,2018, a public notice was submitted for publication in the St.Joseph
Newsleader newspaper to announce the completion of the EAW,its availability to
interested parties,and the process for submitting comments on the EAW,and
WHEREAS The 30-day comment period ended on October 31,2018 at 4:30 p.m.,and
WHEREAS The City of St.Joseph accepted and responded to all written comments received:
NOW THEREFORE BE IT RESOLVED THAT:
1. The EAW was prepared,published,and distributed in compliance with the procedures of the
Minnesota Environmental Policy Act and Minnesota Rules,Parts 4410.1000 to 4410.1700,
2. The EAW,combined with the supplemental information contained in the Response to Comments,
satisfactorily addressed all the issues raised and comments received for which existing information
could have been reasonably obtained,and further investigation is therefore not required,
3. Based on the criteria established in Minnesota Rules Part 4410.1700,the project does not have the
potential for significant environmental effects,
4. The City of St.Joseph makes a"Negative Declaration"on the need for an EIS,
5. The St.Joseph City Council adopts a"Negative Declaration",
6. An EIS is not required,and
7. The City of St.Joseph shall maintain a Record of Decision,including the Response to Comments on
the EAW,and will notify in writing,within five days, all persons on the EAW distribution list, all
persons who commented in writing during the 30-day comment period,and any other person upon
written request. The City of St.Joseph will also send notice of this decision to the project proposer
and the EQB.
This resolution adopted by recorded vote of the St. Joseph City Council in open session on the 19th Day of
November 2018.
Dale Wick
Acting Mayor of St. Joseph
ATTEST
Judy Weyrens
City Administrator
CITY OF ST. JOSEPH
RESPONSE TO COMMENTS, FINDINGS OF FACT,
AND RECORD OF DECISION
FOR THE
ST. JOSEPH DISTRIBUTION CENTER
ENVIRONMENTAL ASSESSMENT WORKSHEET (EAW)
November 6, 2018
TABLE OF CONTENTS
Page
INTRODUCTION 1
COMMENTS RECEIVED 1
RESPONSE TO COMMENTS 2
ITEM-BY-ITEM RESPONSES 2
Section 6.a. Proiect Description 2
Section 7. Cover Types 2
Section 8. Permits and Approvals Required 3
Section 9. Land Use 3
Section 10.b. Soils and Topography 4
Section 11.a.ii. Water Resources: Groundwater 4
Section 11.b.i.Water Resources 5
Section 11.b.ii. Water Resources: Stormwater 5
Section 11.b.iv. Water Resources: Surface Waters 6
Section 12. Contamination/Hazardous Materials/Wastes 7
Section 13. Fish, Wildlife, Plant Communities, and Sensitive Ecological Resources 7
Section 17. Noise 7
Section 18.Transportation 8
Section 19. Cumulative Potential Effects 8
FINDINGS OF FACT 9
RECORD OF DECISION 11
Page i
CITY OF ST. JOSEPH
RESPONSE TO COMMENTS, FINDINGS OF FACT,
AND RECORD OF DECISION
FOR THE
ST. JOSEPH DISTRIBUTION CENTER
ENVIRONMENTAL ASSESSMENT WORKSHEET (EAW)
November 6, 2018
INTRODUCTION
The Environmental Assessment Worksheet(EAW)was prepared,published,and distributed by the City of St.
Joseph for the proposed Warehouse Distribution Center pursuant to Minnesota Rules, Chapter 4410. The
completed EAW was distributed to the Environmental Quality Board(EQB) and persons and agencies listed
on the official June 2018 EQB EAW Distribution List in accordance with Minnesota Rules 4410.1500. The
notification was published in the EQB Monitor on October 1,2018,initiating the 30-day comment period. A
press release was submitted for publication in the St. Joseph Newsleader newspaper. The 30-day comment
period ended on October 31, 2018.
The EAW and comments on it have been reviewed in accordance with Minnesota Rules 4410.1700 to
determine if the project has potential for significant environmental effects. This document includes the
Response to Comments for all comments received by the City of St. Joseph, the Findings of Fact supporting
the decision, and the Record of Decision.
The purpose of an EAW is to evaluate a proposed project's potential for significant environmental effects. It
is not to be used to justify a decision, nor do indications of adverse environmental effects necessarily require
that a project be disapproved. EAWs are used as guides in issuing,amending,and denying permits and carrying
out other responsibilities of governmental units to avoid or minimize adverse environmental effects and to
restore and enhance environmental quality(Minnesota Rules 4410.0300, Subp. 3).
COMMENTS RECEIVED
Five agencies and one resident submitted written comments on the EAW. Six comments were dated or
received prior to the comment period deadline. Copies of the comment letters are included at the end of this
document. The following table lists the comment letters received in chronological order.
Table 1.0. Comment Letters Received
No. Comment Letter Received From Signatory Abbreviation Date
1. Stearns County Environmental Services Greg Bechtold SCES October 2,2018
2. Minnesota Pollution Control Agency Karen Kromar MPCA October 16,2018
3. Department of the Army, Corps of Engineers Brian Yagle Corps October 16,2018
4. Minnesota Department of Natural Resources Rebecca Horton DNR October 31,2018
5. Stearns County Soil&Water Conservation District Dennis Fuchs SWCD October 31,2018
6. Gina Dullinger Gina Dullinger Dullinger October 31,2018
Page 1
RESPONSE TO COMMENTS, FINDINGS OF FACT,AND RECORD OF DECISION
St.Joseph Distribution Center Environmental Assessment Worksheet(EAW) November 16,2018
RESPONSE TO COMMENTS
Minnesota Rules 4410.1600 states that the comments shall address the accuracy and completeness of the
material contained in the EAW, potential impacts that may warrant further investigation before the project is
commenced,and the need for an EIS on the proposed project. Comments that do not address these areas have
been noted for the record, but are not necessarily addressed in the response. As part of the process in
determining whether an EIS is needed, the City of St. Joseph must respond to all substantive comments
received during the 30-day comment period(Minnesota Rules 4410.1700, Subp.4 and 5).
This document responds to comments on an item-by-item basis. Comments are organized by EAW Item
number and addressed on an item-by-item basis. Agencies who commented are listed by abbreviation in
random order at the start of each topic and item.
ITEM-BY-ITEM RESPONSES
Section 6.a. Project Description
Agencies/Individuals Commenting: SWCD, Dullinger
Comment Summary: The SWCD believes that the scope of the project is being downplayed by only listing
the building area.Dullinger is concerned about phasing of construction and stockpiling of material.
Response
The building area is the determining factor for this type of environmental review(Part 4410.4300
Subp. 14.A.-Industrial,commercial,and institutional facilities). The impervious surface is listed in
Section 7 and is shown at 51.9%of the area for a total of 44.7-acres. The construction will be phased
based on market needs. It is anticipated there will be stockpiling during each phase of construction,
but between phases the stockpiling will be minimized.
Section 7. Cover Types
Agencies/Individuals Commenting: SCES, DNR, SWCD, Dullinger
Comment Summary: Stearns County Environmental Services provided data for hydric soils and states that
the amount and location of wetland within the project are unknown until a Level 2 Wetland Delineation
is completed and approved. The DNR states the shoreland overlay district has a maximum impervious
coverage of 25%,non-water-orientated industrial uses in the shoreland overlay district must have double
the setback or substantially screened from view from the water by vegetation or topography,and reminds
the City that the DNR must approve any modifications to the City's shoreland ordinance. The DNR
notes that a variance will be requested for a building height over 40-feet, but the maximum building
height in the shoreland overlay district is 25-feet. The SWCD suggests looking at strategies to minimize
the construction site footprint, especially during the first phase. Dullinger requests clarification of uses
in Table 7.1.
Response
A Level 2 Wetland Delineation was completed on site on October 30, 2018,and will be reviewed by
Stearns County. The wetland permitting has been identified under Section 8.Permits and Approvals
Required. Impervious surface coverage will be limited to 25%in the shoreland overlay district. If the
project proposer chooses to screen the building from view from the water instead of doubling the
setback,the City will require planting plans as a means of verification. If the Shoreland Ordinance is
modified the City will contact the DNR for comments. The variance for building height noted on page
Page 2
RESPONSE TO COMMENTS, FINDINGS OF FACT,AND RECORD OF DECISION
St. Joseph Distribution Center Environmental Assessment Worksheet(EAW) November 6,2018
5 of the EAW is in reference to the underlying zoning. The project proposer does not anticipate
needing a height variance in the shoreland overlay district.
The project proposer is looking at ways to reduce the construction foot print. The current first phase
includes grading the entire 4-acre pond and using that material to rough grade part of the site. The
project proposer will revisit this during the development of construction plans to see if this is the best
method to minimize runoff.
The building coverage is listed under"Other/Building". The"Impervious Surface"includes all
impervious surfaces except buildings (pavements,walks, etc.). The total impervious surfaces created
by the project will be 44.7-acres.
Section 8. Permits and Approvals Required
Agencies/Individuals Commenting: MPCA, DNR, SWCD
Comment Summary: The MPCA requests the EAW state which NPDES/SDS permit is required for the
project. The MPCA and SWCD believe this project may need a NPDES/SDS permit for Industrial
Activity from MPCA. The DNR states the project will require Public Waters permits from the DNR.
The DNR notes there are multiple crossings of the South Fork Watab River within a span of one-mile
and recommends using those crossings. Mitigation for a new crossing(if permitted)or widening of the
existing culverts on County Road 2 will be required. A hydraulic capacity study regarding potential
changes to the floodplain as a result of the crossing and outfall will be necessary as part of the Public
Waters permit.
Response
The NPDES/SDS Construction Stormwater General Permit(CSW Permit)will be incorporated into the
EAW Response to Comments. The Primary SIC for the warehouse activity does not trigger the
MPCA's NPDES/SDS permit for Industrial Activity. If the Primary SIC changes during design of the
project or future use of the facility,an NPDES/SDS permit will be obtained for the facility. Page 5 of
the EAW notes the Public Water crossing permit through the DNR. The project proposer met with the
DNR area hydrologist on August 21,2018 to better understand the DNR's requirements and concerns
regarding a South Fork Watab River Crossing. The project proposer has studied multiple locations in
central Minnesota and has studied different configurations on this site. The project proposer
understands they will need to demonstrate the steps and sequencing for the location as shown on the
proposed site plan. It is understood that a hydraulic capacity study will be required by the DNR.
Section 9. Land Use
Agencies/Individuals Commenting: SWCD, Dullinger
Comment Summary: The SWCD notes there is a trail on the east side of Country Road 2 and suggests
incorporating alternate forms of transportation into the plan. The SWCD requests clarification on the
parking variance to be requested. The SWCD also requests clarification as to which comprehensive plan
is referenced in Section 9.a.ii. and 9.b.iii. Dullinger notes the shifting of the proposed collector road to
the north property line, and questions why the access does not occur at that location. Dullinger also
notes the importance of collector streets and questions how right-of-way will be dedicated for these
collector streets. Dullinger asks how the project will conform to the shoreland overlay district.
Page 3
RESPONSE TO COMMENTS, FINDINGS OF FACT,AND RECORD OF DECISION
St.Joseph Distribution Center Environmental Assessment Worksheet(EAW) November 16,2018
Response
The EAW notes there are no trails within the project boundary. There is a trail on the east side of
County Road 2;however,the County Engineering Department has no plans to provide a pedestrian
crossing at this time. Stearns County Engineering Department also did not submit comments on the
EAW. The project proposer will work with the City to determine if alternative forms of transportation
are appropriate. The adjacent land use and transportation plans described in this Section did not
change with the adoption of the new Comprehensive Plan.
Access to a north collector street is problematic for a couple of reasons. There is not enough room to
create stacking at the future intersection, stacking at the project proposer's site, and include a guard
shack with turn around. Because trucks do not back up to loading docks from the passenger side,the
trucks would need to circle the building,or there would need to be additional drive lanes(and
associated impervious surfaces)to keep the trucks on the east side of the building. Additionally,grade
issues of up to 30' have been identified. The project proposer will work with the City to identify and
dedicate right-of-way for future streets.
The project proposer has worked to keep the site in line with the shoreland overlay district. The
project proposer has met with City staff to discuss options and conformity. In one of those meetings,
the City discussed revising a portion of the ordinance. Through the design process,the project
proposer will revise the site plan to bring it into conformance with ordinances. Per the current plan,
the accessory structure(guard shack)is in non-compliance because of the 300-foot setback. If the
setback remains in the ordinance,the project proposer will seek to obtain a variance from the setback
and also at screening and mitigation to offset the variance requested.
Section 10.b. Soils and Topography
Agencies/Individuals Commenting: SWCD
Comment Summary: The SWCD recommends using BMPs during construction such as protecting soils
from unnecessary disturbance and compaction, delineating and fencing off areas not to be disturbed,
using native, non-invasive plants for permanent cover, and using weed-seed free topsoil if import is
needed.
Response
Construction site BMPs will be developed during the design process, approved by the regulating
agencies, and implemented during construction. BMPs may include those listed above. It is not
anticipated that topsoil will be imported to the site.
Section 11.a.ii. Water Resources: Groundwater
Agencies/Individuals Commenting: MPCA, SWCD
Comment Summary: The MPCA notes site limitations for infiltration, including St. Joseph's Drinking
Water Supply Management Area(DWSMA). The SWCD also notes the concern to the DWSMA. The
SWCD notes watershed areas for the wetlands have not been identified and that the permitting of filling
of wetlands is not guaranteed. The SWCD suggests using native species or similar species for vegetation
reclamation.
Page 4
RESPONSE TO COMMENTS, FINDINGS OF FACT,AND RECORD OF DECISION
St.Joseph Distribution Center Environmental Assessment Worksheet(EAW) November 6,2018
Response:
The project proposer is working with the City of St. Joseph to identify the final site layout and will
incorporate DWSMA requirements, as required. Infiltration will be avoided in vulnerable portions of
the DWSMA. Additional construction BMPs, such as at fueling locations,shall be incorporated into
the SWPP Plan and implemented during construction. Impacts to wetlands will be sequenced and
permitted prior to site grading. Watershed areas for wetlands cannot be identified until on-site wetland
delineations occur and are approved. Wetland watersheds will be verified during the preliminary
design process. The project proposer will review the opportunity to use native species, especially
around the South Fork Watab River.
Section 11.b.i. Water Resources
Agencies/Individuals Commenting: Dullinger
Comment Summary: Dullinger notes the SSTS/holding tank option will be designed to County standards,
in cooperation with the City. Dullinger lists some of those standards and a concern about the life-span
of the system.
Response
The SSTS/holding tank will be designed according to applicable standards.
Section 11.b.ii. Water Resources: Stormwater
Agencies/Individuals Commenting: MPCA, DNR, SWCD, Dullinger
Comment Summary: The MPCA notes volume reduction requirements of the NPDES/SDS/CSW Permit
and that wet sedimentation basins are not considered a volume reduction practice. If infiltration is used
at the site, at least one soil boring must be conducted to verify the seasonal water table is at least 3-feet
below the bottom of the system and that the infiltration rate is above 8.3-inches per hour as measured in
the field. Pretreatment must be provided in advance of an infiltration system. The MPCA also
encourages the proposer to incorporate Better Site Design practices and Green Infrastructure. The DNR
suggests using infiltration practices to mitigate the potential changes in the floodplain. The SWCD notes
the challenge of recharging an aquifer when infiltration is not allowed by governing agencies. The
SWCD recommends improving the existing non-natural conditions to look more natural. The SWCD
recommends using permeable pavement. Dullinger notes the existing use of the land and the
interchangeable use of"Watab Creek"and"South Fork Watab River".
Response
Stormwater volume reduction BMPs meeting the design and construction requirements of the City of
St. Joseph and the MPCA NPDES/SDS CSW Permit will be incorporated into the final design. If
infiltration of stormwater is not an option, due to fueling areas,DWSMA,etc., other methods such as
water harvest and reuse will be utilized. The project proposer will investigate the options of Better Site
Design practices and Green Infrastructure.
The hydrology of the site,both existing and proposed conditions,will be modeled by the project
proposer and reviewed by the City. It will meet or exceed City standards.
Page 5
RESPONSE TO COMMENTS, FINDINGS OF FACT,AND RECORD OF DECISION
St.Joseph Distribution Center Environmental Assessment Worksheet(EAW) November 16,2018
Section 11.b.iv. Water Resources: Surface Waters
Agencies/individuals Commenting: Corps, DNR, SWCD, Dullinger
Comment Summary: The Corps notes that the current site layouts shows an access road crossing the South
Fork Watab River and impacts to an on-site ditch. The Corps notes that this type of proposed work often
includes the permanent or temporary discharge of fill material into the tributaries which may be waters
of the United States. Any activity that temporarily or permanently impacts a water of the United States
might require a Department of Army Permit. The DNR notes the potential for the watercourse to be
more"flashy"due to stormwater discharges. There is also the potential for scour at stormwater outfalls.
The DNR discusses requirements for culvert construction in the South Fork Watab River. The DNR
again notes lengthening the County Road 2 culverts or using the north field entrance as possible
alternatives to the shown South Fork Watab River crossing. The SWCD recommends the design of this
development not force a future collector road to impact wetlands. Dullinger discusses the realignment
of the collector streets and her concern about further impacts to wetlands. Dullinger also recommends
on-site wetland mitigation.
Response
Surface waters will be submitted to the Corps to determine status as water of the United States. If
surface waters are determined to be water of the United States,and the surface water will be impacted
by construction,the project proposer will permit the impacts through the Corps. Stormwater outfalls
will meet regulatory requirements to prevent scour. Stormwater discharges will be equal to or less
than existing conditions per City requirements. As stated by the DNR,this area of the South Fork
Watab River"has already been impacted through straightening, channelization,and realignment". As
part of the permitting process for the crossing,the project proposer will discuss the sequencing of the
site and access points. To address the two options suggested by the DNR:
- Lengthen Country Road 2 Culverts—The County will not allow a private parallel drive in their
right-of-way. In order to lengthen the culverts,maintain setbacks from the county right-of-way,
and utilize county design standards,it is estimated that an additional 120-lineal feet of watercourse
would be impacted.
- Utilize north field approach—There are two approaches north of the South Fork Watab River. The
northern most approach is approximately 30-feet in elevation higher than the proposed parking lot,
creating grades steeper than 5%. Additionally,the location of this approach is the approximate
location for a collector street. The south approach is just north of the South Fork Watab River.
This access point comes in north of the south side of the building, and since trucks only back into
docks from the driver's side at distribution facilities,it would require some trucks to travel an
addition mile around the building. Additionally,this access point would not meet county
intersection spacing requirements.
The project proposer is working with the City to minimize any collector street deviation from the
City's Transportation Plan. It should be noted that the Transportation Plan was prepared without on-
site wetland delineations. Those delineations have now been performed and wetlands have been
identified in the original locations of both collector streets. It is anticipated that the shifting of the
collector streets will not further these impacts. Any necessary wetland impacts,and associated
mitigation,will be sequenced and permitted through the appropriate governing agencies.
Page 6
RESPONSE TO COMMENTS, FINDINGS OF FACT,AND RECORD OF DECISION
St.Joseph Distribution Center Environmental Assessment Worksheet(EAW) November 6,2018
Section 12. Contamination/Hazardous Materials/Wastes
Agencies/Individuals Commenting: SWCD
Comment Summary: The SWCD asks how to protect the project from stormwater and/or vandalism during
and after the construction process.
Response
Typical methods of storing hazardous materials include double containment, secured facilities,etc.
These methods will be detailed during the fmal design and identified in the SWPP Plan.
Section 13. Fish, Wildlife, Plant Communities, and Sensitive Ecological Resources
Agencies/Individuals Commenting: SWCD, Dullinger
Comment Summary: The SWCD notes there may be an opportunity to offset some cumulative impacts
(stream crossing) by restoring the meanders to the straightened, channelized, and realigned South Fork
Watab River. The SWCD recommends the project proposer work with them and notes the riparian
corridor as the most important habitat on site. Dullinger requests the terrestrial community and the
vertebrate species indicated in the EAW.
Response
The project proposer will work with the permitting agencies to mitigate any impacts to the South Fork
Watab River,including evaluating the potential to restore channelized sections of South Fork Watab
River as appropriate.
At the time the EAW was prepared,the Natural Heritage Information System(NNIS)response was not
available from the DNR. Consequently,Westwood relied upon licensed data from the DNR to provide
general information regarding rare species and communities. Westwood's license agreement only
permits rare feature discloser to the nearest section. The one vertebrate species identified in the
database within the same section,but not within the project area,is the Cerulean Warbler. The
terrestrial community located in the database within the same section,but not within the project area,is
a Tamarack swamp. The DNR's NHIS response letter was received on October 4,2018. The DNR's
letter concludes that they do not believe the proposed project will negatively affect any known
occurrences of rare features. A second letter was received from the DNR Region Environmental
Assessment Ecologist on October 31,2018. That letter reiterates that"the Natural Heritage Review
letter concluded that no adverse impacts to rare species were expected as a result of this project."
Section 17. Noise
Agencies/Individuals Commenting: MPCA
Comment Summary: The MPCA recommends all construction equipment be appropriately muffled and
that construction activities take place between 7:00am and 10:00pm to limit noise pollution.
Page 7
RESPONSE TO COMMENTS, FINDINGS OF FACT,AND RECORD OF DECISION
St.Joseph Distribution Center Environmental Assessment Worksheet(EAW) November 16,2018
Response
The project proposer will follow applicable state and local laws regarding noise regulations. The
project proposer will work with the City to establish construction work hours prior to proceeding with
construction activities.
Section 18. Transportation
Agencies/Individuals Commenting: SWCD, Dullinger
Comment Summary: The SWCD recommends pervious pavements or other BMPs to reduce the amount
and impact of impervious surfaces. Dullinger discusses the history of County Road 2 in this area, the
types of vehicles using the property, and turning movements. Dullinger notes the project is below the
threshold for a traffic impact study, but comments additional turn lanes and acceleration lanes may be
needed. Dullinger also discusses using the future collector streets for access to County Road 2.
Response
Stormwater volume reduction BMPs meeting the design and construction requirements of the City of
St.Joseph and the MPCA NPDES/SDS CSW Permit will be incorporated into the final design. The
project proposer will investigate the options of Better Site Design practices and Green Infrastructure.
Preliminary conversations between the City and the Stearns County Highway Department regarding
the project proposer's site and use have occurred. The traffic generated by the project is within the
capacity of County Road 2. The Steams County Highway Department has not provided official
comments on the EAW. The project proposer is working with the City to identify access to the site
from a future south road in roughly the same location as Leaf Road if that option were to move
forward.
Section 19. Cumulative Potential Effects
Agencies/Individuals Commenting: SWCD
Comment Summary: The SWCD recommends pervious pavements or other BMPs to reduce the amount
and impact of impervious surfaces. The SWCD recommends wetland and habitat restoration.
Response
The project proposer will investigate pervious pavements and other BMPs to reduce the amount and
impact of impervious surfaces.. The project proposer will investigate options for wetland and habitat
restoration.
Page 8
RESPONSE TO COMMENTS, FINDINGS OF FACT,AND RECORD OF DECISION
St.Joseph Distribution Center Environmental Assessment Worksheet(EAW) November 6,2018
FINDINGS OF FACT
1. Section 6.a.Project Description.The Warehouse Distribution Center is proposed on approximately
86.03-acres of primarily agricultural land in St.Joseph. The project proposes a total gross building
area of 745,000 square feet. The project will be serviced by municipal sewer and water.
2. Section 6.b.Project Description.The Project will include coverage under the National Pollutant
Discharge Elimination System(NPDES)and State Disposal System(SDS)Construction Stormwater
(C SW) General Permit.As a part of the Permit,best management practices(BMPs)will be put into
practice during all phases of construction.
3. Section 6.c.Project Description.Project Magnitude "Industrial Building Area"includes the
building area as well as pavement and walks surrounding each building,it does not include streets,
surface parking, truck fueling and maintenance, stormwater ponding, and green space. Streets,
parking, and fueling areas are considered impervious surfaces; impact areas are quantified in Section
7. Cover Types,Table 7.1 Estimated Before and After Cover Types.
4. Section 7.Cover Types.Prior to initiating construction, a wetland delineation was conducted on
October 30,2018 to determine wetland boundaries on site.Approval from the US Army Corps of
Engineers and Steams County Environmental Services will be necessary before proceeding with the
first phase of construction.Impervious surface coverage will be limited to 25%in the shoreland
overlay district; if necessary, additional measures will be taken to substantially screen infrastructure
using vegetation within the shoreland overlay district.A stormwater infiltration pond is proposed to
mitigate runoff from new impervious surfaces.Impervious surfaces in Table 7.1 includes streets,
surface parking, and truck fueling and maintenance. Other/Buildings in Table 7.1 includes the
warehouse building, associated support buildings, and pavements/walks around the buildings.
5. Section 8.Permits and Approvals Required.The NPDES/SDS Construction Stormwater General
Permit(CSW Permit)will be utilized for the Project. The Primary Standard Industrial Classification
(SIC)for the warehouse activity does not trigger the MPCA's NPDES/SDS permit for Industrial
Activity.A hydraulic capacity study for the Public Waters permit will be prepared for the DNR.The
applicant will acquire all applicable permits prior to Project construction.
6. Section 9.Land Use.The applicant will work with the City regarding alternative forms of
transportation and their practicability in terms of the Project. A north collector street is not feasible
given the characteristics at the intersection in conjunction with stacking issues,grading conditions,
and the necessary conditions for loading and unloading trucks. If the current setback requirements
are not changed during revisions of the Shoreland Overlay District ordinance, a variance will be
necessary for the guard shack.
7. Section 10.b. Soils and topography. Soil disturbances at the site will be limited to the extent
necessary to construct the proposed improvements. Limits of grading and temporary and permanent
erosion control measures will be in accordance with the MPCA NPDES Construction Stormwater
General Permit.
8. Section 11.a.ii.Water Resources: Groundwater. The Applicant is working with the City to
conform the final site layout in conjunction to Drinking Water Supply Management Area(DWSMA)
requirements.Impacts to groundwater resources will be minimized using construction BMPs, siting
Project infrastructure away from sensitive areas to the maximum extent practicable, as well as
utilizing native species where feasible.
9. Section 11.b.i.Water Resources: Wastewater.The SSTS/holding tank will be designed using
applicable standards.
Page 9
RESPONSE TO COMMENTS, FINDINGS OF FACT,AND RECORD OF DECISION
St.Joseph Distribution Center Environmental Assessment Worksheet(EAW) November 16,2018
10. Section 11.b.ii. Water Resources: Stormwater.BMPs noted in the NPDES/SDS CSW Permit will
be integrated into the final site design to properly manage stormwater.Other methods of stormwater
management are available if infiltration is not a practicable option.The Applicant is reviewing the
Better Site Design practices and Green Infrastructure methods to incorporate into the Project as
practicable.
11. Section 11.b.iv.Water Resources: Surface Waters. Surface water construction permits will be
applied for on an as-needed basis. Expanding the County Road 2 culverts is not feasible due to
additional watercourse impacts.Both of the suggested approaches north of the South Fork Watab
River are not practicable given issues with steep grades and the necessary conditions for loading and
unloading trucks.
12. Section 12. Contamination/Hazardous Materials/Wastes.On-site hazardous materials storage will
integrate protection methods from the SWPPP,including double containment and secured facilities.
13. Section 13.Fish,wildlife,plant communities,and sensitive ecological resources(rare features).
The Applicant intends to coordinate with the Stearns County Soil&Water Conservation District
regarding impacts and potential restoration to sections of the South Fork Watab River.
14. Section 17.Noise.The Project will abide by state and local laws regarding noise regulations.
15. Section 18. Transportation.County Road 2 has the capacity to accommodate traffic generated by
the Project.The Applicant will coordinate with the City regarding alternative site access options.
16. Section 19. Cumulative Potential Effects.The Project proposer will investigate approaches and
options associated with Better Site Design practices and Green Infrastructure.
Page 10
RESPONSE TO COMMENTS, FINDINGS OF FACT,AND RECORD OF DECISION
St.Joseph Distribution Center Environmental Assessment Worksheet(EAW) November 6,2018
RECORD OF DECISION
Based on the EAW,the Response to Comments, and the Findings of Fact,the City of St.Joseph as the RGU
for this environmental review,concludes the following:
1. The EAW was prepared,published,and distributed in compliance with Minnesota Statutes,Chapter
116D,to implement the environmental review procedures established by the Minnesota Environmental
Policy Act and Minnesota Rules Parts 4410.1000 to 4410.1700(1997).
2. The EAW, combined with the supplemental information contained in the Response to Comments and
Findings of Fact, satisfactorily addressed and responded to all of the issues raised and comments
received for which existing information could have been reasonably obtained, and further investigation is
therefore not required.
3. Based on the criteria established in Minnesota Rules Part 4410.1700,the project does not have the
potential for significant environmental effects.
4. An EIS is not required for the St. Joseph Distribution Center.
5. The City Council of the City of St.Joseph adopts a"Negative Declaration".
Page 11
.aa cirya{,ci+xMh mm
CITY OF ST. JOSEPH
Resolution No.
A RESOLUTION APPROVING THE
ST.JOSEPH DISTRIBUTION CENTER
ENVIRONMENTAL ASSESSMENT WORKSHEET (EAW)
FINDING NO NEED FOR AN
ENVIRONMENTAL IMPACT STATEMENT (EIS)
WHEREAS Minnesota Rules 4410.4300 Subp. 14.A.requires that an EAW be prepared for Industrial,
Commercial and Institutional Facilities in excess of 300,000 square feet for a third or
fourth class city; and
WHEREAS On September 17,2018 an EAW for the St Joseph Distribution Center,which is designed
to include up to 745,000 square feet of warehouse/distribution space,was approved for
publication by the St.Joseph City Council; and
WHEREAS Beginning on September 26,2018,copies of the EAW were distributed to all persons and
agencies on the official Environmental Quality Board(EQB)mailing list and other
interested parties; and
WHEREAS On October 1, 2018,the EAW was publicly noticed in the EQB Monitor,commencing
the 30-day public comment period; and
WHEREAS On October 1, 2018, a public notice was submitted for publication in the St.Joseph
Newsleader newspaper to announce the completion of the EAW,its availability to
interested parties,and the process for submitting comments on the EAW, and
WHEREAS The 30-day comment period ended on October 31,2018 at 4:30 p.m., and
WHEREAS The City of St. Joseph accepted and responded to all written comments received:
NOW THEREFORE BE IT RESOLVED THAT:
1. The EAW was prepared,published,and distributed in compliance with the procedures of the
Minnesota Environmental Policy Act and Minnesota Rules,Parts 4410.1000 to 4410.1700,
2. The EAW,combined with the supplemental information contained in the Response to Comments,
satisfactorily addressed all the issues raised and comments received for which existing information
could have been reasonably obtained, and further investigation is therefore not required,
3. Based on the criteria established in Minnesota Rules Part 4410.1700,the project does not have the
potential for significant environmental effects,
4. The City of St.Joseph makes a"Negative Declaration"on the need for an EIS,
5. The St.Joseph City Council adopts a"Negative Declaration",
6. An EIS is not required,and
7. The City of St. Joseph shall maintain a Record of Decision,including the Response to Comments on
the EAW,and will notify in writing,within five days,all persons on the EAW distribution list,all
persons who commented in writing during the 30-day comment period,and any other person upon
written request. The City of St. Joseph will also send notice of this decision to the project proposer
and the EQB.
This resolution adopted by recorded vote of the St.Joseph City Council in open session on the 19`''Day of
November 2018.
Dale Wick
Acting Mayor of St.Joseph
ATTEST
Judy Weyrens
City Administrator
Comment
Letters
Received
Judy Weyrens
From: Bechtold, Greg <Greg.Bechtold@co.stearns.mn.us>
Sent: Tuesday, October 2, 2018 4:38 PM
To: Judy Weyrens
Cc: Bechtold, Greg
Subject: EAW St Joseph Distribution Center
Attachments: 10-2-2018 potential wetland areas.pdf
Judy:The proposed site has 30-feet of elevation difference that will require extensive movement of earth to prepare the
site for this project.The agriculture field has multiple drain tile lines installed to make it dry enough for agricultural
crops.There is hydric soil, and potentially wetland adjacent to the two drainageways, and the South Fork of the Watab
River.The majority of the site is agricultural field; however it may still be wetland.There are springs, and sidehill seeps in
the project area.There may be up to 20-acres of wetland within the project area. Please see the attached 10-2-2018
potential wetland areas sketch.The amount and location of wetland within the project are unknown until a Level 2
wetland delineation is completed, and approved.
Thank you, Greg
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Judy Weyrens
From: Tegdesch, Elizabeth (MPCA) <elizabeth.tegdesch@state.mn.us>
Sent: Tuesday, October 16, 2018 9:49 AM
To: Judy Weyrens
Cc: Kromar, Karen (MPCA); Card, Dan (MPCA);Wenzel, Melissa (MPCA);Getman, Roberta
(MPCA); Steinwand, Christine (MPCA); McDill, Teresa (MPCA)
Subject: MPCA Comment Letter- St.Joseph's Distribution Center
Attachments: St.Joesph's Distribution Center EAW Comment Ltr.pdf
Attached are the Minnesota Pollution Control Agency's comments on the St.Joseph's Distribution Center Environmental
Assessment Worksheet.A paper copy will follow by U.S. mail.
Please acknowledge receipt of this comment letter to Karen Kromar at Karen.kromar@state.mn.us
Thank you.
Elizabeth Tegdesch
Environmental Review and EQB Support
Minnesota Pollution Control Agency
520 Lafayette Road N
St. Paul, MN 55155/651-757-2100
elizabeth.tegdescht state.mn.us
NOTICE:This email(including attachments)is covered by the Electronic Communications Privacy Act, 18 U.S.C.2510-2521.This email
may be confidential and may be legally privileged. If you are not the intended recipient,you are hereby notified that any retention,
dissemination,distribution,or copying of this communication is strictly prohibited. Please reply back to the sender that you have
received this message in error,then delete it.Thank you.
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11111 Ai MINNESOTA POLLUTION
II CONTROL AGENCY
520 Lafayette Road North I St.Paul,Minnesota 55155-4194 1651-296-6300
800-657-3864 I Use your preferred relay service I info.pca@estate.mn.us I Equal Opportunity Employer
October 16, 2018
Judy Weyrens
Administrator
City of St.Joseph
75 Callaway Street East
St.Joseph, MN 56374
Re: St.Joseph's Distribution Center Environmental Assessment Worksheet
Dear Judy Weyrens:
Thank you for the opportunity to review and comment on the Environmental Assessment Worksheet
(EAW)for the St.Joseph's Distribution Center project(Project) in the city of St.Joseph,Stearns County,
Minnesota.The Project consists of construction of a new warehouse/distribution facility. Regarding
matters for which the Minnesota Pollution Control Agency(MPCA) has regulatory responsibility or other
interests,the MPCA staff has the following comments for your consideration.
Permits and Approvals.(Item S)
• The EAW should specify the type of National Pollutant Discharge Elimination System/State Disposal
System (NPDES/SDS) permit required for the Project. In this case it seems the reference is to the
Construction Stormwater General Permit(CSW Permit).
• Please note it is likely that the Project also requires an Industrial Stormwater NPDES/SDS General
Permit for Sector P/Land Transportation activities.This coverage must be applied for 180 days
before construction or operation of the facility. For questions regarding Industrial Stormwater,
please contact Melissa Wenzel atjrVlellssa.wenz+eiegate.mn.us or 651-757-2816.
Water Resources(Item 11)
• The EAW proposes use of a wet sedimentation basin and/or infiltration areas at the site. It should be
noted that the CSW Permit requires a volume reduction method to treat the first one inch of
stormwater runoff unless prohibited for one of the reasons in the Permit.Volume reduction is
provided via infiltration or water harvest and reuse.A wet sediment basin is not considered a
volume reduction practice.
• The Project proposer needs to determine whether infiltration is prohibited at the site.The fueling
and maintenance area at the site cannot discharge stormwater into an infiltration area and would
require a separate stormwater treatment system.Also,stormwater cannot be infiltrated into an
Emergency Response Area (ERA) designated by the Minnesota Department of Health in a Drinking
Water Supply Management Area(DWSMA)with high to very high vulnerability.The EAW states that
the DWSMA has a medium to very high vulnerability.Only if the ERA is classified as moderate or the
infiltration system is located outside the ERA within a DWSMA with high to very high vulnerability
can a Municipal Separate Storm Sewer System perform or approve a higher level of engineering
review to allow the infiltration system.
• If infiltration is used at the site,at least one soil boring must be conducted in the proposed location
to verify the seasonal water table is at least 3 feet below the bottom of the system and that the
infiltration rate is above 8.3 inches per hour as measured in the field.Also,pretreatment must be
provided in advance of an infiltration system.
Judy Weyrens
Page 2
October 16,2018
• The MPCA highly encourages the proposers to incorporate Better Site Desien practices and Green
Infrastructure into the site design to minimize the amount of new impervious areas that require
stormwater treatment and to reduce the amount of stormwater runoff reaching the Watab River.
Questions regarding CSW Permit requirements should be directed to Roberta Getman at 507-206-2629
or Roberta.Getrnan tate.mn.us.
Noise(Item 17)
To help maintain the state noise standards during project construction,the MPCA recommends that all
of the equipment used during construction be appropriately muffled.We also recommend that
construction activities take place during daytime hours(7:00 am to 10:00 pm),during which time the
noise standards are less strict,as is most practicable. For noise related questions, please contact
Christine Steinwand at 651-757-2327 or Christine.Steinwand'state.mn.us.
We appreciate the opportunity to review this Project. Please provide your specific responses to our
comments and notice of decision on the need for an Environmental Impact Statement. Please be aware
that this letter does not constitute approval by the MPCA of any or all elements of the Project for the
purpose of pending or future permit action(s) by the MPCA. Ultimately,it is the responsibility of the
Project proposer to secure any required permits and to comply with any requisite permit conditions. If
you have any questions concerning our review of this EAW, please contact me by email at
Karern.krQmat@state.mn.us or by telephone at 651-757-2508.
Sincerely,
Karen Kromar
Project Manager
Environmental Review Unit
Resource Management and Assistance Division
KK:bt
cc: Dan Card, MPCA,St. Paul
Melissa Wenzel, MPCA,St. Paul
Roberta Getman, MPCA, Rochester
Christine Steinwand, MPCA,St. Paul
Teresa McDill, MPCA,St. Paul
Judy Weyrens
From: Whaley, Colleen A CIV CEMVP CEMVD(US) <Colleen.A.Whaley@usace.army.mil>
Sent: Tuesday, October 16, 2018 11:13 AM
To: Yagle, Brian B CIV USARMY CEMVP (US);Chris.rice@ricecompanies.com;Judy Weyrens
Cc: Hafer, Kristen A CIV USARMY CEMVP (US)
Subject: 2018-02941-BBY 10-16-2018 Pre-App Letter(UNCLASSIFIED)
Attachments: 2018-02941-BBY 20181016 Preapp-MN.PDF
CLASSIFICATION: UNCLASSIFIED
Hello,
Attached please find the subject document. A hard copy will not be sent. If you wish to receive a hard copy of
this letter please respond to this email. If you have any other questions, please contact the project manager
indicated in the letter.
Colleen A. Whaley
Environmental Protection Technician
U.S. Army Corps of Engineers
180 Fifth Street East, Suite 700
Saint Paul, MN 55101-1678
(651) 290-5361
CLASSIFICATION: UNCLASSIFIED
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. 4 DEPARTMENT OF THE ARMY
ST.PAUL DISTRICT,CORPS OF ENGINEERS
180 FIFTH STREET EAST,SUITE 700
ST.PAUL,MN 55101-1678
October 16, 2018
REPLY TO ATTENTION OF
REGULATORY BRANCH
Regulatory File No. MVP-2017-02941-BBY
Rice Companies
do Chris Rice
1019 Industrial Blvd. South
Sauk Rapids, Minnesota 56379
Dear Mr. Rice:
We have received your email dated September 24, 2018 regarding the Environmental
Assessment Worksheet(EAW)for the St. Joseph Distribution Center project in the City of St.
Joseph. The proposed project is located in the Section 9, Township 124 North, Range 29 West,
Stearns County, Minnesota. The purpose of this letter is to inform you that based on available
information a Department of the Army (DA) permit may be required for your proposed activity.
The Proposed Plan Site(Exhibit 3)figure submitted with the EAW for the St. Joseph Distribution
Center appears to show an access road crossing the South Fork Watab River and impacts to an
on-site ditch from the construction of a building with associated parking. This type of proposed
work often includes the permanent or temporary discharge of fill material into these tributaries
which may be waters of the United States. Any activity that temporarily or permanently impacts
a water of the United States might require a Department of Army Permit. This letter also
provides general information regarding the U.S. Army Corps of Engineers (Corps) regulatory
program.
When a proposal involves the discharge of dredged or fill material into waters of the United
States, it may be subject to Corps jurisdiction under Section 404 of the Clean Water Act (CWA
Section 404). Waters of the United States include navigable waters, their tributaries, and
adjacent wetlands (33 CFR § 328.3). CWA Section 301(a) prohibits discharges of dredged or
fill material into waters of the United States, unless the work has been authorized by a DA
permit under CWA Section 404. Information about the Corps permitting process can be
obtained online at http://www.mvp.usace.army.mil/Missions/Regulatory.aspx.
The Corps evaluation of a CWA Section 404 permit application involves multiple analyses,
including (1) evaluating the proposal's impacts in accordance with the National Environmental
Policy Act(NEPA) (33 CFR part 325), (2)determining whether the proposal is contrary to the
public interest(33 CFT § 320.4), and (3)determining whether the proposal complies with the
Section 404(b)(1) Guidelines (Guidelines) (40 CFR part 230).
The Guidelines specifically require that "no discharge of dredged or fill material shall be
permitted if there is a practicable alternative to the proposed discharge which would have less
adverse impact on the aquatic environment, so long as the alternative does not have other
significant adverse environmental consequences" (40 CFR § 230.10(a)). Time and money
spent on the proposal prior to applying for a CWA Section 404 permit cannot be factored into
the Corps decision whether there is a less damaging practicable alternative to the proposal.
Regulatory Branch (File No. MVP-2018-02941-BBY)
You are advised not to perform any work that requires DA authorization without obtaining
that authorization. If you have any questions about the Corps regulation of a particular
waterbody (including wetlands)or activity, please contact the Regulatory project manager listed
below and arrange for an on-site consultation. To proceed without first obtaining required DA
authorization violates Federal law and exposes the responsible party to criminal, civil, and
administrative penalties.
If you would like to request a jurisdictional determination, please contact the Corps
representative identified in the final paragraph of this letter. If you would like to apply for a DA
permit, please fill out the attached application form. Additional application guidance has been
included for your use. Please send your completed application form to the U. S. Army Corps of
Engineers, Regulatory Branch, 180 Fifth Street East—Suite 700, Saint Paul, MN 55101-1678.
If an application for a Corps permit has not yet been submitted, the project proposer may
request a pre-application consultation meeting with the Corps to obtain information regarding
the data, studies or other information that will be necessary for the permit evaluation process. A
pre-application consultation meeting is strongly recommended if the proposal has substantial
impacts to waters of the United States, or if it is a large or controversial project.
For further information or to request a pre-application consultation meeting, please contact
Brian Yagle in our St. Paul office at(651) 290-5975 or Brian.B.Yagle@usace.army.mil. In any
correspondence or inquiries, please refer to the Regulatory file number shown above.
Sincerely,
Brian Yagle
Project Manager
Cc:
Judy Weyrens—City of St. Joseph
Page 2 of 2
Joint Application Form for Activities Affecting Water Resources
in Minnesota
This joint application form is the accepted means for initiating review of proposals that may affect a water resource(wetland,
tributary, lake,etc.)in the State of Minnesota under state and federal regulatory programs. Applicants for Minnesota Department
of Natural Resources(DNR) Public Waters permits MUST use the MPARS online permitting system for submitting applications to
the DNR. Applicants can use the information entered into MPARS to substitute for completing parts of this joint application form
(see the paragraph on MPARS at the end of the joint application form instructions for additional information).This form is only
applicable to the water resource aspects of proposed projects under state and federal regulatory programs;other local
applications and approvals may be required. Depending on the nature of the project and the location and type of water resources
impacted,multiple authorizations may be required as different regulatory programs have different types of jurisdiction over
different types of resources.
Regulatory Review Structure
Federal
The St. Paul District of the U.S.Army Corps of Engineers(Corps)is the federal agency that regulates discharges of dredged or fill
material into waters of the United States(wetlands,tributaries, lakes,etc.) under Section 404 of the Clean Water Act(CWA)and
regulates work in navigable waters under Section 10 of the Rivers and Harbors Act. Applications are assigned to Corps project
managers who are responsible for implementing the Corps regulatory program within a particular geographic area.
State
There are three state regulatory programs that regulate activities affecting water resources. The Wetland Conservation Act
(WCA) regulates most activities affecting wetlands. It is administered by local government units(LGUs)which can be counties,
townships,cities,watershed districts,watershed management organizations or state agencies(on state-owned land).The
Minnesota DNR Division of Ecological and Water Resources issues permits for work in specially-designated public waters via the
Public Waters Work Permit Program(DNR Public Waters Permits). The Minnesota Pollution Control Agency(MPCA)under Section
401 of the Clean Water Act certifies that discharges of dredged or fill material authorized by a federal permit or license comply
with state water quality standards.One or more of these regulatory programs may be applicable to any one project.
Required Information
Prior to submitting an application,applicants are strongly encouraged to seek input from the Corps Project Manager and LGU staff
to identify regulatory issues and required application materials for their proposed project. Project proponents can request a pre-
application consultation with the Corps and LGU to discuss their proposed project by providing the information required in
Sections 1 through 5 of this joint application form to facilitate a meaningful discussion about their project. Many LGUs provide a
venue(such as regularly scheduled technical evaluation panel meetings)for potential applicants to discuss their projects with
multiple agencies prior to submitting an application.Contact information is provided below.
The following bullets outline the information generally required for several common types of determinations/authorizations.
• For delineation approvals and/or jurisdictional determinations,submit Parts 1,2 and 5,and Attachment A.
• For activities involving CWA/WCA exemptions,WCA no-loss determinations,and activities not requiring mitigation,
submit Parts 1 through 5,and Attachment B.
• For activities requiring compensatory mitigation/replacement plan,submit Parts 1 thru 5,and Attachments C and D.
• For local road authority activities that qualify for the state's local road wetland replacement program,submit Parts 1
through 5,and Attachments C, D(if applicable),and E to both the Corps and the LGU.
Minnesota Interagency Water Resource Application Form February 2014 Page 1 of 11
Submission Instructions
Send the completed joint application form and all required attachments to:
U.5 Army Corps of Engineers.Applications may be sent directly to the appropriate Corps Office. For a current listing of areas of
responsibilities and contact information,visit the St. Paul District's website at:
http://www.nivp.usace.army.mil/Missions/Regulatory.aspx and select"Minnesota"from the contact Information box.
Alternatively,applications may be sent directly to the St. Paul District Headquarters and the Corps will forward them to the
appropriate field office.
Section 401 Water Quality Certification:Applicants do not need to submit the joint application form to the MPCA unless
specifically requested. The MPCA will request a copy of the completed joint application form directly from an applicant when they
determine an individual 401 water quality certification is required for a proposed project.
Wetland Conservation Act Local Government Unit: Send to the appropriate Local Government Unit.If necessary,contact your
county Soil and Water Conservation District(SWCD)office or visit the Board of Water and Soil Resources(BWSR)web site
(www.bwsr.state.mn.us)to determine the appropriate LGU.
DNR Public Waters Permitting: In 2014 the DNR will begin using the Minnesota DNR Permitting and Reporting System(MPARS)for
submission of Public Waters permit applications(https://webappsll.dnr.state.mn.us/mpars/public/authentication/login).
Applicants for Public Waters permits MUST use the MPARS online permitting system for submitting applications to the DNR. To
avoid duplication and to streamline the application process among the various resource agencies,applicants can use the
information entered into MPARS to substitute for completing parts of this joint application form. The MPARS print/save function
will provide the applicant with a copy of the Public Waters permit application which,at a minimum,will satisfy Parts one and two
of this joint application. For certain types of activities,the MPARS application may also provide all of the necessary information
required under Parts three and four of the joint application. However,it is the responsibility of the Applicant to make sure that
the joint application contains all of the required information,including identification of all aquatic resources impacted by the
project(see Part four of the joint application). After confirming that the MPARS application contains all of the required
information in Parts one and two the Applicant may attach a copy to the joint application and fill in any missing information in the
remainder of the joint application.
Minnesota Interagency Water Resource Application Form February 2014 Page 2 of 11
Project Name and/or Number:
PART ONE: Applicant Information
If applicant is an entity(company,government entity,partnership,etc.),an authorized contact person must be identified. If the
applicant is using an agent(consultant, lawyer,or other third party)and has authorized them to act on their behalf,the agent's
contact information must also be provided.
Applicant/Landowner Name:
Mailing Address:
Phone:
E-mail Address:
Authorized Contact(do not complete if same as above):
Mailing Address:
Phone:
E-mail Address:
Agent Name:
Mailing Address:
Phone:
E-mail Address:
PART TWO: Site Location Information
County: City/Township:
Parcel ID and/or Address:
Legal Description(Section,Township,Range):
Lat/Long(decimal degrees):
Attach a map showing the location of the site in relation to local streets,roads, highways.
Approximate size of site(acres)or if a linear project,length(feet):
If you know that your proposal will require an individual Permit from the U.S.Army Corps of Engineers,you must provide the
names and addresses of all property owners adjacent to the project site. This information may be provided by attaching a list to
your application or by using block 25 of the Application for Department of the Army permit which can be obtained at:
http://www.mvp.usace.army.mil/Portals/57/docs/regulatory/ReguiatoryDocs/engform 4345 2012oct.pdf
PART THREE: General Project/Site Information
If this application is related to a delineation approval,exemption determination,jurisdictional determination,or other
correspondence submitted prior to this application then describe that here and provide the Corps of Engineers project number.
Describe the project that is being proposed,the project purpose and need,and schedule for implementation and completion.The
project description must fully describe the nature and scope of the proposed activity including a description of all project elements
that effect aquatic resources(wetland,lake,tributary,etc.)and must also include plans and cross section or profile drawings
showing the location,character,and dimensions of all proposed activities and aquatic resource impacts.
Minnesota Interagency Water Resource Application Form February 2014 Page 3 of 11
Project Name and/or Number:
PART FOUR: Aquatic Resource Impact' Summary
If your proposed project involves a direct or indirect impact to an aquatic resource (wetland, lake, tributary, etc.) identify each
impact in the table below. Include all anticipated impacts, including those expected to be temporary. Attach an overhead view
map, aerial photo, and/or drawing showing all of the aquatic resources in the project area and the location(s) of the proposed
impacts. Label each aquatic resource on the map with a reference number or letter and identify the impacts in the following table.
Type of Impact Duration of County,Major
Aquatic Existing Plant
Aquatic Resource (fill,excavate, Impact Overall Size of Watershed#,
Resource Type2 Community
ID(as noted on drain,or Permanent(P) Size of Impact Aquatic and Bank
(wetland,lake, 3 Type(s)in
overhead view) remove or Temporary Resource 4 Service Area#
tributary etc.) 1 Impact Area 5
vegetation) (T) of Impact Area
llf impacts are temporary;enter the duration of the impacts in days next to the"1". For example,a project with a temporary access fill that
would be removed after 220 days would be entered"T(220)".
2Impacts less than 0.01 acre should be reported in square feet. Impacts 0.01 acre or greater should be reported as acres and rounded to the
nearest 0.01 acre. Tributary impacts must be reported in linear feet of impact and an area of impact by indicating first the linear feet of impact
along the flowline of the stream followed by the area impact in parentheses). For example,a project that impacts 50 feet of a stream that is 6
feet wide would be reported as 50 ft(300 square feet).
3This is generally only applicable if you are applying for a de minimis exemption under MN Rules 8420.0420 Subp.8,otherwise enter"N/A".
4Use Wetland Plants and Plant Community Types of Minnesota and Wisconsin 3`d Ed.as modified in MN Rules 8420.0405 Subp.2.
sRefer to Major Watershed and Bank Service Area maps in MN Rules 8420.0522 Subp.7.
If any of the above identified impacts have already occurred,identify which impacts they are and the circumstances associated
with each:
PART FIVE: Applicant Signature
❑ Check here if you are requesting a pre-application consultation with the Corps and LGU based on the information you have
provided. Regulatory entities will not initiate a formal application review if this box is checked.
By signature below,I attest that the information in this application is complete and accurate. I further attest that I possess the
authority to undertake the work described herein.
Signature: Date:
I hereby authorize to act on my behalf as my agent in the processing of this application and to furnish, upon request,
supplemental information in support of this application.
The term"impact"as used in this joint application form is a generic term used for disclosure purposes to identify
activities that may require approval from one or more regulatory agencies. For purposes of this form it is not meant to
indicate whether or not those activities may require mitigation/replacement.
Minnesota Interagency Water Resource Application Form February 2014 Page 4 of 11
Project Name and/or Number:
Attachment A
Request for Delineation Review, Wetland Type Determination, or
Jurisdictional Determination
By submission of the enclosed wetland delineation report, I am requesting that the U.S.Army Corps of Engineers,St. Paul District
(Corps)and/or the Wetland Conservation Act Local Government Unit(LGU)provide me with the following(check all that apply):
❑Wetland Type Confirmation
❑ Delineation Concurrence. Concurrence with a delineation is a written notification from the Corps and a decision from the LGU
concurring, not concurring,or commenting on the boundaries of the aquatic resources delineated on the property.Delineation
concurrences are generally valid for five years unless site conditions change. Under this request alone,the Corps will not address
the jurisdictional status of the aquatic resources on the property,only the boundaries of the resources within the review area
(including wetlands,tributaries, lakes,etc.).
❑ Preliminary Jurisdictional Determination.A preliminary jurisdictional determination(PJD)is a non-binding written indication
from the Corps that waters,including wetlands, identified on a parcel may be waters of the United States. For purposes of
computation of impacts and compensatory mitigation requirements,a permit decision made on the basis of a PJD will treat all
waters and wetlands in the review area as if they are jurisdictional waters of the U.S. PJDs are advisory in nature and may not be
appealed.
❑Approved Jurisdictional Determination.An approved jurisdictional determination (AJD) is an official Corps determination that
jurisdictional waters of the United States are either present or absent on the property.AJDs can generally be relied upon by the
affected party for five years.An AID may be appealed through the Corps administrative appeal process.
In order for the Corps and LGU to process your request,the wetland delineation must be prepared in accordance with the 1987
Corps of Engineers Wetland Delineation Manual,any approved Regional Supplements to the 1987 Manual,and the Guidelines for
Submitting Wetland Delineations in Minnesota(2013).
http://www.mvp.usace.army.mil/Missions/Regulatory/DelineationJDGuidance.aspx
Minnesota Interagency Water Resource Application Form February 2014 Page 5 of 11
Project Name and/or Number:
Attachment B
Supporting Information for Applications Involving Exemptions, No Loss
Determinations, and Activities Not Requiring Mitigation
Complete this part if you maintain that the identified aquatic resource impacts in Part Four do not require wetland
replacement/compensatory mitigation OR if you are seeking verification that the proposed water resource impacts are either
exempt from replacement or are not under CWA/WCA jurisdiction.
Identify the specific exemption or no-loss provision for which you believe your project or site qualifies:
Provide a detailed explanation of how your project or site qualifies for the above. Be specific and provide and refer to attachments
and exhibits that support your contention.Applicants should refer to rules(e.g.WCA rules),guidance documents(e.g. BWSR
guidance,Corps guidance letters/public notices),and permit conditions(e.g.Corps General Permit conditions)to determine the
necessary information to support the application.Applicants are strongly encouraged to contact the WCA LGU and Corps Project
Manager prior to submitting an application if they are unsure of what type of information to provide:
Minnesota Interagency Water Resource Application Form February 2014 Page 6 of 11
Project Name and/or Number:
Attachment C
Avoidance and Minimization
Project Purpose,Need,and Requirements.Clearly state the purpose of your project and need for your project. Also include a
description of any specific requirements of the project as they relate to project location,project footprint,water management,
and any other applicable requirements.Attach an overhead plan sheet showing all relevant features of the project(buildings,
roads,etc.),aquatic resource features(impact areas noted)and construction details(grading plans,storm water management
plans,etc.), referencing these as necessary:
Avoidance. Both the CWA and the WCA require that impacts to aquatic resources be avoided if practicable alternatives exist.
Clearly describe all on-site measures considered to avoid impacts to aquatic resources and discuss at least two project alternatives
that avoid all impacts to aquatic resources on the site.These alternatives may include alternative site plans,alternate sites,and/or
not doing the project.Alternatives should be feasible and prudent(see MN Rules 8420.0520 Subp.2 C).Applicants are encouraged
to attach drawings and plans to support their analysis:
Minimization. Both the CWA and the WCA require that all unavoidable impacts to aquatic resources be minimized to the greatest
extent practicable. Discuss all features of the proposed project that have been modified to minimize the impacts to water
resources(see MN Rules 8420.0520 Subp.4):
Off-Site Alternatives. An off-site alternatives analysis is not required for all permit applications. If you know that your proposal
will require an individual permit(standard permit or letter of permission)from the U.S.Army Corps of Engineers,you may be
required to provide an off-site alternatives analysis. The alternatives analysis is not required for a complete application but must
be provided during the review process in order for the Corps to complete the evaluation of your application and reach a final
decision. Applicants with questions about when an off-site alternatives analysis is required should contact their Corps Project
Manager.
Minnesota Interagency Water Resource Application Form February 2014 Page 7 of 11
Project Name and/or Number:
Attachment D
Replacement/Compensatory Mitigation
Complete this part if your application involves wetland replacement/compensatory mitigation not associated with the local road
wetland replacement program.Applicants should consult Corps mitigation guidelines and WCA rules for requirements.
Replacement/Compensatory Mitigation via Wetland Banking.Complete this section if you are proposing to use credits from an
existing wetland bank(with an account number in the State wetland banking system)for all or part of your
replacement/compensatory mitigation requirements.
Bank
Wetland Bank Major Credit Type
County Service Number of Credits
Account# Watershed# (if applicable)
Area#
Applicants should attach documentation indicating that they have contacted the wetland bank account owner and reached at
least a tentative agreement to utilize the identified credits for the project.This documentation could be a signed purchase
agreement,signed application for withdrawal of credits or some other correspondence indicating an agreement between the
applicant and the bank owner. However,applicants are advised not to enter into a binding agreement to purchase credits until the
mitigation plan is approved by the Corps and LGU.
Project-Specific Replacement/Permittee Responsible Mitigation.Complete this section if you are proposing to pursue actions
(restoration,creation, preservation,etc.)to generate wetland replacement/compensatory mitigation credits for this proposed
project.
Corps Mitigation Bank
WCA Action Eligible Credit% Credits Major
1 Compensation Acres 3 County Service
for Credit 2 Requested Anticipated Watershed#
Technique Area#
1Refer to the name and subpart number in MN Rule 8420.0526.
2Refer to the technique listed in St.Paul District Policy for Wetland Compensatory Mitigation in Minnesota.
31f WCA and Corps crediting differs,then enter both numbers and distinguish which is Corps and which is WCA.
Explain how each proposed action or technique will be completed(e.g.wetland hydrology will be restored by breaking the tile )
and how the proposal meets the crediting criteria associated with it.Applicants should refer to the Corps mitigation policy
language,WCA rule language,and all associated Corps and WCA guidance related to the action or technique:
Attach a site location map,soils map, recent aerial photograph,and any other maps to show the location and other relevant
features of each wetland replacement/mitigation site. Discuss in detail existing vegetation,existing landscape features,land use
(on and surrounding the site),existing soils,drainage systems(if present),and water sources and movement. Include a
topographic map showing key features related to hydrology and water flow(inlets, outlets,ditches,pumps,etc.):
Minnesota Interagency Water Resource Application Form February 2014 Page 8 of 11
Project Name and/or Number:
Attach a map of the existing aquatic resources,associated delineation report,and any documentation of regulatory review or
approval.Discuss as necessary:
For actions involving construction activities,attach construction plans and specifications with all relevant details. Discuss and
provide documentation of a hydrologic and hydraulic analysis of the site to define existing conditions, predict project outcomes,
identify specific project performance standards and avoid adverse offsite impacts. Plans and specifications should be prepared by
a licensed engineer following standard engineering practices. Discuss anticipated construction sequence and timing:
For projects involving vegetation restoration, provide a vegetation establishment plan that includes information on site
preparation,seed mixes and plant materials,seeding/planting plan(attach seeding/planting zone map),planting/seeding
methods,vegetation maintenance,and an anticipated schedule of activities:
For projects involving construction or vegetation restoration,identify and discuss goals and specific outcomes that can be
determined for credit allocation. Provide a proposed credit allocation table tied to outcomes:
Provide a five-year monitoring plan to address project outcomes and credit allocation:
Discuss and provide evidence of ownership or rights to conduct wetland replacement/mitigation on each site:
Quantify all proposed wetland credits and compare to wetland impacts to identify a proposed wetland replacement ratio.Discuss
how this replacement ratio is consistent with Corps and WCA requirements:
By signature below,the applicant attests to the following(only required if application involves project-specific/permittee
responsible replacement):
• All proposed replacement wetlands were not:
• Previously restored or created under a prior approved replacement plan or permit
• Drained or filled under an exemption during the previous 10 years
• Restored with financial assistance from public conservation programs
• Restored using private funds,other than landowner funds,unless the funds are paid back with interest to the individual
or organization that funded the restoration and the individual or organization notifies the local government unit in
writing that the restored wetland may be considered for replacement.
• The wetland will be replaced before or concurrent with the actual draining or filling of a wetland.
• An irrevocable bank letter of credit,performance bond,or other acceptable security will be provided to guarantee successful
completion of the wetland replacement.
• Within 30 days of either receiving approval of this application or beginning work on the project, I will record the Declaration of
Restrictions and Covenants on the deed for the property on which the replacement wetland(s)will be located and submit proof
of such recording to the LGU and the Corps.
Applicant or Representative: Title:
Signature: Date:
Minnesota Interagency Water Resource Application Form February 2014 Page 9 of 11
Project Name and/or Number:
Attachment E
Local Road Replacement Program Qualification
Complete this part if you are a local road authority(county highway department,city transportation department,etc.)seeking
verification that your project(or a portion of your project)qualifies for the MN Local Government Road Wetland Replacement
Program(LGRWRP). If portions of your project are not eligible for the LGRWRP,then Attachment D should be completed and
attached to your application.
Discuss how your project is a repair,rehabilitation,reconstruction,or replacement of a currently serviceable road to meet
state/federal design or safety standards/requirements.Applicants should identify the specific road deficiencies and how the
project will rectify them.Attach supporting documents and information as applicable:
Provide a map, plan,and/or aerial photograph accurately depicting wetland boundaries within the project area.Attach associated
delineation/determination report or otherwise explain the method(s) used to identify and delineate wetlands.Also attach and
discuss any type of review or approval of wetland boundaries or other aspects of the project by a member or members of the local
Technical Evaluation Panel(TEP)or Corps of Engineers:
In the table below,identify only the wetland impacts from Part 4 that the road authority has determined should qualify for the
LGRWRP.
Wetland Impact ID Type of Impact Size of Impact County,Major Watershed#,
Existing Plant Community
(as noted on (fill,excavate, (square feet or1 and Bank Service Area#of
overhead view) drain) acres to 0.01) Type(s) in Impact Area Impact2
1Use Wetland Plants and Plant Community Types of Minnesota and Wisconsin 3"'Ed.as modified in MN Rules 8420.0405 Su bp.2.
2Refer to Major Watershed and Bank Service Area maps in MN Rules 8420.0522 Subp.7.
Discuss the feasibility of providing onsite compensatory mitigation/replacement for important site-specific wetland functions:
Please note that under the MN Wetland Conservation Act,projects with less than 10,000 square feet of wetland impact are
allowed to commence prior to submission of this notification so long as the notification is submitted within 30 days of the impact.
The Clean Water Act has no such provision and requires that permits be obtained prior to any regulated discharges into water of
the United States. To avoid potential unauthorized activities,road authorities must,at a minimum,provide a complete application
to the Corps and receive a permit prior to commencing work.
By signature below,the road authority attests that they have followed the process in MN Rules 8420.0544 and have determined
that the wetland impacts identified in Part 4 are eligible for the MN Local Government Road Wetland Replacement Program.
Road Authority Representative: Title:
Signature: Date:
Minnesota Interagency Water Resource Application Form February 2014 Page 10 of 11
Technical Evaluation Panel Concurrence: Project Name and/or Number:
TEP member: Representing:
Concur with road authority's determination of qualification for the local road wetland replacement program?n Yes ❑ No
Signature: Date:
TEP member: Representing:
Concur with road authority's determination of qualification for the local road wetland replacement program?❑Yes ❑ No
Signature: Date:
TEP member: Representing:
Concur with road authority's determination of qualification for the local road wetland replacement program? ❑Yes ❑ No
Signature: Date:
TEP member: Representing:
Concur with road authority's determination of qualification for the local road wetland replacement program?❑Yes ❑ No
Signature: Date:
Upon approval and signature by the TEP,application must be sent to: Wetland Bank Administration
Minnesota Board of Water&Soil Resources
520 Lafayette Road North
Saint Paul,MN 55155
Minnesota Interagency Water Resource Application Form February 2014 Page 11 of 11
Judy Weyrens
From: Horton, Becky(DNR) <becky.horton@state.mn.us>
Sent: Wednesday, October 31, 2018 1:07 PM
To: Judy Weyrens
Subject: St.Joseph Distribution Center EAW- DNR comments
Attachments: 2018-10-31-StJoesephsDistributionCenterEAW-DNRCmntLtr.pdf;2018-10-04-NoCo.pdf
Hi Judy,
Attached are comments from the DNR related to the St. Joseph Distribution Center EAW.
Becky
Rebecca Horton
Region Environmental Assessment Ecologist I Ecological and Water Resources
Minnesota Department of Natural Resources
1200 Warner Road
St. Paul, MN 55404
Phone: 651-259-5755
Fax: 651-772-7977
Email: becky.horton@state.mn.us
mndnr.gov
mDEATUPARTMENTRALRESOOUF
NRCES
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1
DEPARTMENT OF
NATURAL RESOURCES
Minnesota Department of Natural Resources
Division of Ecological&Water Resources
500 Lafayette Road, Box 25
St. Paul,MN 55155-4025
October 4,2018
Correspondence#ERDB 20190102
Ms. Kari Block
Westwood Professional Services, Inc.
12701 Whitewater Drive,Suite 300
Minnetonka, MN 55343
RE: Natural Heritage Review of the proposed St.Joseph Site,
T124N R29W Section 9;Stearns County
Dear Ms. Block,
As requested, the above project has been reviewed for potential effects to known occurrences of rare features.
Given the project details provided with the data request form,I do not believe the proposed project will negatively
affect any known occurrences of rare features.
The Natural Heritage Information System (NHIS), a collection of databases that contains information about
Minnesota's rare natural features, is maintained by the Division of Ecological and Water Resources, Department
of Natural Resources. The NHIS is continually updated as new information becomes available, and is the most
complete source of data on Minnesota's rare or otherwise significant species,native plant communities,and other
natural features. However, the NHIS is not an exhaustive inventory and thus does not represent all of the
occurrences of rare features within the state. Therefore, ecologically significant features for which we have no
records may exist within the project area. If additional information becomes available regarding rare features
in the vicinity of the project,further review may be necessary.
For environmental review purposes,the results of this Natural Heritage Review are valid for one year;the results
are only valid for the project location (noted above) and the project description provided on the NHIS Data
Request Form. Please contact me if project details change or for an updated review if construction has not
occurred within one year.
The Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as
a whole. Instead, it identifies issues regarding known occurrences of rare features and potential effects to these
rare features. If needed, please contact your DNR Regional Environmental Assessment Ecologist to determine
whether there are other natural resource concerns associated with the proposed project. Please be aware that
additional site assessments or review may be required.
Thank you for consulting us on this matter,and for your interest in preserving Minnesota's rare natural resources.
Please include a copy of this letter in any state or local license or permit application. An invoice will be mailed to
you under separate cover.
Sincerely,
scumm4AA
3
Samantha Bump
Natural Heritage Review Specialist
Samantha.Bump@state.mn.us
Links: DNR Regional Environmental Assessment Ecologist Contact Info
http://www.dnr.state.mn.us/eco/ereview/erp regioncontacts.html
Page 2 of 2
mlDEPARTMENT OF
NATURAL RESOURCES
October 31, 2018
Judy Weyrens
Administrator
75 Callaway St. E
St.Joseph, MN 56374
RE: St.Joseph Distribution Center EAW
Dear Judy Weyrens,
The Minnesota Department of Natural Resources(DNR) has reviewed the Environmental Assessment Worksheet
(EAW)for the St.Joseph Distribution Center.The EAW states that a warehouse and distribution facility will be
constructed, however it does not describe what products will be housed and transferred from this facility.This
information would be useful in order to fully assess whether all potential effects are accurately addressed within
the EAW.We offer the following specific comments for your consideration.
Related to the shoreland overlay district: Industrial projects are not listed as a permitted use in the shoreland
overlay district for a Tributary stream, which is the designation of the South Fork Watab River. Height within the
shoreland overlay district is limited to 25 feet.
• Page 4,Table 7.1 lists impervious surface and other buildings as covering approximately 52%of the land
surface. Impervious surface in the shoreland overlay district is limited to 25%. Efforts should be made to
create infiltration areas to mitigate the impacts of high impervious surface amounts and the resulting
potential changes in the floodplain (upstream as well as downstream).
• Page 5 states that variances will be requested for building height and reduction in setbacks.The
Shoreland overlay district ordinance for the City of St.Joseph indicates that industrial uses without
water-oriented needs must either be set back double the normal setback or substantially screened from
view from the water by vegetation or topography,assuming summer, leaf-on conditions.A reduction in
setbacks with added building height will not meet the requirements of the ordinance and planting plans
were included in the design pages of the EAW.These items must be considered by the City if a variance
request is received.
• Page 7 states that the City of St.Joseph is currently reviewing the Shoreland Ordinance.As a reminder,
the DNR must approve any changes to the city's shoreland ordinance.
Related to public waters impacts: The EAW does not adequately discuss potential impacts to the South Fork
Watab River,a DNR public water.
• Page 13 notes that the majority of the project will be treated by a single stormwater retention basin
approximately four acres in size,with the remainder of the areas treated in smaller basins.The smaller
basins are not shown on any of the diagrams.Any stormwater outfalls to the river will require Public
Waters permits from the DNR.
• Page 14 of the EAW states that a crossing of the South Fork Watab River is required for the project.
Currently there are four crossings of this public watercourse within a span of one mile.As shown in
Exhibit 3,there is an existing field entrance from County Road 2, north of the river, which should be
considered for access to the site.Additional crossings of the river for this project could further impact
this public resource. It is possible that the DNR may not be able to be issue a permit to cross the river at
this location if a less environmentally impacting solution exists,such as widening the existing culvert
Minnesota Department of Natural Resources • Ecological and Water Resources
1200 Warner Road,St. Paul, MN 55106
2
crossings on County Road 2.The building shown in the location of the field entrance could be shifted
slightly to the north to accommodate an entrance in this location. Mitigation for the river crossing(if
permitted)or widening of the existing culverts on County Road 2 will be required.Such mitigation may
include adding meanders to restore the river and its connection to the floodplain.A hydraulic capacity
study regarding potential changes to the floodplain as a result of the crossing and outfall will be
necessary.The study cannot merely match upstream and downstream culverts,as indicated in the EAW.
• Page 16: The statement that"no physical effects or alterations to surface waters are anticipated as a
consequence of site development" is incorrect.The addition of approximately 45 acres of impervious
surfaces will potentially make the watercourse much more flashy due to discharge from the storm pond
to the river. Depending upon the amount of discharge to the river from the outfall, there may be
significant scour as well.The act of placing culverts and fill into the channel of a watercourse is an
impact to the watercourse.Culverts remove that portion of stream bed channel unless sized
appropriately and buried to allow sediment to re-form inside the culvert. In addition,culverts do not
allow natural meandering of the stream within its floodplain and potentially narrow the channel
affecting hydraulics and increasing the possibility of impacts both upstream and down.The channel of
the Watab River has already been impacted through straightening, channelization, and realignment.As
stated above, a less environmentally impacting solution to adding to the number of crossings on the
Watab River would be to lengthen the culverts under County Road 2 and access from the north side of
the river where an existing entrance already exists.The impact area was not calculated and submitted as
a part of the EAW requested under this section.
Additional comments:
• Page 19: We understand the Natural Heritage Review letter had not been received prior to submittal of
the EAW.The review letter has since been completed and sent to the applicant(attached for your
record).The Natural Heritage Review letter concluded that no adverse impacts to rare species were
expected as a result of this project.We recommend considering utilizing native species for landscaping
to provide food and habitat for birds, pollinators, and other wildlife,as well as lesson watering and
landscaping requirements such as pesticides and herbicides.
• It appears that apportion of the building is proposed to be built over an existing tile line,that was placed
as a result of closing an open drainage ditch.This should be investigated during any onsite wetland
delineations and during project construction.
Feel free to contact area hydrologist Nicola Blake-Bradley(nicola.blake-bradlye@state.mn.us)with any
questions related to shoreland overlay district, public waters impacts and permitting
requirements/coordination.
On behalf of the DNR,thank you for your consideration of these comments.
Sincerely,
/s/Rebecca Horton
Region Environmental Assessment Ecologist
CC: Nicki Blake-Bradley, Area Hydrologist
Attachments: NHIS Review Letter
Minnesota Department of Natural Resources • Ecological and Water Resources
1200 Warner Road,St. Paul, MN 55106
Judy Weyrens
From: Breth, Katie - NRCS-CD,Waite Park, MN <katie.breth@mn.nacdnet.net>
Sent: Wednesday, October 31, 2018 1:18 PM
To: Judy Weyrens
Cc: Fuchs, Dennis - NRCS-CD,Waite Park, MN;Cymbaluk,Wayne - NRCS-CD,Waite Park,
MN;Weimann, Kyle - NRCS-CD,Waite Park, MN
Subject: Environmental Assessment Worksheet- St.Joseph Distribution Center Comments
Attachments: St.Joseph DC EAW for Distribution Final.pdf; Infiltration Flow Chart Guide.pdf
Good Afternoon Ms.Weyrens,
Stearns County Soil and Water Conservation District(SWCD)thanks you for the opportunity to provide comment on the
Environmental Assessment Worksheet—St.Joseph Distribution Center. Attached you will find the District's comment
letter and supporting document.
Stearns County SWCD would be happy to provide technical assistance at the request of the City and Rice Companies. It
is Stearns County SWCD's mission to provide local leadership in the conservation of soil,water and related resources
through programs,and partnerships with individuals, businesses,organization,and government.
If you have question, please contact District Administrator, Dennis Fuchs at(320)251-7800 ext3.
Kind Regards,
Kane'$re.th'
Source Water Protection Specialist
Stearns County Soil and Water Conservation District(SWCD)
110 2' Street South Suite 128
Waite Park, MN 56387
General Office Line (320)2517800 X3
Direct Line(320) 345-6482
Fax 1-855-205-6907
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(------.._
sus couNnII) cqr� Stearns Coun Soil & Water
9
. .` Conservation District
triERVATI t N DI ��� Steams County SWCD TeL(320)251-7800 ext.3
110 2"d Street South—Suite 128 Fax. 1-855-205-6907
Waite Park,MN 56387 Web.www.steamscountyswcd.net
October 31, 2018
City of St. Joseph
Attn: Judy Weyrens
75 Callaway Street East
St. Joseph, MN 56374
RE: Notice of Public Comment Period on Environmental Assessment Worksheet—
St.Joseph Distribution Center
Dear Ms.Weyrens,
This letter and its attachment are Steams County Soil and Water Conservation District's(SWCD)formal comments
to the Notice of Public Comment Period on the Environmental Assessment Worksheet—St. Joseph Distribution
Center. The comments are broken into two sections 1)potential impact and concerns to groundwater and drinking
water, and 2)other environmental concerns.
1) Groundwater/Drinking Water Comments:
The proposed Distribution Center is to be constructed within the St Joseph Drinking Water Supply Management
Area(DWSMA),within the ten-year groundwater capture zone, an area of very high groundwater vulnerability that
requires additional protection to ensure safe drinking water access to the city and other users. Contamination of the
aquifer and drinking water wells could result in the need to install expensive treatment equipment or to greatly limit
future capabilities to construct additional wells within the DWSMA.
We request that the City of St. Joseph(RGU)consider requiring additional precautions of Rice Companies
(Proposer)in order to safeguard the aquifer. In addition, the SWCD encourages the Proposer complete additional
site inspections to ensure compliance and drinking water resource impacts.
As you know, adding significant impervious surface alters the existing hydrology and impacts the recharge of the
aquifer. In the St. Joseph DWSMA,the soils are coarse textured and closely connected to the groundwater aquifer.
As such, the operation should take extra care to prevent potentially hazardous substances, including fuel, from
infiltrating through the subsurface materials.
The following are additional precautions to consider when considering the construction of the Distribution Center of
this size and magnitude within a very sensitive DWSMA:
• Surface Runoff: Surface water runoff from on-and off-site should be controlled to avoid infiltration in
all vulnerable portions of the DWSMA. The Minnesota Department of Health and Minnesota Pollution
Control Agency developed joint guidance for determining the applicability of infiltration in a Drinking
Water Supply Management Area (DWSMA). Attached to this letter is the step-by-step process for
determining if infiltration is allowed and appropriated in a DWSMA(Infiltration Flow Chart Guide).
Based on the information provided in the Environmental Assessment Worksheet(EAW)a higher level of
engineering review for stormwater infiltration in DWSMAs is recommended.
• Fuel Storage: Fuel storage should not occur in areas where geologic cover(topsoil) has been
removed. During construction, if equipment is fueled in areas where top soil has been removed it
should be done over an impervious pad or other surface where spills can be contained and cleaned up.
After construction is complete continue with proper fuel storage and have an emergency leak and spill
plan on hand.
• Post-Construction Site Runoff: Vegetation used for reclamation should be native species or similar
species that do not require regular or seasonal application of nutrients or pesticides.
Stearns County SWCD supports responsible industrial development as an important economic resource. However,
it is also imperative to protect and sustain the drinking water supply for the City of St. Joseph and others drawing
from the aquifer. We trust that the City of St. Joseph will find the appropriate balance between the two needs.
2) Other Environmental Comments
Question #6a. Project Description.
Appears the amount of project impact is being down-played. 745,000 sq ft(17.1 ac) of buildings is highlighted
vs the impact of the roads and parking needs to be included which pushes up the proposed impact to
1,051,974 sqft((24.15 ac) see Table 7.1 in the EAW). This does include the 11+ acres of landscaping.
Question #7. Cover Types.
Approximately 36 acres are to be disturbed in just the first phase but resulting in 24+ acres of final impervious
and another 11+ acres into lawn and landscaping. Look at strategies to minimize the construction site footprint
to the maximum extent practicable.
Question #8. Permits and approvals required.
Maybe missing the MPCA's NPDES/SDS Permit for Industrial Activity once the facility is operational. Wetland
Replacement Plan should not be needed. With an 86-acre site the wetlands should be able to be avoided.
Question #9. Land Use.
1St paragraph states no trails near site in which there is a trail immediately across County Road 2. 2nd
paragraph states that a variance may be needed for parking spaces. Please consider alternative strategies for
people to get to work. It is unclear if the variance would be needed for more or less parking spaces than
allowed. Preferably less than what is required. Under item ii, is the reference to the 2011 plan still valid since
there was a new plan recently adopted? Item iii b, is that referring to the old or new plan?
Question #10b. Soils and Topography.
•Page 2
Conservation design strategies and best management practices should be utilized to protect soils from
unnecessary disturbance and compaction. A practice to consider is to limit areas of disturbed soil and soil
compaction by controlling equipment movement on site by roping off areas before construction activity begins.
Use native, non-invasive plants for permanent cover establishment(example: use low maintenance buffalo
grass instead of turf grass). Make sure any topsoil that gets transported to the site is weed seed free to prevent
the spread of non-native and invasive species.
Question #11a. Water Resources.
The EAW appears not to identify the watershed areas providing hydrology to the existing wetlands. What will
guarantee wetland sustainability after the project has been completed?There is an assumption that wetlands
will allowed to be filled as part of this project. Highly recommend not to make that assumption since it is an 86-
acre site with room to build and still avoid the wetlands. There also appears to be an opportunity to be able to
restore stream and wetland functions and values of the once farmed site. Consider using pollinator friendly
native species within and around the project site (11 acres of landscaping).
Question#11b. Water Resources.
The EAW states "This wetland is a small isolated wetland that has had historic impacts from agriculture. The
planned onsite stormwater system will provide the infiltration benefits to the surrounding watershed that the
wetland is currently providing". It is more than just the wetland area that provides recharge to the aquifer. How
will this project account for the loss of 24 acres of recharge area to the aquifer? Especially if stormwater
infiltration is not allowed?
It is recommended that through the design of this development is done in a manner not to force future
development of a collector road to impact the wetland. A solution to this issue needs to be addressed so that
future impact to wetlands are avoided.
The rerouting of the agricultural ditch could be used as a feature in the overall landscaping and/or routed in a
manner to restore the hydrology to the existing wetland.
Utilize permeable surfaces such as porous asphalt, concrete, or a permeable pavement system with a higher
engineering review as required.
Strategies to increase tree cover within the project area should be included. Working trees located in
appropriate places and densities would reduce noise, help treat stormwater, calm traffic speeds, prevent snow
drifting, remove carbon and other pollutants, improve aesthetics and community health, provide wildlife habitat,
keep impervious surfaces cool reducing heat island effect, minimize impervious surface maintenance due to
exposure, and provide a more sustainable development through energy conservation.
Question #12. Contamination/Hazardous/Wastes.
How will the material be handled and stored so that the waste is not subject to stormwater and/or vandalism
during and after the construction process?
Question #13. Ecological resources.
There appears to be an opportunity of offset some of cumulative impacts (stream crossing) by restoring the
meanders to once straightened Watab River that flows through the site since the equipment necessary would
•Page 3
be onsite. Work through the SWCD for the restoration. The riparian corridor is identified as the most important
habitat on the site.
Question #18. Transportation.
Recommend the use of pervious pavements or other BMP's with higher engineering review to the maximum
extent practicable to reduce the amount and impact of impervious surfaces.
Question#19. Cumulative potential effects.
This project will increase the cumulative impacts within the area. Cumulative impacts can only be minimized by
including low impact development(ex. minimize impervious surfaces)and other sustainable design strategies
(ex. Limiting construction disturbance to protect the soil from being unnecessarily compacted). Based on the
before and after estimated cover types there appears to be over 11 acres of lawn and landscaping that could
be utilized to offset a lot of the cumulative potential effects through wetland and habitat restoration.
In review, there are many opportunities to further minimize the negative environmental impacts of this project.
By incorporating low impact development techniques, the overall environmental impacts could be significantly
reduced.
Thank you for the opportunity to comment. I would encourage the City of St. Joseph and Rice Companies to request
technical assistance from the Steams County SWCD to develop strategies to minimize the overall impact of the
proposed development to our natural resources. If you have questions, please contact me at(320)251-7800 ext 3.
Sincerely,
Dennis J. Fuchs
Administrator
Attachment: Infiltration Flow Chart Guide
•Page 4
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Judy Weyrens
From: Judy Weyrens
Sent: Thursday, November 1, 2018 8:40 AM
To: Randy Sabart;William.Huston@westwoodps.com
Subject: FW: Public Comment Period - EAW: St.Joseph Distribution Center
Attachments: EAW comment- 20181031.docx
From:GINA DULLINGER [mailto:ginadullinger@yahoo.com]
Sent:Wednesday,October 31,2018 1:33 PM
To:Judy Weyrens<jweyrens@cityofstjoseph.com>
Cc:Therese Haffner<thaffner@cityofstjoseph.com>
Subject: Public Comment Period -EAW:St.Joseph Distribution Center
I have reviewed the Environmental Assessment Worksheet (EAW) for the St. Joseph Distribution Center
proposed by Rice Companies, and have prepared the attached written comments as part of the public review and
comment period which ends today, October 31, 2018.
Of paramount concern(as detailed in the attached comments)is the failure of the project proposer to
acknowledge the project's impact on the transportation system. The project will be accessing existing roadways
at an intersection that is already prone to problems, and additional traffic will be taxing on the I-94 interchange
where there are no turn lanes or acceleration/bypass lanes. The analysis in the EAW fails to account for the type
of vehicle traffic generated by the project, which due to the project characteristics, will presumably consist of a
large percentage of tractor-trailers.
Thank you for your time and consideration. I can be contacted by phone at 320.291.4883 with any questions.
Sincerely,
Gina Dullinger
15552 County Road 51
St. Joseph, MN 56374
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To: iwevrensAcityofstioseph.com Remove this sender from my allow list
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1
Comments on EAW—St. Joseph Distribution Center
Gina Dullinger
6.b, Paragraph 6:
"It is anticipated that construction will entail moving approximately 400,000 cubic yards of material around
the site. No export of material from the site is anticipated."
As the project is proposed to be constructed in phases over a period of ten years,with the total quantity of
material anticipated to be moved around the site(with no export), I am concerned about the existence of
large stockpiles of material remaining on the site between various phases of construction. Material
stockpiles on site are prone to erosion by wind and water. In addition, they are visually obtrusive.With the
proposed project site being located at a major point of entry to the City of St. Joseph, unsightly dirt piles
would be a detriment to the image of the City of St. Joseph.
6.c:
The project development is described to include "streets, surface parking, warehouse facilities, truck
fueling and maintenance, stormwater ponding, and green space" (6.b, paragraph 3). These uses don't
appear to be included in the tabulation of Project Magnitude, as only the 745,000 square foot of gross
building area is included.What is the project magnitude in terms of other uses—streets, parking, fueling
areas, etc.?
Table 7.1
The tabulation of cover types is unclear as to what is included as"Impervious Surface"and
"Other/Buildings."
9.a.ii:
Per the City's Comprehensive Plan (2011), "Future development patterns will respect the mobility function
of 1-94 and CSAH 2;therefore, the development of future collector streets is imperative. Commercial
and/or high value industrial nodes will be afforded excellent access from collector streets."
The proposed development does not have access to any collector streets, and any collector streets that
have been planned for the area (in accordance with the City's Transportation Plan)are being either
removed or marginalized by the proposed development.
While it is proposed to relocate the northern collector street to the north property boundary, thus planning
for future development, the proposed project is not going to be connected to this collector?This appears
to be in direct contradiction to the intent expressed in the City's Comprehensive Plan and furthered in the
Transportation Plan. As a large industrial distribution center, it seems foolish to not connect the site to a
collector street, and instead to rely upon a local street for access.
While realigning a future collector street to the south of the site may serve future needs of adjacent land
uses, it is unclear as to the extents and alignment of the right-of-way which is proposed to be dedicated
during the platting process. How will the project proposer dedicate right of way, when as it states in 19.b,
"the project proposer does not currently own or have options on adjacent lands"?The City has previously
identified collector streets as being a priority—this priority should be upheld.
9.a.iii, Paragraph 3:
The project proposer recognizes that the development"must conform to the requirements of the
[Shoreland] Overlay" but does not provide any information regarding how the project will conform. Simply
relying on the City to either revise the ordinance or approve of a variance is irresponsible.
Comments on EAW—St. Joseph Distribution Center
Gina Dullinger
9.b, Paragraph 2:
"The proposed project is compatible with existing land use and planned land uses in the area as it offers
light industrial and General Business activities that are compatible with the industrial and commercial land
uses in this area as contemplated by the City's Comprehensive Plan."
The City's Comprehensive Plan adopted in 2018, shows the entire site as Light Industrial according to the
Future Land Use Plan. What"General Business"or"commercial"activities are proposed?
11.b.i.1:
"Due to timing of the project, sanitary sewer may not yet be in place for the first phase of the project. If
that is the case, the site will use a Subsurface Sewage Treatment System (SSTS)or holding tank until the
City sanitary sewer system is extended."
While it is stated that the SSTS/holding tank will be designed to Stearns County standards, in cooperation
with the City, care should be taken to ensure that adequate depth, capacity, and structural integrity is
provided. The system should be designed for an adequate life span, should the sewer extension not
occur in a timely fashion.
11.b.ii:
"Given the project area is currently undeveloped, it is reasonable to assume that a portion of stormwater
leaves the site as runoff."
Currently the site is an active farm field, with significant pervious area. Care must be taken in quantifying
the existing runoff that leaves the site under the current undeveloped conditions.
"If the snow is not hauled off site, stockpiles will need to be placed such that they do not negatively impact
the stormwater treatment facilities or Watab Creek."
No other mention is made within the document of Watab Creek—is this the South Fork Watab River?
11.b.iv.a:
Efforts should be taken to minimize impacts to existing wetlands. If impacts are required, options for
onsite mitigation should be explored before resorting to purchasing wetland credits to mitigate for the
construction impacts.
"The planned onsite stormwater system will provide the infiltration benefits to the surrounding watershed
that the wetland is currently providing."
Restrictions on infiltration are discussed in 11.b.ii, and the majority of the stormwater treatment is
proposed through a wet sedimentation basin, therefore, it is doubtful that the wetland's benefit to the
watershed will be mimicked through any proposed onsite infiltration basins.
"When this impact occurs, it will be a part of the City of St. Joseph's permitting process for the new road,
and the city will be responsible for permitting and replacement for the wetland impact."
The City's Transportation plan shows the north collector street bisecting the proposed site (see Exhibit 6),
and it is the project proposer that is proposing to shift this street to the north property boundary. As it is
the project proposer that is requesting the future street be shifted north, and thus causing impacts to the
Comments on EAW—St. Joseph Distribution Center
Gina Dullinger
wetland, I believe the project proposer should have some responsibility for the wetland impacts caused by
the collector street. The location as proposed in the Transportation Plan has no wetland impacts.
13.b:
"This query indicated two records within 1-mile of the project area."
What is the"terrestrial community" and the"vertebrate species"which will not be affected by the project?
18:
"No traffic impact study or mitigation is required as the peak hour traffic that will be generated from the
site is less than 250 vehicles and total daily trips will be less than 2,500."
While it may be true that the total average daily traffic generated by the project is a mere 680 trips per
day, with a peak hour of 160 trips per hour—based on the type and scale of facility, it appears safe to
assume that most of these trips will be from tractor-trailers and not from passenger vehicles. No mention
is made of the type of vehicle traffic generated by the site—I believe this is a significant oversight in
the analysis. Furthermore, no discussion is made as to the"effect on traffic congestion on affected
roads"as required by 18.b, nor is the project's impact on the regional transportation system discussed.
While the means of actual connection of the project to existing roadways is unclear based on the site plan
(Exhibit 3), it appears as though the sole means of ingress/egress for the project will be a connection to
Minnesota Street at Leaf Road north of County Road 2.This intersection of County Road 2 and
Minnesota Street has proved to be a problematic intersection—the site of fatalities and numerous
vehicular crashes. In fact, the intersection has already been redesigned once in its short lifetime! The
vertical alignment at the intersection and the superelevation of County Road 2 through the curve provides
significant challenges to vehicles making turns at the intersection. The speed of traffic traveling County
Road 2, and the proximity of the 1-94 interchange adds to the complexity of the intersection. Currently, the
north leg of this intersection sees very little traffic, and all the proposed traffic from the project will be
added here.
Tractor-trailers leaving the site will presumable enter County Road 2 traveling southbound in an effort to
access 1-94. Their right turns onto County Road 2 will have a significant impact on the travel along County
Road 2, as will their turning left to access eastbound 1-94 and turning right to access westbound 1-94.
With the traffic signal constructed to the north at the intersection of County Road 2 and County Road 75,
access to and from 1-94 is already complicated—there are no turn lanes or acceleration/bypass lanes,
and vehicles frequently pass on the shoulders to avoid turning vehicles, which poses a significant danger
on the roadway. In addition, tractor-trailers arriving at the site will cause significant problems to the travel
along County Road 2 as again, there are no turn lanes or acceleration/bypass lanes currently.
Even if the future northern collector street was to be constructed, and access from the site to County
Road 2 was to be from the collector, significant improvements to County Road 2 would be required to
accommodate the existing traffic and the addition of tractor-trailers from the project. Turn lanes,
acceleration/bypass lanes, and intersection improvements would all likely be warranted.
The project proposer takes the stance that because the trip generation falls beneath the threshold, there
will be no transportation impacts due to the project. The analysis provided in the EAW fails to account for
the type of traffic generated by the project, and in failing to do so, the analysis incorrectly assumes no
impacts will occur. There will be transportation impacts to the affected roads which should be at the very
least minimized, if not mitigated!
Comments on EAW—St. Joseph Distribution Center
Gina Dullinger
While"no mitigation measures have been identified as being required,"what are the measures that will be
taken to MINIMIZE project related transportation effects (per 13.c)?