1997-10-21 EAW Review
Minnesota Department of Natural Resources
500 Lafayette Road 10
St. Paul, Minnesota 55155-40_
October 21, 1997
Garrison Hale, Administrator
City of Albertville
5975 Main Avenue NE
Albertville, MN 55301
RE: Cedar Creek Residential Development and Golf Course
Environmental Assessment Worksheet (EA W)
Dear Mr. Hale,
The Department of Natural Resources (DNR) has reviewed the EA W for the Cedar Creek Residential
Development and Golf Course project. We offer the following comments for your consideration.
Item 8, Permits and Approvals Required, should list the County Ditch Authority if there will be
outlets into the county ditch identified in Item 18. Use of the county ditch for storm sewer outlets may
require an outlet fee and permit.
In the fish and wildlife habitat discussion offered in Item lla, assertions are offered that the site
contains no fishery resources. This is incorrect. County Ditch #9 likely provides some seasonal fish
habitat, especially for potential use by northern pike during spring spawning runs and subsequent
fingerling rearing. County Ditch #9 flows into County Ditch #21 and ultimately into Pelican Lake,
Beebe Lake, Mud Lake, Uhl Lake, and the Mississippi River; each of these basins exhibits a substantial
fish community. In addition, ditches are often inhabited year-round by mudminnows, sticklebacks,
various dace, minnow and shiner species. County Ditches #9 & #21 support such species and are an
important component of the ecosystem. Ensuring that project-generated runoff is properly pretreated
and managed can allow for post-project habitat retention in the county ditch.
Given the previous discussion, we note that Item 12, Physical Impacts on Water Resources, states,
"Minor relocation of portions of existing drainage ways within the Project area will be performed to
conform with overall platting and stormwater and water quality controls." The modification or
"relocation" of natural waterways implied in this statement causes concern because such activity
reduces, or even eliminates, the existing natural resource functions and values (e.g., fish habitat) that
are present. Development should conform as much as possible to the existing landform to minimize the
overall impacts to the ecosystem. Regarding the text in the EAW, does this mean that runoff patterns
will be changed or altered, or that additional drainages will be created? In general, natural drainages
should not be altered.
Item 13, Water Appropriation, indicates that water appropriation will be required, either for ongoing
course watering needs or temporarily during project construction. A DNR water appropriation permit
DNR Information: 612-296-6157, 1-800-766-tlOOO . TTY: 612-296-5484, 1-800-657-3929
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Garrison Hale, City Administrator
October 21, 1997
will be required for any activity that results in the appropriation of 10,000 gallons of water per day, or
1,000,000 gallons per year. It should also noted that the permit numbers identified in Item 13c are
incorrect and are most likely the MDH unique well numbers; the correct DNR permit number is 79-
3116. We recommend contacting Larry Kramka, Area Hydrologist, at (320) 255-2984 for information
regarding potential permit requirements.
Regarding stormwater runoff management issues addressed in Item 18, we commend the proposer for
considering stormwater management beyond a "standard" water quality treatment perspective. The
proposed detention measures will also address water runoff quantity issues as well, which we
enthusiastically support for not only the County Ditch system but also from the floodplain management
perspective. To further limit the project's consequences, we recommend incorporating runoff quantity-
based measures to those areas that drain to the School Lake watershed.
Also regarding stormwater management, the retention ponds should be heavily vegetated to improve
their ability to take up excess nutrients, particularly phosphorus, which would normally be taken up by
crops and fringe wetland vegetation stands. Additional measures include maintenance of vegetated
buffers between the golf course and ponds and County Ditch #9. Retention of enough natural buffer
along County Ditch #9 within the golf course and residential development will also retain some residual
upland habitat for wildlife species such as shore birds, songbirds, and some waterfowl, furbearers,
amphibians, and insects beneficial to the local ecosystem.
In regulating stormwater quantities, attention should be paid to discharge rates because as the amount of
runoff increases, there are implications on fish and invertebrate natural history. Severe fluctuations in
flows, regardless of local watershed size, will cause weak year classes of fish and invertebrates. This
can have a "rippling "effect throughout the food chain and ecosystem. Assessment of adequate storage
for the project should include consideration of this factor.
We offer the following comments to clarify or enhance information contained in the EA Wand require
no response.
Golf course turf management often involves the use of various chemical agents, including fertilizers,
herbicides, and pesticides. Spills or other situations, often unintentional, can result in delivery of these
agents to natural watercourses or wastewater treatment facilities. We recommend development of a
contingency plan for these types of events so that golf course personnel have a clearly identified path of
action available to limit potential human health and natural resource impacts.
Regarding project-related habitat losses, we recommend incorporation of landscape design features
considered "friendly" to wildlife, which is best achieved by retaining and protecting natural features
found at the site.
Thank you for the opportunity to review this project. We do not recommend preparation of an
environmental impact statement (EIS) based upon natural resource considerations. We look forward to
receiving your record of decision and responses to comments. Minnesota Rules part 4410.1700,
subparts 4 & 5, require you to send us your Record of Decision within five days of deciding this
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